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Compliance, Safety, Accountability (CSA) A New Way To Measure and Address Commercial Motor Vehicle Safety Industry Briefing December 2010

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Title: Compliance, Safety, Accountability (CSA) A New Way To Measure and Address Commercial Motor Vehicle Safety Industry Briefing December 2010


1
Compliance, Safety, Accountability (CSA) A New
Way To Measure and Address Commercial Motor
Vehicle SafetyIndustry BriefingDecember 2010
2
Presentation Agenda
  • Why Change?
  • What is CSA?
  • Field Test and National Rollout
  • Summary

3
Why Change?
4
A Need For A More Agile, Efficient Program
  • Past Operational Model Limitations
  • Limited intervention toolbox for Safety
    Investigators (SIs)
  • Safety fitness determination tied to compliance
    review
  • Focused largely on carriers
  • Limited number of Federal/State investigators
    compared to large number of carriers
  • U.S. Department of Transportations (USDOT)
    Federal Motor Carrier Safety Administration
    (FMCSA) regulates 725,000 interstate and
    foreign-based truck and bus companies
  • USDOT/FMCSA audit (compliance review) was labor-
    intensive
  • Only able to reach lt 2 (12,000) of total
    carrier population annually

5
Compliance, Safety, Accountability (CSA)
  • CSA is an important initiative to improve the
    efficiency and effectiveness of FMCSAs
    enforcement and compliance program to achieve the
    agencys mission to reduce commercial motor
    vehicle (CMV) crashes, fatalities, and injuries.

6
What Is CSA?
7
What Changed?
  • The way FMCSA measures 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

8
The Operational Model
9
The Operational Model
10
The Operational Model
11
The Operational Model
12
The Operational Model
13
Op-Model Three Core Components
  • Measuring Carrier SafetyImproved ability for
    earlier identification of demonstrated safety
    problems by specific Behavior Analysis and Safety
    Improvement Categories (BASICs) from
  • Safety Measurement System results (on-road
    performance), and/or
  • Investigation Findings
  • Intervention ProcessEmploys an array of
    interventions instead of the previous principal
    option ? a labor-intensive compliance review
  • Safety Fitness Determination (SFD)SFD to be tied
    to current safety performance not limited to
    results of acute/critical violations from a
    compliance review

14
Safety Measurement System
  • CSA introduces the 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 seven
    BASICs
  • Triggers the intervention process (eventually
    will feed Safety Fitness Determination)

15
BASICs
  • BASICs focus on behaviors linked to crash risk
  • Unsafe Driving (Parts 392 397)
  • Fatigued Driving (Hours-of-Service)
  • Parts 392 395)
  • Driver Fitness (Parts 383 391)
  • Controlled Substances/Alcohol (Parts 382 392)
  • Vehicle Maintenance (Parts 393 396)
  • Cargo-Related (Parts 392, 393, 397 HM)
  • Crash Indicator

16
SafeStat vs. SMS
Previous Measurement System SafeStat CSAs SMS
Organized by four broad categories called Safety Evaluation Areas (SEAs) Accident, Driver, Vehicle, and Safety Management Organized by seven specific BASICs
Identified carrier for a compliance review (CR) Identifies safety problems to determine whom to investigate and where to focus the investigation
Used only out-of-service (OOS) and moving violations from roadside inspections. Uses all safety-based roadside inspection violations
Had no impact on safety rating Used to propose adverse safety fitness determination based on carriers current on-road safety performance (future)
Violations were not weighted based on relationship to crash risk Violations are weighted based on relationship to crash risk
Assessed carriers only Measures both carriers and drivers the Driver SMS is a tool for investigators to identify drivers with safety problems during carrier investigations
17
Investigation Findings
  • Included in the BASIC measurements are serious
    violation findings from investigations
  • Serious violations generally consist of
  • Noncompliance thats so severe that immediate
    corrective action is necessary
  • Directly related to carriers management and/or
    operational controls
  • Serious violations found from prior
    investigations are factored into BASIC
    measurements
  • BASIC is considered to be in an alert status and
    displayed accordingly on a carriers record for
    12 months

18
New Agency Plans for Drivers
  • The 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, individual drivers will not be
    assigned safety ratings or safety fitness
    determinations

19
New Agency Plans for Drivers (contd)
  • Pre-employment Screening Program (PSP)
  • PSP was mandated by Congress and is not a part of
    CSA
  • Driver Profiles from FMCSAs 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

20
Example of SafeStat vs. SMS
The following slides provide examples of key
differences between SafeStat and the SMS
21
Carrier Measurement SafeStat Results
22
Carrier Measurement SMS Results
23
Carrier Measurement SMS Results
24
Violation Details Provided in SMS
25
Further Drilldown in SMS
26
Further Drilldown in SMS
27
Further Drilldown in SMS
28
Carrier Access to Data
  • Carriers have access to full SMS results and
    BASIC measurements
  • Public has access to SMS results and BASIC
    measurements except for percentile scores for the
    Crash Indicator and Cargo-Related BASIC
  • Cargo-Related violations are available to the
    public
  • Decision regarding what to display was based on
    feedback through out the field test and data
    preview
  • List of Crashes are available to the public
  • Similar to the Accident SEA in SafeStat

29
Roadside Data Uniformity
  • Data collected at the roadside is the foundation
    of all data-driven traffic safety initiatives
  • CSA relies on roadside data in its SMS
    Methodology
  • The CSA SFD methodology would use roadside data
    as a component of the safety fitness
    determinations

30
Roadside Uniformity-Background
  • Effort organized into four core initiatives
  • Consistent documentation of roadside inspection
    and violation data
  • Standardized processes for making a Request for
    Data Review (RDR)
  • Increased awareness of high-level goals of the
    inspection program
  • Good inspections can support systematic
    enforcement program
  • Screening vs. Inspection
  • Uniform inspection selection processes

31
FMCSA Data Quality
  • Quality data is key to the CSA 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

32
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 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)

33
The Interventions Process
  • The Interventions Process addresses the
  • WHAT
  • Discovering violations anddefining 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

34
Safety Management Cycle
35
Intervention Tools
  • The intervention tools reach more carriers and
    influence safety compliance earlier
  • Warning Letters
  • Investigations
  • Offsite Investigations
  • Onsite Focused Investigations
  • Onsite Comprehensive Investigations
  • Follow-on corrective actions
  • Cooperative Safety Plan (CSP)
  • Notice of Violation (NOV)
  • Notice of Claim (NOC)
  • Operations Out-of-Service Order (OOS)

36
Previous Process vs. CSA Intervention Process
Previous CR Process CSA Intervention Process
Broad one-size-fits-all investigation Array of interventions can be tailored to address extent and scope of specific safety alerts
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
Focused on broad compliance based on rigid set of acute/critical violations Focuses on improving behaviors that are linked to crash risk
Discovered what violations exist at that time Discovers what safety problem(s) are, why they exist, and how to correct them
Major safety problems resulted in fines (NOC) When problems found, major focus on carrier proving corrective action significant problems continue to result in fines
Focused on carrier Expands focus to driver violations
37
Safety Fitness Determination (SFD)
  • SFD would
  • Incorporate on-road safety performance via the
    new SMS, which is updated on a monthly basis
  • Continue to include major safety violations found
    as part of CSA investigations
  • Produce an SFD of
  • Unfit or
  • Marginal or
  • Continue Operation

Draft rulemaking is currently in review within
USDOT NPRM expected to be published in late
2011.
38
Current Rating Process in CSA
  • CSA incorporates the existing safety rating
    process and will continue to do so until SFD goes
    into effect
  • Drivers will not be rated
  • 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
    its safety rating(385.17)

39
CSA Field Test and National Rollout
40
CSA Field Test
  • Operational Model Field Test Design
  • Design completed January 2008
  • Divided 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)

41
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
  • 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

41
42
Preliminary Results
  • CSA Field Test
  • Reached its goal of contacting more carriers
  • Research shows more contacts equals improved
    safety performance
  • Resulted in strong enforcement similar to
    current model
  • Employed the full array of investigations
  • Investigations in test states were done in the
    following proportions
  • Onsite Comprehensive Investigations (25)
  • Onsite Focused Investigations (45)
  • Offsite Investigations (30)
  • Followed up with carriers 50 of investigations
    result in one of following
  • NOC or NOV
  • CSP
  • Driver-Specific follow-on activities
  • NOV
  • NOC

43
More Preliminary Results
  • Warning letters are having a positive impact
  • Over 8,500 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

Since Phase II (Oct. 1, 2010)
44
Rollout Schedule Guiding Principles
  • Integrate lessons learned from nine-state test
    and feedback from national stakeholder outreach
  • Create a phased approach to methodically step
    stakeholders into new 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 the SMS by
    internalizing concepts of behaviors and BASICs
  • Maximize resources
  • Respond to industry information needs
  • Use measurement system to identify and prioritize
    carriers with safety problems
  • Train field staff in new intervention process

44
45
CSA Rollout Schedule
  • April 12 November 30, 2010
  • Motor carriers can preview their own data by
    seeing their roadside inspections/violations and
    crash events organized by BASIC
  • Summer 2010
  • June 30th The Operational Model Test (Op-Model
    Test) ended
  • July The four test states partially applying the
    CSA 2010 Operational Model fully switched to CSA
  • August
  • The SMS Methodology was modified to increase its
    effectiveness
  • Motor carriers were able to see an assessment of
    their violations based on the new Carrier Safety
    Measurement System (CSMS) that replaced SafeStat
  • December 2010
  • SafeStat was replaced by the CSMS, available to
    the public, including shippers and insurance
    companies
  • FMCSA/States prioritize enforcement using the
    CSMS
  • FMCSA began issuing warning letters to carriers
    with BASICs flagged as alert in the CSMS
  • Roadside inspectors use the CSMS results to
    identify carriers for inspection
  • Transitional elements were introduced to enhance
    the effectiveness of the phased rollout
  • 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

46
December 2010 Detailed Rollout
  • SafeStat was replaced by the CSMS, which is
    available to the public, including shippers and
    insurance companies
  • FMCSA/State enforcement began prioritizing
    enforcement using the CSMS
  • FMCSA began issuing warning letters to carriers
    with deficient BASICs
  • Roadside inspectors began using the CSMS results
    to identify carriers for inspections
  • Transitional elements were introduced to enhance
    the effectiveness of the phased rollout
  • Focused Compliance Reviews
  • DSMS sampling
  • Direct Notice of Violations
  • Red Flag Drivers
  • CSA 2010 became the new compliance and
    enforcement program of FMCSA and became known as
    CSA Compliance, Safety, Accountability

46
47
Summary
48
In Summary
  • CSA introduces improvements in three main areas
  • 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
  • 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
  • Proposed change in evaluation SFD
  • 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

49
What Can Carriers Do?
  • Educate yourselves and your employees
  • Understand the SMS Methodology and the BASICs
  • Check the website for information and updates
    (http//csa.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
  • Log in to the SMS, review BASICs, and address
    safety problems now!
  • Educate drivers about how their performance
    impacts their own driving record and the safety
    measurement 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)

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