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Comprehensive Safety Analysis CSA 2010 National Rollout and Implementation CVSA Fall Conference September 21, 2009

Comprehensive Safety Analysis CSA 2010 National Rollout and Implementation CVSA Fall Conference September 21, 2009. U.S. Department of Transportation Federal Motor Carrier Safety Administration. Presentation Overview. CSA 2010 Defined Op-Model Test Results National Implementation

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Comprehensive Safety Analysis CSA 2010 National Rollout and Implementation CVSA Fall Conference September 21, 2009

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  1. Comprehensive Safety Analysis CSA 2010National Rollout and ImplementationCVSA Fall ConferenceSeptember 21, 2009 U.S. Department of Transportation Federal Motor Carrier Safety Administration

  2. Presentation Overview CSA 2010 Defined Op-Model Test Results National Implementation Panel Discussion State Programs Impacts Roadside Uniformity Update SMS Methodology Details

  3. CSA 2010DefinedGary Woodford, FMCSACSA 2010 Program Manager

  4. Comprehensive Safety Analysis 2010 CSA 2010 is a pro-active initiative to improve the efficiency and effectiveness of FMCSA’s enforcement and compliance program. Uses ALL roadside inspection results and crash reports to identify safety deficiencies Employs a wider array of interventions tailored to problems instead of solely the time-intensive Compliance Review process Enables more carriers to be contacted earlier Requires sustained accountability of carriers AND increases accountability of drivers

  5. New Operational Model: 3 components 1. New Safety Measurement System (SMS) Improved ability to identify demonstrated safety problems 2. New intervention process Employs an array of interventions instead of the single option, labor-intensive compliance review 3. New approach to the Safety Fitness Determination (SFD)SFD tied to current safety performance; not limited to acute/critical violations from a Compliance Review • SFD requires rulemaking, not necessarily part of rollout in July 2010

  6. 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 • Weights time and severity of violations based on relationship to crash risk • Triggers the intervention process (eventually would feed the proposed Safety Fitness Determination) • Calculates safety performance based on 7 Behavior Analysis and Safety Improvement Categories (BASICs)

  7. 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

  8. SafeStat vs SMS

  9. New Intervention Process The New Intervention Process addresses the… WHAT Discovering violations anddefining the problem (similar to current model), but also expanding to include the why and how 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

  10. Safety Management Cycle

  11. New Intervention Tools • New intervention tools reach more carriers and influence safety compliance earlier • Roadside Inspections • 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)

  12. Current vs CSA 2010 Intervention Process

  13. CSA 2010Operational ModelTest ResultsBryan Price Office of Enforcement & Compliance Federal Motor Carrier Safety Administration

  14. Operational Model Field Test Began February 2008 Planned completion June 2010 Designed to test validity, efficiency and effectiveness of new model Evaluation to be conducted by independent 3rd party Original test states include: Colorado, Georgia, Missouri, New Jersey

  15. CSA 2010 Test Spring 2009 Added Montana and Minnesota 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 Fall 2009: Two additional states: Kansas and Maryland | 15

  16. Preliminary OM Test Results (10/1/08-8/31/09) Warning letters are having a positive impact: About 3,000 sent since Feb. 08 45% of recipients logged in to view safety scores Feedback from test states indicate that carriers appreciate the early alert “…carrier officials thanked us for notifying them of their safety problems… once carrier officials understand that the new system enables them to identify their problem drivers, a light goes on. They see CSA 2010 as a tool that they can use to stress the importance of roadside inspections with their drivers, to hold their drivers accountable for their on-road safety performance, and to thereby improve their companies’ overall safety performance.” - Daniel Drexler, Division Administrator in Minnesota | 16

  17. Preliminary OM Test Results (10/1/08-8/31/09) • Reaching its goal of contacting more carriers • One objective of CSA 2010 was to conduct more investigations • Employing the full array of investigations to achieve efficiency and effectiveness • Investigations in test states have been done in the following proportions: • Onsite Investigations – Comprehensive (~25%) • Onsite Investigations – Focused (~45%) • Offsite Investigations (~30%) | 17

  18. Preliminary OM Test Results (10/1/08-7/31/09) | 18

  19. Preliminary OM Test Results (10/1/08-7/31/09) Emphasizing Red Flag driver review with every carrier investigation | 19

  20. CSA 2010 National Implementation PlansBryan Price Office of Enforcement & Compliance Federal Motor Carrier Safety Administration

  21. CSA 2010 Rollout Strategy Summer 2010: Nationwide rollout SMS replaces Safestat BASICs sent to roadside • Summer – December 2010 : State by State rollout • Roll out interventions • Send warning letters after Division/state training | 21

  22. 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 • Evaluates/tracks driver performance individually • 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 • How FMCSA promotes safety • Forces carriers/drivers to be accountable for their safety performance • Demands and enforces safe on-road performance • Makes more complete safety performance assessments publicly available

  23. What Can Carriers Do To Prepare Now? • Learn more about CSA: http://csa2010.fmcsa.dot.gov • Understand the BASICs • Check the site for implementation schedule • Sign up for latest news: RSS/listserv • Check and update records • Motor Carrier Census (Form MCS -150) • Inspection and crash reports • 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 | 23

  24. Implementation: The State Partner PerspectiveA Panel Discussion

  25. State Considerations | 25

  26. CSA 2010 Implementation: State Program ImpactsTom KeaneChief, State Programs DivisionFederal Motor Carrier Safety Administration

  27. Overview Overall Impacts to State MCSAP Programs Specific Changes to CVSP Requirements Other Changes – Data Quality Specific Changes to FMCSA State Programs (SP) Policy Memos | 27

  28. “Change is more about culture than cost” CR production may change – new interventions CR processes – still asked to follow eFOTM How you prepare CVSPs Volume of Data Qs challenges (350.211 (11)) Questions/phone calls from industry 1. Overall Impacts-State MCSAP Programs | 28

  29. 2. Specific Changes to CVSP Will ask States to identify goals for new CSA2010 interventions as part of CR National Program Element CVSP National Program Element Changes Driver/Vehicle Inspections Traffic Enforcement Compliance Reviews Add CSA 2010 interventions here Public Education & Awareness Data Collection | 29

  30. May require updates to FY2010 CVSP budget i.e., training & travel costs State-Specific Objectives should remain unchanged Specific strategies & monitoring plan may change Maintenance of Effort (MOE) levels should remain unchanged 2. Specific Changes to CVSP – Continued | 30

  31. Data quality under new system is critical How violations are treated by SMS All safety-based violations count (not just OOS) Roadside violations may be used to assign ratings Dependent upon SFD rulemaking Data Qs challenges willlikely increase Inspection Uniformity will be critical Requests for inspection reports will increase Impacted by Driver Info Resource (DIR) tool 3. Other Changes – Data Quality | 31

  32. 4. Specific Changes to MCSAP SP Memos • Prior to Implementation • May update SP Memo – Funding Eligibility of Compliance Reviews (SP-90-014-SA) • May update Inspection Selection System (ISS) Memo (SP-09-001-GE) • After Implementation • Update to Cost Eligibility (Overtime) Memo (SP-02-001-CE) • Update to MOE Memo (SP-06-003-GE) | 32

  33. FY2010 will be transition year - Be flexible CSA 2010 Rollout FMCSA grants program changes Reauthorization (indirectly) Please articulate your concerns & challenges We will work with you during implementation! Primary Keys to Successful Implementation | 33

  34. For more information please contact: Tom Keane, Tom.Keane@dot.gov (202) 366-4025 | 34

  35. Roadside Data Uniformity Ad-hoc Status ReportMark Savage, Colorado State Patrol

  36. Objectives of CVSA Data Uniformity Ad-hoc Consistent documentation of roadside inspection and violation data Standardized processes for challenging data Increased awareness and understanding that all inspections (good and bad) must be uploaded Uniform inspection selection processes | 36

  37. Ad-hoc Structure At the spring meeting the structure of the Data Uniformity Ad-hoc group changed Much of the work was divided between the various committees Programmatic issues to PIC Roadside data violations to individual committees This format shows that CVSA is committed to the goals of the Ad-hoc for the long term | 37

  38. Consistent Documentation of Roadside Inspection and Violation Data Why? CSA 2010 Dependent upon SFD rulemaking, roadside data may be used to rate carriers as opposed to its current use which is to prioritize carriers for compliance reviews New safety measurement system uses more than just OOS violations in carrier measurement Program Integrity Data Reciprocity CVSA Strategic Goals | 38

  39. Consistent Documentation of Roadside Inspection and Violation Data Last spring CVSA and the Ad-hoc submitted a grant to FMCSA to fund travel costs associated with work on the Aspen violation lists. This work has been completed and a work-product will be presented at the various committees. The objective of the work groups was to: “To develop operational policies or guidance that will promote and/or mandate the consistent documentation of roadside inspection and violation data.” | 39

  40. Consistent Documentation of Roadside Inspection & Violation Data-Goals & Objectives The actual finished product is a consistent and uniform listing of violations that will appear in ASPEN/Safetynet Thank you to the subject matter experts from the HM, Driver-Traffic Enforcement, Vehicle and Passenger Carrier committees Goal is to correctly classify the data as consistently as possible across jurisdictional lines Operational guidance for roadside inspector | 40

  41. Consistent Documentation of Roadside Inspection and Violation Data-Plan The work product in the form of suggested violations list will be presented to the full committees at this meeting Next, the suggestions will go to Info Systems Committee and for review and eventual submission to FMCSA as the final authority for review and consideration as a change to ASPEN/Safetynet How could IT support the guidance being developed? Simultaneously, the same suggestions will be submitted to the training committee for review for training needs to the roadside inspectors or data entry specialists How could training support the guidance being developed? | 41

  42. Standardized Processes for Challenging Data As for the second task, standardizing the data challenge process, FMCSA has formed a working group that is currently addressing these issues. Several CVSA members are on this group The group is developing procedural guidance on the Data Q’s process Sub-committee of this group is working on a national model for standardizing due process among jurisdictions | 42

  43. Uniform Inspection Selection Processes Increased awareness and understanding that all inspections (good and bad) must be uploaded Uniform inspection selection processes Clean inspections are just as valuable as inspections with multiple violations Documents carrier improvement Impacts resource usage and carrier safety measurement | 43

  44. Program Management Issues-Uniform Inspection Selection Processes Issue request has been submitted to CVSA and routed to PIC for review. The issue request suggests a change to Operational Guidance #5 Inspection Selection Currently CVSA operational guidance in this area is to follow your jurisdiction’s policies Amendment suggests that jurisdictions develop and implement inspection selection policies based on several principles | 44

  45. Program Management Issues-PIC Program-wide management of inspectors and the inspection process Examine possible metrics for measuring roadside data accuracy and uniformity Promote integrity of our processes throughout the inspection from initial contact to completion Inspection/Screening A final outcome is to provide operational guidance to program managers in the form of best practices | 45

  46. Questions? For more information please contact: Mark Savage, Mark.Savage@cdps.state.co.us 303 273 1875 Mike Wilson, MWilson@isp.IN.gov

  47. SMS: Methodology Details, Role in SFD NPRM,& Violation Severity WeightingsBryan Price Office of Enforcement & Compliance Federal Motor Carrier Safety Administration

  48. Safety Measurement System (SMS) Objectives SMS Methodology Details SMS Role in Safety Fitness Determination (SFD) Development of Violation Severity Weights | 48

  49. Entities Two measurement systems for CSA 2010: Carrier Safety Measurement System (CSMS) Driver Safety Measurement System (DSMS) Potential to add additional measurement systems in the future HM Shipper | 49

  50. Methodology Overview Obtain on-road safety event data (e.g., inspections, crashes) and attribute to entity to create a safety event history Place each entity’s violations/crashes into a BASIC Convert BASIC data to quantifiable measure/rate (Safety Fitness Determination would be based on absolute performance) Based on each entity’s BASIC measure, develop rank and percentile for each entity’s BASIC performance Safety Events By Entity BASIC Data BASIC Measures Percentile | 50

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