CSA2010 Industry Briefing July 2010

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

FMC-CSA-10-002
Presentation Agenda
• Why Change?
• CSA 2010: Defined
• Test and Implementation
• Summary
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FMC-CSA-10-002
Why Change?
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FMC-CSA-10-002
Commercial Motor Vehicle Fatalities
Rate of Commercial Motor Vehicle Fatalities is Leveling Off
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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
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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.
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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
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FMC-CSA-10-002
CSA 2010 Defined
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FMC-CSA-10-002
A New Operational Model (Op-Model)
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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
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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)
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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
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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
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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
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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
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FMC-CSA-10-002
Example of SafeStat vs SMS
The following slides provide
examples of key differences between
SafeStat and the new SMS
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Carrier Measurement: SafeStat Results
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Carrier Measurement: SMS Results
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FMC-CSA-10-002
Violation Details Provided in SMS
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FMC-CSA-10-002
Further Drilldown in SMS
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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
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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
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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
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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
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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)
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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
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FMC-CSA-10-002
Safety Management Cycle
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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)
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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
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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.
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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)
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FMC-CSA-10-002
CSA 2010 Test and
National Roll-out
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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)
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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
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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
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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
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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
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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
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FMC-CSA-10-002
Summary
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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
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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)
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For more information, please visit:
csa2010.fmcsa.dot.gov

CSA2010 Industry Briefing July 2010

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Editor's Notes