Ooida Briefing 10142009

U.S. Department of TransportationFederal Motor Carrier Safety Administration

OOIDA Briefing, October 14, 2009

Comprehensive Safety Analysis (CSA) 2010

A New Way To Measure and Address

Commercial Motor Vehicle Safety

OOIDA BriefingOctober 14, 2009

Comprehensive Safety Analysis (CSA) 2010

A New Way To Measure and Address

Commercial Motor Vehicle Safety

OOIDA BriefingOctober 14, 2009U.S. Department of Transportation

Federal Motor Carrier Safety Administration



Presentation AgendaPresentation Agenda

•Why Change?•A Change to Save Lives •CSA 2010: Defined•Test and Implementation

•Summary

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Why Change?Why Change?



Commercial Motor Vehicle FatalitiesCommercial Motor Vehicle Fatalities

Rate of Commercial Motor Vehicle Fatalities is Leveling Off

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A Need For A More Agile, Efficient ProgramA 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

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A Change to Save Lives

A Change to Save Lives



Comprehensive Safety Analysis 2010Comprehensive 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.

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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

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Early Results Are PromisingEarly 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

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CSA 2010 DefinedCSA 2010 Defined



A New Operational Model (Op-Model)A New Operational Model (Op-Model)



Op-Model: Three Core ComponentsOp-Model: Three Core Components

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 Compliance Review

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New Safety Measurement SystemNew 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)

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SMS BASICsSMS BASICs

SMS BASICs focus on behaviors linked to crash risk1. 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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OOIDA Briefing, October 14, 2009Webinar #2

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Methodology Overview Methodology Overview 1) Obtain on-road safety event data (e.g.,

inspections, crashes) and attribute to entity to create a safety event history

2) Place each entity’s violations/crashes into a BASIC3) Convert BASIC data to quantifiable measure/rate

(future Safety Fitness Determination proposed to be based on absolute performance)

4) 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



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Safety EventsSafety Events

BASIC DATASAFETYEVENTS

BASIC MEASURES

PERCENTILE

Safety Event Data Attributed to Entity Carrier Safety Measurement System (CSMS)

– Includes 24 months of carrier on road safety performance~6.6 Million inspections~290 K crashes ~690 K carriers

Driver Safety Measurement System (DSMS)– Includes 36 months of driver on road performance

~9.6 Million inspection records~440 K crash records~3.6 Million drivers



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BASIC DataBASIC Data

Safety Event Data Sorted by BASIC

PERCENTILEBASIC DATABASIC

MEASURESSAFETYEVENTS

– Unsafe Driving (Parts 392 & 397)

– Fatigued Driving (HOS) (Parts 392 & 395)

– Driver Fitness (Parts 383 & 391)

– Controlled Substances /Alcohol (Part 392)

– Vehicle Maintenance (Parts 393 & 396)

– Cargo Related / HM (Parts 392, 393, 397 & HM)

– Crash Indicator



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BASIC MeasuresBASIC 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

BASICMEASURES

PERCENTILEBASIC DATASAFETYEVENTS



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Unsafe Driving MeasureUnsafe Driving Measure

(PUs) UnitsPowerofNumber Average

ViolationsWeightedSeverity&TimeofSum MeasureBASIC

• Operation of CMVs in a dangerous or careless manner.– Examples: speeding, reckless driving, improper lane change

• Considerations:– Time weight: 0-6 Months (3), 6-12 Months (2), 12-24 months (1)

– Violation Severity Weight • based on crash risk: Range from 1-10, where 10 is the most severe

– Normalized by Average Power Units



SafeStat vs SMS SafeStat vs SMS

Today’s Measurement System: SafeStat

CSA 2010 SMS

Organized by four broad categories - Safety Evaluation Areas (SEAs): Accident, Driver, Vehicle, and Safety Management

Organized by seven specific Behavior Analysis Safety Improvement Categories (BASICs)

Identifies carrier for a compliance review (CR)

Identifies safety problems to determine who to investigate and where to focus the investigation

From roadside inspections, uses only out-of-service (OOS) and moving violations

Emphasizes on-road safety performance, using all safety-based road-side inspection violations

No impact on safety rating Used to propose adverse safety fitness determination based on carriers’ current on-road safety performance (future)

Violations are not weighted based on relationship to crash risk

Violations are weighted based on relationship to crash risk

Assesses carriers only Two distinct safety measurement systems-one for individual carriers and one for individual commercial motor vehicle (CMV) drivers



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

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Commonly Asked Question About Driver DataCommonly 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

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Example of SafeStat vs SMSExample of SafeStat vs SMS

The following slides provide

examples of key differences between SafeStat and the

new SMS

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Carrier Measurement: SafeStat ResultsCarrier Measurement: SafeStat Results

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Carrier Measurement: SMS Results Carrier Measurement: SMS Results

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Violation Details Provided in SMSViolation Details Provided in SMS

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Further Drilldown in SMSFurther Drilldown in SMS

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Carrier Access to DataCarrier 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

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New Interventions ProcessNew 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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Safety Management CycleSafety Management Cycle

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New Intervention ToolsNew 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)| 31



Current vs CSA 2010 Intervention ProcessCurrent vs CSA 2010 Intervention Process

Current CR ProcessCSA 2010 Intervention

Process

Broad one-size fits-all investigation regardless of extent or scope of safety deficiencies

Array of interventions can be tailored to address extent and scope of specific safety deficiencies

Resource intensive for agency and time consuming for carrier/fewer carriers contacted

Less resource intensive for agency and less time consuming for carrier/more carriers contacted

Focuses on broad compliance based on rigid set of acute/critical violations

Focuses on improving behaviors that are linked to crash risk

Discover what violations exist

Discover what safety problem(s) are and why they exist, to facilitate corrective action

Major safety problems result in fines (Notice of Claim (NOC))

When problems found, major focus on carrier proving corrective action; significant problems continue to result in fines

Focuses on carrier Expands focus to include investigating individual drivers



What Can Carriers Do To Prepare Now?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 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

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CSA 2010 Test and

Implementation

CSA 2010 Test and

Implementation



CSA 2010 Field TestCSA 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

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100% States in Field Test100% 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

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Preliminary ResultsPreliminary 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%)

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More Preliminary ResultsMore 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

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National Implementation Elements and TimelineNational 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

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Proposed Safety Fitness

Determination

Proposed Safety Fitness

Determination



Safety Fitness Determination: Current LimitationsSafety 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

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Proposed Change to the SFD ProcessProposed Change to the SFD ProcessProposed 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 OperationDraft rulemaking is currently in review

within FMCSA; NPRM scheduled to be published Fall ’09.

Draft rulemaking is currently in review within FMCSA;

NPRM scheduled to be published Fall ’09.| 42



Benefits of the Proposed CSA 2010 SFDBenefits 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 performanceCSA 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

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SummarySummary



In Summary…In Summary…

CSA 2010 introduces improvements in three main areas

1.New Safety Measurement System– More comprehensive– Better able to pinpoint safety problems– Better identifies high crash-risk behavior

2.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

3.Proposed change in evaluation: Safety Fitness Determination– Assess safety performance of larger segment of industry– Based on roadside performance and intervention results

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For more information, see csa2010.fmcsa.dot.gov

For more information, see csa2010.fmcsa.dot.gov

Ooida Briefing 10142009

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