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CSA: A Way to Measure and Address Commercial Motor Vehicle Safety Industry Briefing December 2012

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CSA: A Way to Measure and Address Commercial Motor Vehicle Safety Industry Briefing December 2012 – PowerPoint PPT presentation

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Title: CSA: A Way to Measure and Address Commercial Motor Vehicle Safety Industry Briefing December 2012


1
CSA A Way to Measure and Address Commercial
Motor Vehicle Safety Industry Briefing December
2012
2
Agenda
  • What is Compliance, Safety, Accountability (CSA)?
  • CSAs Results
  • CSAs Three Core Components
  • Summary
  • Safety Measurement System (SMS) Improvements

3
What Is CSA?
  • CSA is the Federal Motor Carrier Safety
    Administrations (FMCSA) enforcement and
    compliance program used to achieve the Agencys
    mission to prevent commercial motor vehicle (CMV)
    crashes, fatalities, and injuries.
  • CSA was designed, field-tested, and refined over
    five years prior to national launch in December
    2010.

4
CSA Operational Model
  • Model based on SFD rulemaking

5
CSAs Results
  • Violations per roadside inspection are down 8
  • Driver violations per roadside inspection are
    down 10
  • The SMS has enough performance data to evaluate
    nearly 40 of active carriers
  • Those carriers are responsible for more than 92
    of reported crashes
  • As of January 2012, FMCSA sent more than 50,000
    warning letters
  • An independent evaluation of the field test
    showed that most carriers improved safety
    compliance after receiving a warning letter or
    other intervention
  • The website housing the SMS hosted 48 million
    user sessions in 2012 a 60 increase over the
    prior year

6
CSAs Three Core Components
  • An SMS that
  • Identifies unsafe carrier and driver behaviors
    that lead to crashes
  • Uses all safety-based roadside inspection
    violations to assess compliance with existing
    regulations
  • Includes investigation findings
  • A Safety Interventions process that
  • Includes an array of interventions
  • Focuses on specific unsafe behaviors
  • Identifies causes of safety problems
  • Defines and requires corrective actions
  • An SFD process that
  • Requires rulemaking, expected to begin in early
    2013
  • Would be tied to on-the-road safety performance
    and replace current system

7
1. The SMS
  • The SMS is FMCSAs workload prioritization tool
    that
  • Uses State-reported crash records, all roadside
    inspection safety-based violations, and certain
    violations found during inspections to identify
    carriers for interventions
  • Previous system used only out-of-service and
    certain moving violations
  • Uses 24 months of data recent events are
    weighted more heavily than older ones
  • Assigns severity weights to violations based on
    relationship to crash risk

8
1. The SMS (cont.)
  • The SMS is FMCSAs workload prioritization tool
    that
  • Calculates safety performance based on seven
    BASICs
  • Triggers the Safety Interventions process (e.g.,
    warning letters, investigations)
  • Will feed the new SFD process once rulemaking is
    completed
  • Is designed to be continually improved as more
    information is available through data and
    analysis

9
The SMS BASICs
  • BASICs focus on behaviors linked to crash risk
  • Unsafe Driving (Parts 392 397)
  • Hours-of-Service (HOS) Compliance
  • (Parts 392 395)
  • Driver Fitness (Parts 383 391)
  • Controlled Substances/Alcohol (Parts 382 392)
  • Vehicle Maintenance (Parts 392, 393 396)
  • Hazardous Materials (HM) Compliance (Federal
    Motor Carrier Safety Regulation Part 397 HM
    Regulations (HMRs) Parts 171, 172, 173, 177, 178,
    179, and 180)
  • Crash Indicator

10
The SMS and Investigation Findings
  • Serious Violations found during investigations
    are factored into BASIC measurements
  • May place a carrier over the Intervention
    Threshold in one or more BASICs results
    displayed on a carriers record for 12 months
  • Serious Violations generally
  • Identify noncompliance so severe that immediate
    corrective action is needed
  • Relate to a carriers management and/or
    operational controls

11
The SMS Screenshots
The following slides provide examples of the SMS
results and data
12
Carrier SMS Results
13
Carrier SMS Results (cont.)
14
Violation Details in the SMS
15
Further Drilldown in the SMS
16
Further Drilldown in the SMS (cont.)
17
Further Drilldown in the SMS (cont.)
18
Information on Drivers
  • The SMS provides investigators with information
    on individual drivers to
  • Enable investigators to conduct more effective
    and efficient investigations
  • Allow for a targeted sampling of drivers for
    those carriers already identified for
    investigations
  • Facilitate follow-up for Serious Violations
  • Under CSA, individual drivers are not assigned
    safety ratings or safety fitness determinations
  • The SMS has been made available to the public to
    facilitate transparency

19
Information on Drivers (cont.)
  • Pre-employment Screening Program (PSP)
  • Mandated by Congress and is not a part of CSA
  • Driver Profiles from FMCSAs Driver Information
    Resource are available to carriers through PSP
  • Driver Profiles are only released with driver
    authorization and include inspection and crash
    data
  • PSP is currently available access and additional
    information can be found at www.psp.fmcsa.dot.gov

20
Carrier Access to Data
  • Carriers have access to their own full SMS
    results and BASIC measurements
  • The public has access to the SMS results and
    BASIC measurements except for percentile ranks
    for the Crash Indicator and HM Compliance BASICs
  • HM Compliance BASIC violations are available to
    the public
  • The decision regarding what to display was based
    on feedback and analyses throughout the field
    test and Data Preview
  • List of crashes is available to the public

21
Roadside Inspection Data Uniformity
  • Data collected by inspectors at the roadside is
    the foundation of all data-driven commercial
    vehicle traffic safety initiatives
  • The CSAs SMS relies on roadside inspection data
  • The CSA SFD methodology would use roadside data
    as a component of safety fitness determinations

22
Roadside Uniformity - Background
  • Effort organized into four initiatives
  • Consistent documentation of roadside inspection
    and violation data
  • Standardized processes for making a request for
    data review (RDR)
  • Increased awareness of high-level inspection
    program goals
  • Good inspections can support systematic
    enforcement program
  • Screening vs. inspection
  • Uniform inspection selection processes

23
FMCSA Data Quality
  • Quality data is key to CSA
  • Comprehensive data quality program initiated over
    five 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

24
RDRs
  • Improper RDRs
  • 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 states that the violation should
    be assigned to the owner-operator
  • Helpful Suggestions
  • Attach document(s) that support the data review
    request.
  • Be specific and detailed in your narrative.
  • An owner-operator with a valid lease agreement
    with another company submitting a data review
    request should include a lease agreement.
  • Ensure contact information is accurate and
    updated.
  • Check the status frequently (additional
    information may be requested).

25
CSAs Three Core Components
  • Safety Measurement System (SMS)
  • Safety Interventions process
  • Safety Fitness Determination (SFD) process

26
2. Safety Interventions Process
  • The Safety 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 by
    using the Safety Management Cycle (SMC)

27
SMC
28
Intervention Tools
  • Warning letters
  • Investigations
  • Offsite Investigations
  • Onsite Focused Investigations
  • Onsite Comprehensive Investigations
  • Follow-on corrective actions
  • Cooperative Safety Plan
  • Notice of Violation (NOV)
  • NOC
  • Operations Out-of-Service Order (OOSO)

29
Intervention Tools Implementation Status
  • Onsite Focused and Comprehensive Investigations
    and Direct NOVs now implemented in all States
  • Includes application of the SMC
  • Offsite Investigations implemented in 10 States
  • Further deployment will occur with IT
    enhancements
  • Automated warning letters implemented in all
    States
  • More than 50,000 sent as of January 2012

30
CSAs Three Core Components
  • The SMS
  • Safety Interventions process
  • SFD process

31
Current Safety Rating Process
  • Ratings are issued based on investigation
    findings
  • Onsite 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
    their safety ratings (385.17)
  • Drivers are not rated

32
3. SFD Process
  • SFD would
  • Incorporate on-road safety performance via the
    SMS, which is updated on a monthly basis
  • Continue to include major safety violations found
    as part of CSA investigations
  • Produce an SFD to determine if a carrier is unfit
    to operate

Draft rulemaking is currently in review within
USDOT
33
Summary
34
CSA Improves Three Core Areas
  • The SMS
  • More meaningful and actionable assessment of
    carrier and driver safety performance
  • Better able to pinpoint the source of safety
    problems
  • Better identifies high crash-risk behavior
  • Interventions process and tools
  • More efficient/effective enforcement and
    compliance process
  • Wider range of interventions to influence
    compliance earlier
  • Matches intervention type with level of safety
    performance
  • Proposed change in evaluation SFD
  • Assesses safety performance of larger segment of
    industry
  • Based on roadside performance and intervention
    results
  • Rating will be updated more often, conveying
    current safety condition

35
What Can Carriers Do?
  • Educate yourselves and your employees
  • Understand the SMS Methodology and the BASICs
  • Subscribe to the CSA Outreach Website and check
    it often for information and updates, including
    carrier preview periods for major SMS changes
    (http//csa.fmcsa.dot.gov)
  • Ensure compliance
  • Review inspections and violation history over
    the past two years
  • Log in to the SMS, review the BASICs, and address
    safety problems immediately (http//ai.fmcsa.dot.g
    ov/SMS/Default.aspx)
  • Check and update records
  • Update the Motor Carrier Census (Form MCS -150)
  • Routinely monitor and review inspection and crash
    data
  • Question potentially incorrect data (DataQs
    https//dataqs.fmcsa.dot.gov)

36
CSA Timeline
  • December 2010 The SMS released to the public
  • FMCSA began to prioritize workload using the SMS
  • Enforcement staff began using the new
    interventions
  • Warning letter intervention was launched
  • BASIC information was made available to Roadside
    Inspectors for use in determining who to inspect
    (new Inspection Selection System)
  • October 2011 SMC implemented
  • Investigators began using SMC during
    investigations to explain where safety issues are
    occurring and ways to resolve them
  • Coming in 2012 and beyond
  • Offsite Investigations will be incorporated into
    the investigators toolkits
  • SFD will pass through rulemaking

37
The SMS Improvements
38
The SMS Improvement Process
  • The SMS is designed and intended to be
    continually improved.
  • Better technology, new data, and continuing
    analysis will provide both means and opportunity
    for refinement
  • FMCSA has taken a systematic approach to rolling
    out improvements.
  • Prioritizing and packaging changes at regular
    intervals
  • Providing enforcement personnel and motor
    carriers a preview period prior to implementation

39
Schedule of SMS Changes
  • March 2012
  • Motor carriers and enforcement staff previewed
    the SMS changes
  • Preview participants are able to view the
    carriers percentile ranks without the changes
    (normal/public SMS site) and with the
    enhancements (preview site)
  • March 27, 2012 through July 30,2012
  • Federal Register Docket open for comments about
    the SMS Preview
  • December 2012
  • SMS public website updated with the SMS changes
    discussed
  • Both logged-in users and the general public can
    see percentile ranks
  • Crash Indicator and the HM Compliance BASIC
    percentiles are available to only logged-in users

40
The SMS Changes
  • Strengthened the Vehicle Maintenance BASIC by
    incorporating cargo/load securement violations
    from the Cargo-Related BASIC
  • Changed the Cargo-Related BASIC to the HM
    Compliance BASIC to better identify safety
    problems related to HM
  • Better aligned the SMS with IEP regulations
  • Aligned violations included in the SMS with CVSA
    inspection levels by eliminating vehicle
    violations derived from driver-only inspections
    and driver violations from vehicle-only
    inspections

41
The SMS Changes (cont.)
  • More accurately identifying carriers involved in
    transporting HM or passengers
  • Modified the SMS Display to
  • Change terminology (replace terms Insufficient
    Data and Inconclusive) to fact-based definitions
  • Break out crashes with injuries and crashes with
    fatalities

42
The SMS Changes (cont.)
  • Strengthened the Vehicle Maintenance BASIC by
    incorporating cargo/load securement violations
    from the Cargo-Related BASIC
  • Allows for appropriate workload prioritization
    while reducing a bias in the Cargo-Related BASIC
    whereby flatbed operators are disproportionately
    identified for intervention
  • ?This bias is the reason that the Cargo-Related
    BASIC was not public
  • Analysis shows that moving these violations will
    result in more effective and efficient workload
    prioritization
  • The Vehicle Maintenance BASIC remains public

43
The SMS Changes (cont.)
  • Changed the Cargo-Related BASIC to the HM
    Compliance BASIC
  • Removed load securement violations so that only
    HM violations remain
  • Provided a more objective comparison with respect
    to HM compliance consequences of crashes and
    cargo spills can be greatly exacerbated when HM
    are involved
  • Enabled enforcement staff to better identify and
    address HM safety issues
  • HM Compliance BASIC percentile is only available
    to logged-in enforcement users and motor carriers

44
The SMS Changes (cont.)
  • Better aligned the SMS with IEP regulations
  • Previously, the SMS did not use violations
    associated with the condition of an Intermodal
    Equipment Provide (IEP) trailer (if it was
    assigned to an IEP)
  • FMCSA has recently revised IEP logic to properly
    attribute each IEP trailer violation to either
    the IEP or the motor carrier based on the ability
    of the driver to find the violation as part of a
    pre-trip inspection
  • IEP violations assigned to a motor carrier are
    now used towards calculating the carriers
    Vehicle Maintenance BASIC

45
The SMS Changes (cont.)
  • Eliminated vehicle violations derived from
    driver-only inspections and driver violations
    from vehicle-only inspections
  • The SMS includes Level III (driver-only)
    inspections in the Vehicle Maintenance BASIC only
    when vehicle violations are noted on the
    inspection
  • Enforcement and industry have raised concerns
    that some vehicle violations fall outside the
    scope of the inspection and could bias the BASIC
    results
  • Analysis showed that this concern merited
    attention, so FMCSA has
  • ?Removed vehicle violations found during
    driver-only inspections
  • ?Removed driver violations found during
    vehicle-only inspections

46
The SMS Changes (cont.)
  • More accurately identifying carriers involved in
    transporting HM or passengers
  • These carriers are subject to more stringent
    thresholds in the SMS

HM Carriers New definition enables FMCSA to focus resources on carriers involved in the majority of placardable HM transport
At least 2 HM placardable vehicle inspections 1 within past 12 months At least 5 total inspections indicated as HM placardable vehicle inspections
Passenger Carriers New definition removes many low-capacity vehicles (e.g., vans and taxis) that are generally outside of FMCSAs authority
Adds all for-hire carriers with 9-15 passenger capacity vehicles and private carriers with 16 capacity Removes all carriers with only 1-8 capacity and private carriers with 1-15 passenger capacity
47
The SMS Changes (cont.)
  • Modified the SMS Display to address feedback
    about current terminology
  • Feedback has indicated that stakeholders find
    some current terminology confusing
  • FMCSA has previewed its effort to modify that
    terminology by
  • Replacing the terms Insufficient data and
    Inconclusive with fact-based descriptions
  • Breaking out crashes with fatalities and crashes
    with injuries

48
Additional SMS Changes for December 2012
  • Based on feedback gathered during the comment
    period, the Agency also incorporated additional
    changes to the SMS in December
  • Removed 1 to 5 mph speeding violations
  • FMCSA has aligned speeding violations to be
    consistent with current speedometer regulations
    (49 CFR 393.82) that require speedometers to be
    accurate within 5 mph.
  • Applies to the prior 24 months of data used by
    the SMS and all SMS data moving forward.
  • Lowered the severity weight for speeding
    violations that do not designate mph range above
    the speed limit.
  • The severity weight was lowered to 1 for
    violations.

49
Additional SMS Changes for December 2012
  • Aligned the severity weight of paper and
    electronic logbook violations
  • FMCSA now equally weights paper and electronic
    logbook violations in the SMS for consistency
    purposes.
  • Changed the name of the Fatigued Driving (HOS)
    BASIC to the HOS Compliance BASIC
  • This BASIC continues to have a strong association
    with future crash risk. This action was taken to
    reflect that the BASIC includes HOS recordkeeping
    requirements that, by themselves, do not
    necessarily indicate fatigued driving or driving
    in excess of allowable hours.

50
  • For more information, visit http//csa.fmcsa.dot.
    gov
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