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

1. Comprehensive Safety Analysis (CSA) 2010A New Way To Measure and Address Commercial Motor Vehicle SafetyIndustry Briefing U.S. Department of Transportation Federal Motor Carrier Safety Administration

2. Presentation Agenda Why Change? CSA 2010: Defined Test and Implementation Summary

3. A 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

4. Comprehensive 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.

5. 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

6. CSA 2010Defined

7. A New Operational Model (Op-Model)

8. Op-Model: Three Core Components • New Safety Measurement System (SMS)Improved ability for earlier identification of demonstrated safety problems • New intervention processEmploys an array of interventions instead of the current principal option -- a labor-intensive compliance review • 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

9. New 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 Behavior Analysis and Safety Improvement Categories (BASICs) • Triggers the intervention process (eventually would feed Safety Fitness Determination)

10. SMS BASICs SMS 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

11. BASIC Measures Convert BASIC Data into Quantifiable Measure Considerations Time Weighting / Time Frame - More recent events more relevant Severity Weightings - Increase weighting of violations that have been shown to create a greater risk of crash involvement Normalizing - Based on exposure: use of number of inspections and power units Single Inspection Cap – limit violation weight of single poor inspection Violation Cap – Cited section number only counts once per inspection SAFETY EVENTS BASIC DATA BASIC MEASURES PERCENTILE 11 11 Webinar #2

12. Based on each BASIC measure, develop percentile indicating entity's BASIC performance Provides a relative assessment of performance Allows for prioritizing intervention resources by behavior Considerations: Peer Grouping - compare measures of entities with similar levels of exposure Data Sufficiency standards – define events/exposure necessary to generate a robust measure Intervention standards – define “critical mass” of poor performance necessary for inclusion of entity in intervention process Percentile SAFETY EVENTS BASIC DATA BASIC MEASURES PERCENTILE 12 12 Webinar #2

13. Based on each BASIC measure, develop percentile indicating entity's BASIC performance Current Inspection and Crash Data – assignment of percentile dependent on age and result of most recent inspection (12 months) Time Weight- Violations recorded in the past 6 months receive a time weight of 3. Violations recorded between 6 and 12 months ago receive a time weight of 2. All violations recorded earlier (older than 12 months but within the past 24 months) receive a time weight of 1. This time weighting places more emphasis on recent violations relative to older violations Percentile SAFETY EVENTS BASIC DATA BASIC MEASURES PERCENTILE 13 13 Webinar #2

14. Peer Grouping Create percentile based on measure for carrier with similar exposure (same peer group) 14 14 Webinar #2

15. New CSA 2010 Thresholds 15 15

16. SafeStat vs SMS

17. Example of SafeStat vs SMS The following slides provide examples of key differences between SafeStat and the new SMS

18. Carrier Measurement: SafeStat Results | 18

19. Carrier Measurement: SMS Results | 19

20. Violation Details Provided in SMS | 20

21. Further Drilldown in SMS | 21

22. Driver Measurement: By Basic | 22

23. Driver History: Unsafe Driver Measure and Violations | 23

24. Carrier Access to Data When will the Carrier SMS data be made available? • Currently, only test state carriers have access to Carrier SMS data, by using the Comprehensive Safety Information (CSI) system • The Carrier SMS data will be accessible beyond the test states late spring/early summer 2010

25. New 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 25

26. 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) will be available to carriers through PSP • Driver Profiles will only be released with driver authorization 26

27. 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

28. Roadside Uniformity-Background • Effort organized into four core initiatives: • Consistent documentation of roadside inspection and violation data • Standardized processes for challenging data • Increased awareness of high-level goals of the inspection program • Good inspections can support systematic enforcement program • Screening vs. Inspection • Uniform inspection selection processes

29. FMCSA 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 challenge the accuracy of federal and state reported data

30. Challenging Data • Improper Challenges: • Driver fired, please remove all these violations • Crash not our fault, please remove • Driver caused the violation, please remove • Owner operator (leased to company), please remove • Helpful Suggestions: • Attach document(s) that support the challenge • Be specific and detailed in your narrative • Owner operator (leased to company): attach lease agreement • Ensure contact information is accurate and updated • Check the status frequently, (additional information may be requested)

31. New Interventions Process The New 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

32. Safety Management Cycle

33. New 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)

34. Current vs CSA 2010 Intervention Process

35. Current 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) 35

36. 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 early 2010.

37. CSA 2010 Test and Implementation

38. CSA 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)

39. 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 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 39

40. Preliminary 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

41. More 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

42. National Implementation Elements and Timeline Summer 2010 • Replace SafeStat with SMS • Send SMS results (BASICs scores) to roadside inspectors Summer through December 2010 • Roll out training to enforcement agencies on new interventions • Send warning letters nationwide

43. Summary

44. In Summary… CSA 2010 introduces improvements in three main areas • 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 • 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 • 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. 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 • 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. For more information, please visit: csa2010.fmcsa.dot.gov