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Compliance, Safety, Accountability (CSA) A New Way To Measure and Address Commercial Motor Vehicle Safety Industry Briefing December 2010. Presentation Agenda. Why Change? What is CSA? Field Test and National Rollout Summary. Why Change?. A Need For A More Agile, Efficient Program.
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Compliance, Safety, Accountability (CSA) A New Way To Measure and Address Commercial Motor Vehicle SafetyIndustry BriefingDecember 2010
Presentation Agenda Why Change? What is CSA? Field Test and National Rollout Summary
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 Transportation’s (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 < 2% (~12,000) of total carrier population annually
Compliance, Safety, Accountability (CSA) CSA 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.
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
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
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)
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
Investigation Findings Included in the BASIC measurements are serious violation findings from investigations • Serious violations generally consist of • Noncompliance that’s so severe that 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 measurements • BASIC is considered to be in an alert status and displayed accordingly on a carrier’s record for 12 months
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
New Agency Plans for Drivers (cont’d) • Pre-employment Screening Program (PSP) • PSP was mandated by Congress and is not a part of CSA • “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
Example of SafeStat vs. SMS The following slides provide examples of key differences between SafeStat and the SMS
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
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
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
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
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)
The Interventions Process The Interventions Process addresses the… • WHAT Discovering violations anddefining the problem • WHY Identifying the cause or where the processes broke down • HOWDetermining how to fix it/prevent it through use of Safety Management Cycle and Safety Improvement Resources
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)
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.
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)
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)
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
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
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)
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
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
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
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
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)
For more information, please visit: http://csa.fmcsa.dot.gov
