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

Driver Briefing | December 2012FMC-CSA-10-027

CSA: A Way to Measure and Address

Commercial Motor Vehicle Safety

Driver BriefingDecember 2012


• What is Compliance, Safety, Accountability (CSA)?

• CSA’s Results• CSA’s Three Core Components• What Does CSA Mean for Drivers?• Summary• Safety Measurement System (SMS)

Improvements

Agenda


What Is CSA?

• CSA is the Federal Motor Carrier Safety Administration’s (FMCSA) enforcement and compliance program used to achieve the Agency’s 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.


Where It All Started


CSA Operational Model

Model based on Safety Fitness Determination (SFD) rulemaking


CSA’s 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


CSA’s Three Core Components

1. 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

2. 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

3. An SFD process that:– Requires rulemaking, expected to begin in early 2013– Would be tied to on-the-road safety performance and replace

the current system


1. The SMS

The SMS is FMCSA’s 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 (OOS) 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


1. The SMS (cont.)

The SMS is FMCSA’s 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


BASICs focus on behaviors linked to crash risk1. Unsafe Driving (Parts 392 & 397)

2. Hours-of-Service (HOS) Compliance(Parts 392 & 395)

3. Driver Fitness (Parts 383 & 391)

4. Controlled Substances/Alcohol (Parts 382 & 392)

5. Vehicle Maintenance (Parts 392, 393 & 396)

6. HM Compliance (Federal Motor Carrier Safety Regulations (FMCSRs) Part 397 & HM Regulations (HMRs) Parts 171, 172, 173, 177, 178, 179, and 180)

7. Crash Indicator

The SMS BASICs


• All violations count toward a carrier’s percentile rank– If received while driving for that carrier

• Only violations within the control of the driver (as deemed by the Agency) count toward a driver’s safety profile– For example: speeding, HOS violations, etc.

• Carriers cannot see the historic driver safety profile– Carriers can only see the violations received while the

driver was employed by the driver’s current company.

Driver Information


• Individual driver safety profiles are used by investigators during carrier investigations only– To identify drivers with safety problems– To prioritize the driver sample during carrier

investigations– To issue Notice of Violations (NOVs)/Notice of Claims

(NOCs) to individual drivers based on this driver investigation as appropriate

• The SMS BASICs are sent to Roadside Inspectors – Assist in determining the level of inspection– North American Standard Inspection procedure does

not change

Driver Information (cont.)


1. The SMS

2.Safety Interventions process

3. SFD process



The Safety 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 by using the Safety Management Cycle (SMC)

2. Safety Interventions Process


SMC


• Warning letters

• Investigations– Offsite Investigations– Onsite Focused Investigations– Onsite Comprehensive Investigations

• Follow-on corrective actions– Cooperative Safety Plan (CSP) – NOV– NOC– Operations OOS Order (OOSO)

Intervention Tools


1. The SMS

2. Safety Interventions process

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 investigations

• Produce an SFD to determine if a carrier is unfit to operate

3. SFD Process

Draft rulemaking is currently in review within USDOTDraft rulemaking is currently in review within USDOT


3. SFD Process

Current Safety Rating Process

CSA incorporates the existing safety rating process and will continue to do so until SFD goes into effect:

• Drivers are not rated• Drivers do not face any more suspension risk

under CSA


What CSA Means to Drivers


CSA puts an emphasis on drivers:

• All violations found during roadside inspections count toward carrier and driver safety measurement according to vehicle or driver violation type

• BASIC information/percentile ranks are sent to Roadside Inspectors as a tool in the decision of whether to inspect and what level to inspect a specific CMV– Roadside Inspectors see carrier information/percentile ranks– Roadside Inspectors do not see driver measurement

information

How Does CSA Impact 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 SFDs

• The SMS has been made available to the public to facilitate transparency

Information on Drivers


Pre-employment Screening Program (PSP)

• Mandated by Congress and is not a part of CSA

• “Driver Profiles” from FMCSA’s 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

Information on Drivers (cont.)


• Know and follow safety rules and regulations– CMV web-based driving tips can be found at

http://www.fmcsa.dot.gov/about/outreach/education/driverTips/index.htm

What Can Drivers Do Now?


• Become knowledgeable about the BASICs and how FMCSA evaluates safety under CSA– Review the SMS Methodology at

http://csa.fmcsa.dot.gov/outreach.aspx

• Advocate for safety among all professional drivers

What Can Drivers Do?


• Spread the word about CSA and encourage fellow drivers to:– Check the CSA Website for more information and updates at

http://csa.fmcsa.dot.gov – Maintain copies of inspection reports– Become knowledgeable about employers’ safety records by checking

carrier safety information online (http://ai.fmcsa.dot.gov/)

What Can Drivers Do? (cont.)


Frequently Asked Questions


• Does CSA give FMCSA the authority to put drivers out of work?– No. CSA does NOT give the Agency the authority to

remove drivers from their jobs. A change of that magnitude would require rulemaking and no such effort is underway.

• Does CSA give FMCSA the authority and processes to rate drivers and revoke their Commercial Driver’s Licenses (CDLs)?– No. Driver safety profiles are available to investigators,

but these are not used to rate drivers and/or revoke CDLs; State licensing agencies perform that function.

Frequently Asked Questions (FAQs)


• Do tickets or warnings that drivers receive while operating their personal vehicles impact the SMS?– No.

• Does the SMS hold carriers responsible for drivers’ errors, such as speeding?– Yes. Carriers are held accountable for drivers’ errors

because they are responsible for the job performance of those who work for them.

FAQs (cont.)


• Do carriers and drivers need to register for CSA and fulfill mandatory training?– No. CSA is primarily focused on helping FMCSA improve its

enforcement operations. Carriers and drivers do not need to register for CSA nor is there a mandatory training requirement.

• Is there a way to request a data review of potentially erroneous or improper violations on carrier and/or driver records?– Yes. The DataQs program (https://dataqs.fmcsa.dot.gov)

allows carriers and drivers to request a data review of information that resides in FMCSA databases such as crash and inspection reports.

FAQs (cont.)


• Is it considered an inspection every time I talk to an inspector at a weigh station?– Not necessarily. Law enforcement perform two types

of actions at the roadside: a screening and an inspection. A screening evaluates a CMV to determine if that driver and/or vehicle warrants an inspection. Screening methods may vary by jurisdiction. A screening does not constitute an inspection and an inspection report is not generated.

FAQs (cont.)


The SMS Improvements


• 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 a preview period for motor carriers prior to

implementation

The SMS Improvement Process


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 was open for comments about the SMS

Preview

December 2012• SMS public website was 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 percentile ranks are

available to only logged-in users

Schedule of SMS Changes


1. Strengthened the Vehicle Maintenance BASIC by incorporating cargo/load securement violations from the Cargo-Related BASIC

2. Changed the Cargo-Related BASIC to the HM Compliance BASIC to better identify safety problems related to HM

3. Better aligned the SMS with Intermodal Equipment Provider (IEP) regulations

4. Aligned violations included in the SMS with Commercial Vehicle Safety Alliance (CVSA) inspection levels by eliminating vehicle violations derived from driver-only inspections and driver violations from vehicle-only inspections

The SMS Changes


5. More accurately identifying carriers involved in transporting HM or passengers

6. Modified the SMS Display to:

– Change terminology (replaced terms Insufficient Data and Inconclusive) to fact-based definitions

– Break out crashes with injuries and crashes with fatalities

The SMS Changes (cont.)


1. 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 were disproportionately identified for intervention

―This bias was the reason that the Cargo-Related BASIC was not public

• Analysis showed that moving these violations resulted in more effective and efficient workload prioritization

• The Vehicle Maintenance BASIC remains public



2. Changed the Cargo-Related BASIC to the HM Compliance BASIC

• Removed load securement violations so that only HM violations remained

• 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

• FMCSA intends to make the HM Compliance BASIC public; however, the final decision will be made at the end of the preview period



3. Better aligned the SMS with IEP regulations

• Previously, the SMS did not use violations associated with the condition of an IEP trailer (if it is 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 carrier’s Vehicle Maintenance BASIC.



4. 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



5. More accurately identifying carriers involved in transporting HM or passengers

These carriers are subject to more stringent thresholds in the SMS


HM CarriersNew 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 the past 12 months

• At least 5% total inspections indicated as HM placardable vehicle inspections

Passenger CarriersNew definition removes many low-capacity vehicles (e.g., vans and taxis) that are generally outside of FMCSA’s 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


6. Modified the SMS Display to address feedback about current terminology

• Feedback has indicated that stakeholders find some current terminology confusing

• FMCSA 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



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:1.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.

2.Lowered the severity weight for speeding violations that do not designate mph range above the speed limit.

1. The severity weight was lowered to 1 for violations.


Additional SMS Changes for December 2012

3. 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.

4. Changed the name of the Fatigued Driving (HOS) BASIC to the HOS Compliance BASIC3. 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.


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

Documents

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