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Comprehensive Safety Analysis (CSA) 2010 Industry Briefing(3)

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					                          Compliance, Safety,
                            Accountability
                               (CSA)
           A New Way To Measure and Address
             Commercial Motor Vehicle Safety
                                Healthy Trucking Association
                                              March 3, 2011
                                              Atlanta, Georgia
U.S. Department of Transportation                                Industry Briefing, December 2010
Federal Motor Carrier Safety Administration
                                                                                    FMC-CSA-10-002
Presentation Agenda


           • Why Change?
           • What is CSA?
           • Field Test and National
             Rollout
           • Summary

U.S. Department of Transportation             Industry Briefing, December 2010    2
Federal Motor Carrier Safety Administration
                                                                 FMC-CSA-10-002
                            Why Change?


U.S. Department of Transportation             Industry Briefing, December 2010    3
Federal Motor Carrier Safety Administration
                                                                 FMC-CSA-10-002
A Need For A More Agile, Efficient Program

• Past Operational Model Limitations
   – Limited intervention toolbox for Safety Investigators (SIs)
   – Safety fitness determination tied to compliance review
   – Focused largely on carriers
• Limited number of Federal/State investigators compared to
  large number of carriers
     – U.S. Department of Transportation’s (USDOT) Federal Motor Carrier
       Safety Administration (FMCSA) regulates ~725,000 interstate and foreign-
       based truck and bus companies
• USDOT/FMCSA audit (compliance review) was labor-
  intensive
     – Only able to reach < 2% (~12,000) of total carrier population annually

 U.S. Department of Transportation                      Industry Briefing, December 2010    4
 Federal Motor Carrier Safety Administration
                                                                           FMC-CSA-10-002
  Compliance, Safety, Accountability (CSA)



CSA 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.




  U.S. Department of Transportation             Industry Briefing, December 2010    5
  Federal Motor Carrier Safety Administration
                                                                   FMC-CSA-10-002
                           What Is CSA?


U.S. Department of Transportation             Industry Briefing, December 2010    6
Federal Motor Carrier Safety Administration
                                                                 FMC-CSA-10-002
What Changed?

• The way FMCSA measures 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


 U.S. Department of Transportation                       Industry Briefing, December 2010    7
 Federal Motor Carrier Safety Administration
                                                                            FMC-CSA-10-002
The Operational Model




U.S. Department of Transportation             Industry Briefing, December 2010    8
Federal Motor Carrier Safety Administration
                                                                 FMC-CSA-10-002
Op-Model: Three Core Components

1. Measuring Carrier Safety
       Improved ability for earlier identification of demonstrated safety
       problems by specific Behavior Analysis and Safety Improvement
       Categories (BASICs) from:
     a)       Safety Measurement System results (on-road performance), and/or
     b)       Investigation Findings
2. Intervention Process
       Employs an array of interventions instead of the previous principal
       option  a labor-intensive compliance review
3. Safety Fitness Determination (SFD)
       SFD to be tied to current safety performance; not limited to results
       of acute/critical violations from a compliance review

 U.S. Department of Transportation                        Industry Briefing, December 2010    9
 Federal Motor Carrier Safety Administration
                                                                             FMC-CSA-10-002
Safety Measurement System

CSA introduces the 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 seven BASICs
• Triggers the intervention process (eventually will feed
  Safety Fitness Determination)


U.S. Department of Transportation             Industry Briefing, December 2010    10
Federal Motor Carrier Safety Administration
                                                                 FMC-CSA-10-002
BASICs

BASICs focus on behaviors linked to crash risk
  1. 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

U.S. Department of Transportation             Industry Briefing, December 2010    11
Federal Motor Carrier Safety Administration
                                                                 FMC-CSA-10-002
  SafeStat vs. SMS

Previous Measurement System: SafeStat                                 CSA’s SMS
Organized by four broad categories called Safety   Organized by seven specific BASICs
Evaluation Areas (SEAs): Accident, Driver,
Vehicle, and Safety Management

Identified carrier for a compliance review (CR)    Identifies safety problems to determine whom to
                                                   investigate and where to focus the investigation
Used only out-of-service (OOS) and moving          Uses all safety-based roadside inspection
violations from roadside inspections.              violations

Had no impact on safety rating                     Used to propose adverse safety fitness
                                                   determination based on carriers’ current on-road
                                                   safety performance (future)
Violations were not weighted based on              Violations are weighted based on relationship to
relationship to crash risk                         crash risk
Assessed carriers only                             Measures both carriers and drivers – the Driver
                                                   SMS is a tool for investigators to identify drivers
                                                   with safety problems during carrier investigations
   U.S. Department of Transportation                                   Industry Briefing, December 2010    12
   Federal Motor Carrier Safety Administration
                                                                                          FMC-CSA-10-002
 Investigation Findings

Included in the BASIC measurements are serious
  violation findings from investigations
• Serious violations generally consist of
     – Noncompliance that’s so severe that immediate corrective
       action is necessary
     – Directly related to carrier’s management and/or operational
       controls
• Serious violations found from prior investigations are
  factored into BASIC measurements
     – BASIC is considered to be in an alert status and displayed
       accordingly on a carrier’s record for 12 months

 U.S. Department of Transportation              Industry Briefing, December 2010
 Federal Motor Carrier Safety Administration
                                                                   FMC-CSA-10-002
 New Agency Plans for Drivers

• The 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, individual drivers will not be assigned
  safety ratings or safety fitness determinations


 U.S. Department of Transportation             Industry Briefing, December 2010    14
 Federal Motor Carrier Safety Administration
                                                                  FMC-CSA-10-002
New Agency Plans for Drivers (cont’d)

• Pre-employment Screening Program (PSP)
     – PSP was mandated by Congress and is not a part of CSA
     – “Driver Profiles” from FMCSA’s Driver Information
       Resource (DIR) are available to carriers through PSP
     – Driver Profiles will only be released with driver
       authorization
     – PSP is currently available, access and additional
       information can be found at www.psp.fmcsa.dot.gov



 U.S. Department of Transportation             Industry Briefing, December 2010    15
 Federal Motor Carrier Safety Administration
                                                                  FMC-CSA-10-002
Example of SafeStat vs. SMS




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




U.S. Department of Transportation             Industry Briefing, December 2010    16
Federal Motor Carrier Safety Administration
                                                                 FMC-CSA-10-002
Carrier Measurement: SMS Results




U.S. Department of Transportation             Industry Briefing, December 2010    17
Federal Motor Carrier Safety Administration
                                                                 FMC-CSA-10-002
Carrier Measurement: SMS Results




U.S. Department of Transportation             Industry Briefing, December 2010    18
Federal Motor Carrier Safety Administration
                                                                 FMC-CSA-10-002
Violation Details Provided in SMS




U.S. Department of Transportation             Industry Briefing, December 2010    19
Federal Motor Carrier Safety Administration
                                                                 FMC-CSA-10-002
Further Drilldown in SMS




U.S. Department of Transportation             Industry Briefing, December 2010    20
Federal Motor Carrier Safety Administration
                                                                 FMC-CSA-10-002
Further Drilldown in SMS




U.S. Department of Transportation             Industry Briefing, December 2010    21
Federal Motor Carrier Safety Administration
                                                                 FMC-CSA-10-002
Further Drilldown in SMS




U.S. Department of Transportation             Industry Briefing, December 2010    22
Federal Motor Carrier Safety Administration
                                                                 FMC-CSA-10-002
  Carrier Access to Data

• Carriers have access to full SMS results and BASIC
  measurements
• Public has access to SMS results and BASIC measurements
  except for percentile scores for the Crash Indicator and
  Cargo-Related BASIC
   – Cargo-Related violations are available to the public
           • Decision regarding what to display was based on feedback through
             out the field test and data preview

   – List of Crashes are available to the public
           • Similar to the Accident SEA in SafeStat
  U.S. Department of Transportation                    Industry Briefing, December 2010    23
  Federal Motor Carrier Safety Administration
                                                                          FMC-CSA-10-002
     Roadside Uniformity-Background
•    Effort organized into four core initiatives:
    1. Consistent documentation of roadside inspection and
        violation data
    2. Standardized processes for making a Request for Data
        Review (RDR)
    3. Increased awareness of high-level goals of the inspection
        program
         a) Good inspections can support systematic enforcement
            program
         b) Screening vs. Inspection
    4. Uniform inspection selection processes
     U.S. Department of Transportation             Industry Briefing, December 2010    24
     Federal Motor Carrier Safety Administration
                                                                      FMC-CSA-10-002
 FMCSA Data Quality

• Quality data is key to the CSA 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 request a data review to
  ensure the accuracy of Federal- and State-reported
  data

 U.S. Department of Transportation             Industry Briefing, December 2010    25
 Federal Motor Carrier Safety Administration
                                                                  FMC-CSA-10-002
 Requests for Data Review

• Improper Data Review Requests:
             • Driver fired, please remove all these violations
             • Crash not our fault, please remove
             • Driver caused the violation, please remove
             • Violation was committed by an owner operator or other carrier that was leased
               to our operation when the violation occurred, please remove
             • Company with a valid lease agreement to an owner operator states that the
               violation should be assigned to the owner operator
• Helpful Suggestions:
             • Attach document(s) that support the data review request
             • Be specific and detailed in your narrative
             • An owner operator with a valid lease agreement with another company
               submitting a data review request should include a lease agreement
             • Ensure contact information is accurate and updated
             • Check the status frequently (additional information may be requested)
 U.S. Department of Transportation                              Industry Briefing, December 2010    26
 Federal Motor Carrier Safety Administration
                                                                                   FMC-CSA-10-002
The Interventions Process

The Interventions Process addresses the…

 • WHAT
   Discovering violations and
   defining the problem
 • 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

U.S. Department of Transportation             Industry Briefing, December 2010    27
Federal Motor Carrier Safety Administration
                                                                 FMC-CSA-10-002
 Intervention Tools

The intervention tools reach more carriers and
influence safety compliance earlier
•Warning Letters
•Investigations
       − Offsite Investigations
       − Onsite Focused Investigations
       − Onsite Comprehensive Investigations
•Follow-on corrective actions
       − Cooperative Safety Plan (CSP)
       − Notice of Violation (NOV)
       − Notice of Claim (NOC)
       − Operations Out-of-Service Order (OOS)
  U.S. Department of Transportation             Industry Briefing, December 2010    28
  Federal Motor Carrier Safety Administration
                                                                   FMC-CSA-10-002
Safety Fitness Determination (SFD)

SFD would:
• Incorporate on-road safety performance via the new
  SMS, which is updated on a monthly basis
• Continue to include major safety violations found as
  part of CSA investigations
• Produce an SFD of
      – Unfit or
      – Marginal or
      – Continue Operation
        Draft rulemaking is currently in review within USDOT;
            NPRM expected to be published in late 2011.

 U.S. Department of Transportation             Industry Briefing, December 2010    29
 Federal Motor Carrier Safety Administration
                                                                  FMC-CSA-10-002
 Current Rating Process in CSA

• CSA incorporates the existing safety rating process
  and will continue to do so until SFD goes into effect
• Drivers will not be rated
• Ratings are issued based on investigation findings:
     – Onsite 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)

 U.S. Department of Transportation                  Industry Briefing, December 2010    30
 Federal Motor Carrier Safety Administration
                                                                       FMC-CSA-10-002
                   National Rollout


U.S. Department of Transportation             Industry Briefing, December 2010    31
Federal Motor Carrier Safety Administration
                                                                 FMC-CSA-10-002
 Rollout Schedule Guiding Principles

• Integrate lessons learned from nine-state test and feedback from
  national stakeholder outreach
• Create a phased approach to methodically step stakeholders into
  new SMS:
     – Drive industry to information on how they will be measured; urge
       immediate safety improvements
     – Build a foundation for enforcement staff to understand and effectively
       utilize the SMS by internalizing concepts of behaviors and BASICs

• Maximize resources
     – Respond to industry information needs
     – Use measurement system to identify and prioritize carriers with safety
       problems
     – Train field staff in new intervention process
 U.S. Department of Transportation                      Industry Briefing, December 2010    32
 Federal Motor Carrier Safety Administration
                                                                           FMC-CSA-10-002
         CSA Rollout Schedule
April 12 – November 30, 2010
     –    Motor carriers can preview their own data by seeing their roadside inspections/violations and crash events
          organized by BASIC
Summer 2010
     –    June 30th –The Operational Model Test (Op-Model Test) ended
     –    July –The four test states partially applying the CSA 2010 Operational Model fully switched to CSA
     –    August
            • The SMS Methodology was modified to increase its effectiveness
            • Motor carriers were able to see an assessment of their violations based on the new Carrier Safety
               Measurement System (CSMS) that replaced SafeStat
December 2010
     –    SafeStat was replaced by the CSMS, available to the public, including shippers and insurance companies
     –    FMCSA/States prioritize enforcement using the CSMS
     –    FMCSA began issuing warning letters to carriers with BASICs flagged as “alert” in the CSMS
     –    Roadside inspectors use the CSMS results to identify carriers for inspection
     –    Transitional elements were introduced to enhance the effectiveness of the phased rollout
Coming in 2011
     –    Safety Fitness Determination Notice of Proposed Rulemaking (NPRM) is scheduled to be released
     –    Enforcement staff will be trained and new interventions will be implemented state-by-state
         U.S. Department of Transportation                                       Industry Briefing, December 2010    33
         Federal Motor Carrier Safety Administration
                                                                                                    FMC-CSA-10-002
 December 2010 – Detailed Rollout

• SafeStat was replaced by the CSMS, which is available to the public, including
  shippers and insurance companies
• FMCSA/State enforcement began prioritizing enforcement using the CSMS
• FMCSA began issuing warning letters to carriers with deficient BASICs
• Roadside inspectors began using the CSMS results to identify carriers for
  inspections
• Transitional elements were introduced to enhance the effectiveness of the
  phased rollout;
      –    Focused Compliance Reviews
      –    DSMS sampling
      –    Direct Notice of Violations
      –    Red Flag Drivers
• CSA 2010 became the new compliance and enforcement program of FMCSA
  and became known as: CSA – Compliance, Safety, Accountability

  U.S. Department of Transportation                     Industry Briefing, December 2010    34
  Federal Motor Carrier Safety Administration
                                                                           FMC-CSA-10-002
                                        Summary


U.S. Department of Transportation                 Industry Briefing, December 2010    35
Federal Motor Carrier Safety Administration
                                                                     FMC-CSA-10-002
 In Summary…

CSA introduces improvements in three main areas
1. 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

2. 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: SFD
     – 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
 U.S. Department of Transportation                      Industry Briefing, December 2010    36
 Federal Motor Carrier Safety Administration
                                                                           FMC-CSA-10-002
 What Can Carriers Do?

• Educate yourselves and your employees:
     – Understand the SMS Methodology and the BASICs
     – Check the website for information and updates (http://csa.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
     – Log in to the SMS, review BASICs, and address safety problems now!
     – Educate drivers about how their performance impacts their own driving record
       and the safety measurement 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)

 U.S. Department of Transportation                           Industry Briefing, December 2010    37
 Federal Motor Carrier Safety Administration
                                                                                FMC-CSA-10-002
For more information, please visit:
    http://csa.fmcsa.dot.gov



  U.S. Department of Transportation             Industry Briefing, December 2010    38
  Federal Motor Carrier Safety Administration
                                                                   FMC-CSA-10-002

				
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