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Comprehensive Safety Analysis (CSA) 2010 A New Way To Measure and Address Commercial Motor Vehicle Safety Industry Briefing October 2009. U.S. Department of Transportation Federal Motor Carrier Safety Administration. Presentation Agenda. Why Change? A Change to Save Lives

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Comprehensive Safety Analysis (CSA) 2010A New Way To Measure and Address Commercial Motor Vehicle SafetyIndustry BriefingOctober 2009

U.S. Department of Transportation

Federal Motor Carrier Safety Administration

presentation agenda
Presentation Agenda

Why Change?

A Change to Save Lives

CSA 2010: Defined

Test and Implementation


commercial motor vehicle fatalities
Commercial Motor Vehicle Fatalities

Rate of Commercial Motor Vehicle Fatalities is Leveling Off

a need for a more agile efficient program
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

comprehensive safety analysis 2010
Comprehensive Safety Analysis 2010

What is CSA 2010?

CSA 2010 is a pro-active 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 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 count
    • 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
early results are promising
Early Results Are Promising
  • Eight states are testing model with promising results via earlier contact with more carriers
  • Carrier feedback is generally positive; an investigator in the test state of Missouri reports:

“…the new model has had a positive reaction from most carriers.  Many are trying to do well but sometimes do not realize they have deficiencies or problems in one area or another.  Carriers also like that CSA 2010 allows us to do a focused investigation on the specific areas that have violation problems and to identify the process breakdowns in their safety management systems to help them correct the deficiency.”

- Steff Copeland, State Enforcement Investigator, MO DOT

op model three core components
Op-Model: Three Core Components
  • New Safety Measurement System (SMS)Improved ability to identify demonstrated safety problems
  • Proposed change for evaluation: new approach to the Safety Fitness Determination (SFD)SFD tied to current safety performance; not limited to acute/critical violations from a Compliance Review
  • New intervention processEmploys an array of interventions instead of the single option, labor-intensive compliance review
new safety measurement system
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 will feed the proposed Safety Fitness Determination)
  • Calculates safety performance based on 7 Behavior Analysis and Safety Improvement Categories (BASICs)
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
driver safety measurement system dsms
Driver Safety Measurement System (DSMS)

DSMS quantifies commercial motor vehicle (CMV) driver performance in terms of BASICs, using available roadside performance data

  • Allows Safety Investigators (SI) to see an individual CMV driver’s safety record across employers
  • Allows SIs to examine drivers who have been cited for severe driver violations, in conjunction with carrier interventions
  • May result in driver Notice of Violation or Notice of Claim based on driver violation history across current and previous employers
commonly asked question about driver data
Commonly Asked Question About Driver Data

When Will Carriers Have Access to Driver Data for Employment Decisions?

  • FMSCA’s Driver Information Resource (DIR) attributes roadside inspection and crash data to individual CMV drivers
  • “Driver Profiles” from DIR that contain inspection and crash histories for individual drivers will be made available through FMCSA’s Commercial Driver Pre-employment Screening Program (PSP) later in 2009; drivers would authorize release of profiles
  • FMCSA is negotiating with 3rd party vendors to provide access to PSP data for carriers and drivers
example of safestat vs sms
Example of SafeStat vs SMS

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

carrier access to data
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 when CSA 2010 begins full implementation in summer 2010
safety fitness determination current limitations
Safety Fitness Determination: Current Limitations

The current safety rating/SFD process has limitations

  • Only issued with on-site Compliance Review (resource intensive)
  • Only a snapshot of carrier compliance taken at the time of most recent Compliance Review
    • Safety ratings (Sat, Conditional or Unsat) are often outdated and may not reflect current safety posture
  • Heavily based on violations deemed “critical” or “acute”
  • Unsatisfactory/Unfit SFD rating requires multiple areas of deficiency
proposed change to the sfd process
Proposed Change to the SFD Process

Proposed change would:

Incorporate on-road safety performance via new SMS on a monthly basis

Continue to include major safety violations found as part of CSA 2010 investigations

Produce a Safety Fitness Determination of

Unfit or

Marginal or

Continue Operation

Draft rulemaking is currently in review within FMCSA; NPRM scheduled to be published Fall ’09.

benefits of the proposed csa 2010 sfd
Benefits of the Proposed CSA 2010 SFD
  • Maximizes the use of data collected during roadside inspections
    • Approx. 3 million inspections performed annually
  • Creates carrier accountability for sustained unsafe operations and performance
  • Assesses more carriers based on current safety performance

CSA 2010 issues safety ratings within the existing regulatory framework. This will continue until the SFD rule goes into effect

new interventions process
New Interventions Process

The New Interventions 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
new intervention tools
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)
what can carriers do to prepare now
What Can Carriers Do To Prepare Now?
  • Learn more about CSA:
    • 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 report
  • 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
csa 2010 field test
CSA 2010 Field Test

Op-Model Field Test Design:

  • Design completed January 2008
    • Divides representative carriers into

comparable test and control groups

Op-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
100 states in field test
100% States in Field Test
  • Additional states
    • Spring 2009: MT, MN
    • Fall 2009: KS, MD
  • 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


preliminary results
Preliminary Results

So far, CSA 2010 is:

  • Reaching its goal of contacting more carriers
    • One objective of CSA 2010 was to conduct more investigations per FTE, per month
    • This goal is being met or exceeded by test state SIs
  • Resulting in strong enforcement; similar to current model
  • 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%)
more preliminary results
More Preliminary Results

Warning letters are having a positive impact:

  • About 4,000 sent
  • 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
national implementation elements and timeline
National Implementation Elements and Timeline

Summer 2010

  • Replace SafeStat with SMS
  • Inspect carriers with deficient BASICs on the roadside

July through December 2010

  • Roll out interventions tool box
  • Send warning letters nationwide
in summary
In Summary…

CSA 2010 introduces improvements in three main areas

  • New Safety Measurement System
    • More comprehensive
    • Better able to pinpoint safety problems
    • Better identifies high crash-risk behavior
  • Proposed change in evaluation: Safety Fitness Determination
    • Assess safety performance of larger segment of industry
    • Based on roadside performance and intervention results
  • 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