U.S. Department of Transportation Federal Motor Carrier Safety Administration

U.S. Department of TransportationFederal Motor Carrier Safety Administration

Industry Briefing, August 2010

FMC-CSA-10-002

Comprehensive Safety Analysis

(CSA) 2010

A New Way To Measure and Address

Commercial Motor Vehicle Safety

Industry BriefingAugust 2010

Comprehensive Safety Analysis

(CSA) 2010

A New Way To Measure and Address

Commercial Motor Vehicle Safety

Industry BriefingAugust 2010U.S. Department of Transportation

Federal Motor Carrier Safety Administration



FMC-CSA-10-002

Presentation AgendaPresentation Agenda

•Why Change?•CSA 2010: Defined•Test and

Implementation•Summary

2



FMC-CSA-10-002

Why Change?Why Change?

3



FMC-CSA-10-002

Commercial Motor Vehicle FatalitiesCommercial Motor Vehicle Fatalities

Rate of Commercial Motor Vehicle Fatalities is Leveling Off

4



FMC-CSA-10-002

A Need For A More Agile, Efficient ProgramA 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



FMC-CSA-10-002

Comprehensive Safety Analysis 2010Comprehensive 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



FMC-CSA-10-002

What is Changing?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



FMC-CSA-10-002

CSA 2010 DefinedCSA 2010 Defined

8



FMC-CSA-10-002

A New Operational Model (Op-Model)A New Operational Model (Op-Model)

9



FMC-CSA-10-002


10



FMC-CSA-10-002


11



FMC-CSA-10-002


12



FMC-CSA-10-002


13



FMC-CSA-10-002

Op-Model: Three Core ComponentsOp-Model: Three Core Components

1. New Way to Assess Carrier SafetyImproved ability for earlier identification of demonstrated safety problems by specific Behavior Analysis Safety Improvement Categories (BASICs) from:

a) Safety Measurement System results (on-road performance), and/or

b) Investigation Findings

2. New intervention processEmploys 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



FMC-CSA-10-002

New Safety Measurement SystemNew 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 BASICs

• Triggers the intervention process (eventually would feed Safety Fitness Determination) 15



FMC-CSA-10-002

BASICsBASICs

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



FMC-CSA-10-002

SafeStat vs SMS 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



FMC-CSA-10-002

Investigation FindingsInvestigation Findings

Included in BASIC assessments are serious violation findings from investigations

• Serious Violations generally consist of – Non-compliance that’s so severe immediate

corrective action is necessary– Directly related to carrier’s management and/or

operational controls

• Serious Violations found from prior investigations are factored into BASIC Assessments – BASIC is considered deficient and displayed

accordingly on a carrier’s record for 12 months



FMC-CSA-10-002

New Agency Plans for DriversNew 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

19



FMC-CSA-10-002

New Agency Plans for Drivers (cont’d)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

20



FMC-CSA-10-002

Example of SafeStat vs SMSExample of SafeStat vs SMS

The following slides provide examples of key differences between SafeStat and the

new SMS

21



FMC-CSA-10-002

Carrier Measurement: SafeStat ResultsCarrier Measurement: SafeStat Results

22



FMC-CSA-10-002

Carrier Measurement: SMS Results Carrier Measurement: SMS Results

23



FMC-CSA-10-002

Violation Details Provided in SMSViolation Details Provided in SMS

24



FMC-CSA-10-002

Further Drilldown in SMSFurther Drilldown in SMS

25



FMC-CSA-10-002

Carrier Access to DataCarrier Access to Data

When will the Carriers’ SMS results be made available?

•Currently, only test state carriers have access to full SMS results by using the Comprehensive Safety Information (CSI) system•As of August 16, 2010 all carriers have access to FMCSA’s Data Preview (https://csa2010.fmcsa.dot.gov/DataPreview) which includes carrier safety assessments by BASIC

•Carriers will have access to full SMS results and BASIC assessments in December 2010•Public will have access to SMS results and BASIC assessments in December 2010 except for the Crash Indicator

26



FMC-CSA-10-002

Roadside Data Uniformity 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

27



FMC-CSA-10-002

Roadside Uniformity-Background Roadside Uniformity-Background

• Effort organized into four core initiatives:1. Consistent documentation of roadside inspection

and violation data2. Standardized processes for making a Request for

Data Review (RDR)3. Increased awareness of high-level goals of the

inspection programa) Good inspections can support systematic enforcement

programb) Screening vs. Inspection

4. Uniform inspection selection processes

28



FMC-CSA-10-002

FMCSA Data QualityFMCSA 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

29



FMC-CSA-10-002

Requests for Data ReviewRequests 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)

30



FMC-CSA-10-002

New Interventions ProcessNew Interventions Process

The New 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

31



FMC-CSA-10-002

Safety Management CycleSafety Management Cycle

32



FMC-CSA-10-002

New Intervention ToolsNew 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) 33



FMC-CSA-10-002

Current vs CSA 2010 Intervention ProcessCurrent vs CSA 2010 Intervention Process

Current CR ProcessCSA 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

34



FMC-CSA-10-002

Safety Fitness Determination (SFD)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.

Draft rulemaking is currently in review within DOT;

NPRM expected to be published in late 2010.35



FMC-CSA-10-002

Current Rating Process in CSA 2010Current 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)

36



FMC-CSA-10-002

CSA 2010 Test and National Roll-out

CSA 2010 Test and National Roll-out

37



FMC-CSA-10-002

CSA 2010 Field TestCSA 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)

38



FMC-CSA-10-002

100% States in Field Test100% 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

3939



FMC-CSA-10-002

Preliminary ResultsPreliminary 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

40



FMC-CSA-10-002

More Preliminary ResultsMore 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

41



FMC-CSA-10-002

Roll-Out Schedule Guiding PrinciplesRoll-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

42



FMC-CSA-10-002

CSA 2010 Roll-out ScheduleCSA 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

43



FMC-CSA-10-002

SummarySummary

44



FMC-CSA-10-002

In Summary…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

45



FMC-CSA-10-002

What Can Carriers Do To Prepare Now?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 – Log in to the Data Preview (https://csa2010.fmcsa.dot.gov/DataPreview),

review BASIC assessments and 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)

46



FMC-CSA-10-002

47

For more information, please visit:

csa2010.fmcsa.dot.gov

Documents

U.S. Department of Transportation Federal Motor Carrier Safety Administration