CSA2010 Industry Briefing July 2010

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Overview of CSA 2010 program; why and how.

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  • CSA 2010 is a pro-active initiative to improve the efficiency and effectiveness of FMCSA’s enforcement and compliance program.Uses ALL roadside inspection results and crash reports to identify safety deficienciesEmploys a wider array of interventions tailored to problems instead of solely the time-intensive Compliance Review processEnables more carriers to be contacted earlierRequires sustained accountability of carriers AND increases accountability of drivers
  • The Agency has given consideration to individual driver ratings, but this would happen sometime in the future, not as a part of CSA 2010 implementation.  In order for the Agency to begin rating drivers new authorities would be required through reauthorization AND rulemakingThe next slide will address driver data that will be available to carriers and drivers in the near future
  • Clear understanding that data collected at the roadside is a critical component of all traffic safety initiatives. For example, CSA 2010, TACT etc…Important Note to bring up: ONLY information on inspection reports get to FMCSA, an inspection has to take place. For example, if a driver receives a speeding ticket but no inspection is performed, that will not show up in the measurement system.So for both the carriers and the enforcement agencies that use this data its importance cannot be underestimated. During the summer of 2008 FMCSA and its state partners working on the Op Model test (FSWG) identified a need to enhance the uniformity and quality of roadside violation data. During discussions the consensus was that the data in its current form is fundamentally sound, valid and useableHowever, opportunities exist to enhance the quality of data and in turn, improve the integrity of all traffic safety programs.
  • The effort to enhance the quality and uniformity of the roadside violation data started at the Fall 2008 CVSA meeting with the creation of an Ad-hoc committee to look at this issue. Currently this committee is managing an Alliance-wide effort to enhance the overall quality and uniformity of the data. The effort has four core components listed on the screen.Consistent documentation of roadside inspection and violation data- Through a FMCSA funded high priority grant, CVSA began work on guidance that will promote and/or mandate the consistent documentation of roadside inspection and violation data. Standardized processes for challenging data- This initiative will provide procedural guidance on the management of the roadside data challenge process through our Data Q’s management systemIncreased awareness of the high level goals of the inspection program- This component of the roadside data uniformity initiative will focus on the increased importance of the roadside violation data and an understanding of how the data will be used. The goal is to broaden the understanding that every inspection counts and that there is a direct relation between the collection of the data and the end use of the data. Uniform inspection selections system-CVSAis currently facilitating discussions regarding the policies that govern when and how vehicles should be selected for an inspection. The goal is to focus discussions on implementing a valid and consistent vehicle and driver inspection selection process operated within the scope of a jurisdiction’s rules and policies that will promote roadside data uniformity.
  • Good quality data has always been a priority for FMCSA and with the implementation of CSA 2010 it continues to be a primary focus.  FMCSA has been working with States on complete reporting of large truck and bus crash and inspection data. Over that past several years FMCSA developed a comprehensive data quality program, and implemented several efforts to evaluate and monitor data that are reported, improve data, and correct errors in the data.  The DataQs system is an electronic means for filing concerns about Federal and State data Through this system, data concerns are automatically forwarded to the appropriate office for resolution. The system also allows filers to monitor the status of each filing.
  • The agency is in the process of developing a DataQs guide. This guidance is intended to act as a best practice for the States in resolving challenges and will help improve consistency and standardize the resolution process. The Guide will include; timeframes for responses, documents required to corroborate challenges are valid, sources available to validate data, recommended ‘due process’ procedures, the appeals process and others. Until the guide is available here are a few tips and suggestions. There are certain types of challenges that are inappropriate. …..Complete documentation will expedite the resolution of a challenge, therefore be thorough! The review of a challenge is a research effort. Effectively a challenger is going in front of a “judge” and the judge is going to be looking for evidence. The State needs as much corroborating data or support documentation as possible in order to accurately resolve a challenge. Challengers should attach as much “evidence” as possible to refute the data that is displayed in FMCSA’s systems.
  • Per statutory language, a safety rating can only be issued to a carrier following a Compliance Review; and a Compliance Review is defined as an on-site investigation of a carrier; therefore, a rating can only be issued during an investigation that occurs at the carrier’s place of business.Because the onsite focused review only looks at a few areas of a carrier’s regulatory compliance, only a Conditional or Unsatisfactory rating may be applied based on findings.  The Agency cannot provide a Satisfactory rating since it will not have reviewed all areas.  As is current policy, a carrier may apply for an administrative request for upgrade and provide evidence of corrective action.
  • Register for a Compass Account to access the various FMCSA websites“Raise awareness that every inspection counts and every violation counts” –train drivers to get good inspections and remind them to have due diligence with their responsibilities (i.e. pre-trip inspections)
  • CSA2010 Industry Briefing July 2010

    1. 1. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 Comprehensive Safety Analysis (CSA) 2010 A New Way To Measure and Address Commercial Motor Vehicle Safety Industry Briefing July 2010 U.S. Department of Transportation Federal Motor Carrier Safety Administration
    2. 2. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 Presentation Agenda • Why Change? • CSA 2010: Defined • Test and Implementation • Summary 2
    3. 3. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 Why Change? 3
    4. 4. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 Commercial Motor Vehicle Fatalities Rate of Commercial Motor Vehicle Fatalities is Leveling Off 4
    5. 5. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 A Need For A More Agile, Efficient Program • Current Operational Model Limitations – Limited intervention tool-box for Safety Investigators (SIs) – Safety fitness determination tied to compliance review – Focus largely on carriers • Limited number of Federal/State investigators compared to large number of carriers – U.S. Department of Transportation’s (U.S. DOT) Federal Motor Carrier Safety Administration (FMCSA) regulates ~725,000 interstate and foreign- based truck and bus companies • U.S. DOT/FMCSA audit (compliance review) is labor- intensive – Only able to reach < 2% (~12,000) of total carrier population annually 5
    6. 6. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 Comprehensive Safety Analysis 2010 What is CSA 2010? CSA 2010 is an important initiative to improve the efficiency and effectiveness of FMCSA’s enforcement and compliance program to achieve the Agency’s mission to reduce commercial motor vehicle (CMV) crashes, fatalities, and injuries. 6
    7. 7. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 What is Changing? • The way FMCSA assesses carrier safety – Identifies unsafe carrier and driver behaviors that lead to crashes – Uses all safety-based roadside inspection violations • How FMCSA addresses carrier safety issues – Reaches more carriers earlier and more frequently – Improves efficiency of investigations • Focuses on specific unsafe behaviors • Identifies root causes • Defines and requires corrective actions 7
    8. 8. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 CSA 2010 Defined 8
    9. 9. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 A New Operational Model (Op-Model) 9
    10. 10. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 A New Operational Model (Op-Model) 10
    11. 11. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 A New Operational Model (Op-Model) 11
    12. 12. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 A New Operational Model (Op-Model) 12
    13. 13. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 A New Operational Model (Op-Model) 13
    14. 14. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 Op-Model: Three Core Components 1. New Safety Measurement System (SMS) Improved ability for earlier identification of demonstrated safety problems 2. New intervention process Employs an array of interventions instead of the current principal option -- a labor-intensive compliance review 3. New approach to Safety Fitness Determination (SFD) SFD would be tied to current safety performance; not limited to results of acute/critical violations from a compliance review 14
    15. 15. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 New Safety Measurement System CSA 2010 introduces a new safety measurement system (SMS) that… • Uses crash records and ALL roadside inspection safety- based violations to determine carrier/driver safety • Assigns weights to time and severity of violations based on relationship to crash risk • Calculates safety performance based on 7 Behavior Analysis and Safety Improvement Categories (BASICs) • Triggers the intervention process (eventually would feed Safety Fitness Determination) 15
    16. 16. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 SMS BASICs SMS BASICs focus on behaviors linked to crash risk 1. Unsafe Driving (Parts 392 & 397) 2. Fatigued Driving (Hours-of-Service); Parts 392 & 395) 3. Driver Fitness (Parts 383 & 391) 4. Controlled Substances/Alcohol (Parts 382 & 392) 5. Vehicle Maintenance (Parts 393 & 396) 6. Cargo-Related (Parts 392, 393, 397 & HM) 7. Crash Indicator 16
    17. 17. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 SafeStat vs SMS Today’s Measurement System: SafeStat CSA 2010 SMS Organized by four broad categories - Safety Evaluation Areas (SEAs): Accident, Driver, Vehicle, and Safety Management Organized by seven specific BASICs Identifies carrier for a compliance review (CR) Identifies safety problems to determine whom to investigate and where to focus the investigation Uses only out-of-service (OOS) and moving violations from roadside inspections. Uses all safety-based roadside inspection violations No impact on safety rating Used to propose adverse safety fitness determination based on carriers’ current on-road safety performance (future) Violations are not weighted based on relationship to crash risk Violations are weighted based on relationship to crash risk Assesses carriers only Assesses carriers and drivers – the driver SMS is a tool for investigators to identify drivers with safety problems during carrier investigations 17
    18. 18. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 New Agency Plans for Drivers • The new Carrier Measurement System provides internal tools, including enhanced information on individual drivers, to investigators to more effectively and efficiently conduct carrier investigations – Tools allow for targeted sampling using enhanced driver information – Follow up on serious violations • Under CSA 2010, individual drivers will not be assigned safety ratings or safety fitness determinations 18
    19. 19. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 New Agency Plans for Drivers (cont’d) • Other Agency initiatives are underway, including the Pre-employment Screening Program (PSP) – PSP was mandated by Congress and is not a part of CSA 2010 – “Driver Profiles” from FMCSA’s Driver Information Resource (DIR) are available to carriers through PSP – Driver Profiles will only be released with driver authorization – PSP is currently available, access and additional information can be found at www.psp.fmcsa.dot.gov 19
    20. 20. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 Example of SafeStat vs SMS The following slides provide examples of key differences between SafeStat and the new SMS 20
    21. 21. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 Carrier Measurement: SafeStat Results 21
    22. 22. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 Carrier Measurement: SMS Results 22
    23. 23. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 Violation Details Provided in SMS 23
    24. 24. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 Further Drilldown in SMS 24
    25. 25. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 Carrier Access to Data When will the Carriers’ SMS results be made available? •Currently, only test state carriers have access to SMS results by using the Comprehensive Safety Information (CSI) system •FMCSA is providing all carriers an early review of their own safety data by BASIC (As of April 12, 2010) •Non-test carriers’ SMS results will be available to carriers in August •Public will have access to carrier SMS results in the winter of 2010 25
    26. 26. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 Roadside Data Uniformity • Data collected at the roadside is the foundation of all data driven traffic safety initiatives • CSA 2010 relies on roadside data in its SMS Methodology • The CSA 2010 SFD methodology would use roadside data as a component of the safety fitness determinations 26
    27. 27. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 Roadside Uniformity-Background • Effort organized into four core initiatives: 1. Consistent documentation of roadside inspection and violation data 2. Standardized processes for making a Request for Data Review (RDR) 3. Increased awareness of high-level goals of the inspection program a) Good inspections can support systematic enforcement program b) Screening vs. Inspection 4. Uniform inspection selection processes 27
    28. 28. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 FMCSA Data Quality • Quality data is key to CSA 2010 Operational Model • Comprehensive data quality program initiated over 5 years ago • Current data is useful and meaningful; improvements can always be made • DataQs provides the public (including carriers and drivers) the opportunity to request a data review to ensure the accuracy of federal and state reported data 28
    29. 29. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 Requests for Data Review • Improper Data Review Requests: • Driver fired, please remove all these violations • Crash not our fault, please remove • Driver caused the violation, please remove • Violation was committed by an owner operator or other carrier that was leased to our operation when the violation occurred, please remove • Company with a valid lease agreement to an owner operator challenges that the violation should be assigned to the owner operator • Helpful Suggestions: • Attach document(s) that support the challenge • Be specific and detailed in your narrative • An owner operator with a valid lease agreement with another company submitting a challenge should include a lease agreement • Ensure contact information is accurate and updated • Check the status frequently, (additional information may be requested) 29
    30. 30. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 New Interventions Process The New Interventions Process addresses the… • WHAT Discovering violations and defining the problem • WHY Identifying the cause or where the processes broke down • HOW Determining how to fix it/prevent it through use of Safety Management Cycle and Safety Improvement Resources 30
    31. 31. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 Safety Management Cycle 31
    32. 32. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 New Intervention Tools New intervention tools reach more carriers and influence safety compliance earlier •Warning Letters •Investigations − Offsite Investigations − Onsite Investigations - Focused − Onsite Investigations - Comprehensive •Follow-on corrective actions − Cooperative Safety Plan (CSP) − Notice of Violation (NOV) − Notice of Claim (NOC) − Operations Out-of-Service Order (OOS) 32
    33. 33. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 Current vs CSA 2010 Intervention Process Current CR Process CSA 2010 Intervention Process Broad one-size-fits-all investigation Array of interventions can be tailored to address extent and scope of specific safety deficiencies Resource intensive for enforcement agencies and time consuming for carrier/fewer carriers contacted Less resource intensive for enforcement agencies and less time consuming for carrier/more carriers contacted Focuses on broad compliance based on rigid set of acute/critical violations Focuses on improving behaviors that are linked to crash risk Discovers what violations exist at that time Discovers what safety problem(s) are, why they exist, and how to correct them Major safety problems result in fines (Notice of Claim (NOC)) When problems found, major focus on carrier proving corrective action; significant problems continue to result in fines Focuses on carrier Expands focus to driver violations 33
    34. 34. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 Safety Fitness Determination (SFD) SFD would: • Incorporate on-road safety performance via new SMS which is updated on a monthly basis • Continue to include major safety violations found as part of CSA 2010 investigations • Produce a Safety Fitness Determination (SFD) of – Unfit or – Marginal or – Continue Operation Draft rulemaking is currently in review within DOT; NPRM expected to be published in late 2010. 34
    35. 35. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 Current Rating Process in CSA 2010 • CSA 2010 incorporates the existing safety rating process and will continue to do so until SFD would go into effect • Drivers will not be rated • Ratings are issued based on investigation findings: – On-site comprehensive investigations can result in Satisfactory, Conditional or Unsatisfactory ratings – Onsite focused investigations can result in Conditional or Unsatisfactory Ratings – Offsite investigations do not result in a rating – Carriers can request an administrative review of its safety rating(§385.17) 35
    36. 36. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 CSA 2010 Test and National Roll-out 36
    37. 37. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 CSA 2010 Field Test Operational-Model Field Test Design: • Design completed January 2008 – Divides representative carriers into comparable test and control groups Operational-Model Field Test: • February 2008 – June 2010 • Designed to test validity, efficiency, and effectiveness of new model • Independent evaluation by University of Michigan Transportation Research Institute (UMTRI) • Colorado, Georgia, Missouri, New Jersey (first test group) 37
    38. 38. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 100% States in Field Test • Additional states – Spring 2009: MT (AB), MN (ON) – Fall 2009: KS, MD, DE • 100% of the State participates in CSA 2010 – Offers a more accurate picture of efficiencies, capabilities and benefits – Tests integration with national program goals and Congressional mandates – Provides more data to evaluate test, including workload and workforce analyses 3838
    39. 39. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 Preliminary Results So far, CSA 2010 is: • Reaching its goal of contacting more carriers – Research shows more contacts equals improved safety performance • Resulting in strong enforcement; similar to current model • Employing the full array of investigations – Investigations in test states have been done in the following proportions • Onsite Investigations – Comprehensive (~25%) • Onsite Investigations – Focused (~45%) • Offsite Investigations (~30%) • Following up with carriers: 50% of investigations result in one of following: • Notice of Claim or Violation • Cooperative Safety Plan • Driver-Specific follow-on activities – Notice of Violation – Notice of Claim 39
    40. 40. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 More Preliminary Results Warning letters are having a positive impact: • Almost 5,500 sent • Almost 50% of recipients logged in to view their data and safety assessments • Feedback from test states indicate that some carriers appreciate the early alert 40
    41. 41. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 Roll-Out Schedule Guiding Principles • Integrate lessons-learned from 9-state test and feedback from national stakeholder outreach • Create a phased approach to methodically step stakeholders into new measurement system (SMS): – Drive industry to information on how they will be measured; urge immediate safety improvements – Build a foundation for enforcement staff to understand and effectively utilize SMS by internalizing concepts of behaviors and BASICs • Maximize resources – Respond to industry information needs – Use new measurement system to identify and prioritize carriers with safety problems – Train field staff in new intervention process 41
    42. 42. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 CSA 2010 Roll-out Schedule April 12 – November 30, 2010 • Motor carriers can preview their own data by seeing their roadside inspections/violations and crash events organized by Behavior Analysis and Safety Improvement Category (BASIC) Summer 2010 • June 30th – The Operational Model (Op-Model) Test ended • July – The four test states partially applying the CSA 2010 Operational Model (Colorado, Georgia, Missouri, and New Jersey ) will fully switch over to CSA 2010, bringing total CSA 2010 states to nine • August – The Safety Measurement System (SMS) Methodology will be modified to increase its effectiveness – Motor carriers will be able to see an assessment of their violations based on the new Carrier Safety Measurement System (CSMS) that will replace SafeStat later in 2010 Fall/Winter 2010 – SafeStat will be replaced by the CSMS, which will be available to the public, including shippers and insurance companies – FMCSA/States will prioritize enforcement using the CSMS – FMCSA will begin to issue warning letters to carriers with deficient BASICs – Roadside inspectors will use the CSMS results to identify carriers for inspection Coming in 2011 – Safety Fitness Determination Notice of Proposed Rulemaking (NPRM) is scheduled to be released – Enforcement staff will be trained, and new interventions will be implemented state-by-state 42
    43. 43. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 Summary 43
    44. 44. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 In Summary… CSA 2010 introduces improvements in three main areas 1. New Safety Measurement System – More comprehensive profile of carriers and drivers – Better able to pinpoint the source of safety problems – Better identifies high crash-risk behavior 2. New interventions process and tools – More efficient/effective enforcement and compliance process – Wider range of interventions to influence compliance earlier – Match intervention with level of safety performance 3. Proposed change in evaluation: Safety Fitness Determination – Assess safety performance of larger segment of industry – Based on roadside performance and intervention results – Rating will be updated more often, conveying current safety condition 44
    45. 45. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 What Can Carriers Do To Prepare Now? • Educate Yourselves and Your Employees: – Understand the SMS Methodology and the BASICs – Check the website for information and updates (http://csa2010.fmcsa.dot.gov) – Raise awareness that every inspection counts and every violation counts • Ensure compliance – Review inspections and violation history over the past 2 years – Address safety problems now – Educate drivers about how their performance impacts their own driving record and the safety assessment of the carrier • Check and update records – Motor Carrier Census (Form MCS -150) – Routinely monitor and review inspection and crash data – Question potentially incorrect data (DataQs: https://dataqs.fmcsa.dot.gov) 45
    46. 46. U.S. Department of Transportation Federal Motor Carrier Safety Administration Industry Briefing, July 2010 FMC-CSA-10-002 46 For more information, please visit: csa2010.fmcsa.dot.gov

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