Post on 24-Dec-2015
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Comprehensive Safety Analysis (CSA) 2010
A New Way To Measure and Address Commercial Motor Vehicle Safety
April 2010
Joe DarbyDoug DickinsonMarsh Risk Consulting
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Overview
CSA 2010 overview – Mark Langer
Time Line for implementation
What clients are telling us so far
Initial Concerns
What carriers should do to prepare
Wrap-up – Rich Bleser
What is CSA 2010?
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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.
Why CSA 2010?
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Commercial Motor Vehicle Fatalities
Rate of Commercial Motor Vehicle Fatalities is Leveling Off
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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– FMCSA regulates ~725,000 interstate and foreign-based truck and bus companies
U.S. DOT/FMCSA audit Compliance Review (CR) is labor intensive– Only able to reach < 2% (~12,000) of total carrier population annually
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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
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A New Operational Model (Op-Model)A New Operational Model (Op-Model)
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CSA 2010 Op-Model
1. New Safety Measurement System (SMS)Improved ability to identify demonstrated safety problems
2. New intervention processEmploys an array of interventions instead of the single option, labor-intensive compliance review
3. 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 CR
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• 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 Calculates safety performance based on 7 Behavior Analysis and Safety Improvement Categories (BASICs)
• Driver Safety Measurement System (DSMS) will be used to directly address commercial motor vehicle (CMV) driver performance in terms of BASICs, using available roadside performance data
New Safety Measurement System (SMS)
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SMS BASICs
SMS BASICs focus on behaviors linked to crashes1. 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
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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
• HOW Determining how to fix it/prevent it through use of Safety Management Cycle and Safety Improvement Resources
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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)
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Expansion from What to Why? Safety Management Cycle
What safety management processes are breaking down?
Why are these safety management processes breaking down?
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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 CR− 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
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Proposed Change to the SFD Process
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 is scheduled to be published Dec 2010.
Draft rulemaking is currently in review within FMCSA; NPRM is scheduled to be published Dec 2010.
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Benefits of 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
CSA 2010 issues safety ratings within the existing regulatory framework. This will continue until the SFD rule goes into effect
CSA 2010 Implementation
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National Implementation
Summer 2010
Replace SafeStat with SMS
Inspectors see BASICs information at the roadside
July through December 2010
Roll out interventions tool box
Send warning letters nationwide
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Time Line
SMS information available to carriers : April 12, 2010– Live violation data available
Details of how BASICS are calculated: August 2010
Prioritization of carriers begins: November 2010– BASICS data live for all carriers
Safety Fitness Determination (SFD) Proposed Rule Making: December 2010
Interventions begin on large scale: Spring 2011
CSA 2010 Field Test
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Preliminary Results
New Elements
Warning letters are having a positive impact:– About 4,000 sent to-date– 45% of recipients logged in to view safety scores– Feedback from test states indicates that carriers appreciate the early
alert
Carriers are using SMS results– Some have logged in more than 200 times since the test started– Anecdotally, they are using the data to drive safety improvements
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Impact on Industry
Carrier Impacts
More carriers will hear from FMCSA
Specific safety performance information in SMS will be available
All violations will count
Warning letters will alert carriers of poor safety performance
More carriers will be exposed to compliance and enforcement efforts
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Impact on Industry
Driver Impacts
Drivers will be able to examine their employers’ safety performance
Deficient BASICs will be available to roadside inspectors
Investigators will know an individual driver’s record across companies
Investigators will pursue and penalize driver “red flag” violations
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Client Experience
Two DOT approaches– Education opportunity
Chance to reset expectations Provide insights to how to be safer carrier
– Carrot and Stick Stand off Letter listing demands Consequences clearly outlined
SMS Demonstration
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Carrier Measurement: SafeStat Results
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Carrier Measurement: SMS Results
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Violation Details Provided in SMS
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Further Drilldown in SMS
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How to get better in SMS?
Good Inspections
“Get Well” Rules – Violation time weight diminishes
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BASIC No percentile assigned if:
Crash Indicator No crashes in last year
Unsafe Driving and Drug and Alcohol No percentile assigned if no inspections with a violation in these BASICs in the last year
Fatigued Driving, Driver Fitness, Vehicle Maintenance and Cargo Related
No inspections with a violation in that BASIC within the past year; and
Most recent relevant inspection does not have a violation of that BASIC
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Initial Concerns
MN Trucking Association
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Summary
Enforcement
DataQ
Peer Groupings
Accessing the data
Safety Fitness Determination
Crash Indicator
Inspection point values
Hazardous Materials as separate basic
Commercial Vehicle Drivers
FMCSA has agreed to some elements of the high lighted
areas above – but continue to believe that the same data that
was effective in reducing crashes with Safer will work
with the BASICS
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Enforcement
Unequal enforcement (i.e. IN and OH)
Probable cause basis for stop
Warning ticket– Lower threshold– No recourse– Intent on counseling not enforcement
Inspection inaccuracies
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Peer groupings
Vehicle size only basis– Only 3 groups
No industry grouping (i.e. bus, van, LTL, flatbed, hazardous materials)
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Accessing the data
What data will be available to public
What driver data will be available to carriers
Data accuracy– Driver employment decisions based on warning tickets that cannot
be challenged
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Crash indicator
All crashes– Includes non-preventable which carrier cannot impact
Carrier with only non-preventable crashes could look less safe than carrier with a smaller of crashes that are all preventable
Mileage not used to normalize the data
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Inspection point values
Relative weight of infractions– Improper transport of explosives = 2 points– Loose tie downs = 10 points
– Not informing carrier of violation = 6 points– Not wearing glasses or hearing aid = 2 points
– Steer tire and trailer tire have the same weight
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Drivers
Data from terminated drivers stay on carrier profile for 24 months
Carrier that hires same driver has a clean slate
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Actions to do to prepare
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What Can Carriers Do To Prepare Now?
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What Can Carriers Do To Prepare Now?
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Vigillo Aggregate Statistics
76% of Vigillo Customers have at least 1 BASIC over the Intervention Threshold
(1200+ Fleets)
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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 and listening session notice– Sign up for latest news: RSS/listserv
Check and update records– Motor Carrier Census (Form MCS -150)
– Inspection and crash reports https://dataqs.fmcsa.dot.gov/login.asp
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
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What Can Carriers Do To Prepare Now?
Register for pre-employment screening– www.psp.fmcsa.dot.gov
Use a private company to get a preview of the BASICs– Vigillo and RAIR Technologies provides model of CSA 2010– Driver management features not in CSA test– www.vigillo.com– www.RAIR.com
Mock FMCSA audit– Fleet Group can provide
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Key Points for clients
Coming soon to all states
Unlike Safer – “good inspections” do not impact all elements of the BASICS (e.g. Unsafe Driving)
Register for Compass Portal now– https://portal.fmcsa.dot.gov – Review, understand, correct data
Take letter seriously– Safety rating can change without an audit
Individual driver performance will be visible– Hiring / retention implications
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Commitment
CRIProcessMeasurement
MeasureResults
IdentifyOpportunity
Measure andmonitor performance
and continuously improve
Mutually explorethe situation and form initial hypotheses of problem
Execute/Implement
Solution
Define theCauses
Create and manage change
Search for the problem’s most likely cause(s); refine andtest the hypothesisDesign/Select
Best SolutionIdentify the “best” solution, the risks involved, and the
commitment to change
CSA 2010Mgmt.
Process
Assess Current Fitness
TrainManagers
&Capacity
IncorporateActionPlan
MonitorSafety Fitness
IdentifyImprovement Opportunities
Game Changer– Regulations remain the same– Accountability measures are enhanced
Action Steps– Take Seriously– Assess Fitness– Identify Opportunities– Train – Incorporate Action Plan– Monitor Performance
Marsh Risk Consulting is at the fore-front– Contact us for assistance
Wrap-Up
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Questions
For additional information go to: www.fmcsa.dot.gov/csa2010
For additional assistance contact your local Client Executive or the following:
Rich Bleser – 414-290-4920 Doug Dickinson – 920-445-3814Joe Darby – 503-781-9821
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