compliance, safety, accountability (csa) pdc/csa2010industry.pdf · fmc-csa-10-002 compliance,...

U.S. Department of TransportationFederal Motor Carrier Safety Administration

Industry Briefing, December 2010FMC-CSA-10-002

Compliance, Safety, Accountability

(CSA)

A New Way To Measure and Address Commercial Motor Vehicle Safety

Industry BriefingDecember 2010



Presentation Agenda

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

Rollout• Summary

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Why Change?

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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

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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.

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What Is CSA?

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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

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The Operational Model

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Op-Model: Three Core Components

1. Measuring Carrier SafetyImproved 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/orb) Investigation Findings

2. Intervention ProcessEmploys 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

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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)

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BASICs

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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SafeStat vs. SMS

Previous Measurement System: SafeStat CSA’s SMS

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

Organized by seven specific BASICs

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 violations from roadside inspections.

Uses all safety-based roadside inspection 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 relationship to crash risk

Violations are weighted based on relationship to 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

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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



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

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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

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Example of SafeStat vs. SMS

The following slides provide examples of key differences between

SafeStat and the SMS

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Carrier Measurement: SafeStat Results

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Carrier Measurement: SMS 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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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 SafeStat28



Roadside Data Uniformity

• Data collected at the roadside is the foundation of all data-driven traffic safety initiatives

• CSA relies on roadside data in its SMS Methodology

• The CSA SFD methodology would use roadside data as a component of the safety fitness determinations

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Roadside Uniformity-Background

• Effort organized into four core initiatives:1. Consistent documentation of roadside inspection and

violation data2. Standardized processes for making a Request for Data

Review (RDR)3. Increased awareness of high-level goals of the inspection

programa) Good inspections can support systematic enforcement

programb) Screening vs. Inspection

4. Uniform inspection selection processes30



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

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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)

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The Interventions Process

The Interventions Process addresses the…

• WHAT Discovering violations anddefining the problem

• 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

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Safety Management Cycle

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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)

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Previous Process vs. CSA Intervention Process

Previous CR Process CSA Intervention Process

Broad one-size-fits-all investigation Array of interventions can be tailored to address extent and scope of specific safety alerts

Resource intensive for enforcement agencies and time-consuming for carrier/fewer carriers contacted

Less resource intensive for enforcement agencies and less time-consuming for carrier/more carriers contacted

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

Focuses on improving behaviors that are linked to crash risk

Discovered what violations exist at that time

Discovers what safety problem(s) are, why they exist, and how to correct them

Major safety problems resulted in fines (NOC)

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

Focused on carrier Expands focus to driver violations36



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.

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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)

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CSA Field Test and National Rollout

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CSA Field Test

Operational Model Field Test Design:• Design completed January 2008

– Divided representative carriers into comparable test and control groups

Operational 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 (first test group)

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100% States in Field Test

• Additional states– Spring 2009: MT (AB), MN (ON)– Fall 2009: KS, MD, DE

• 100% of the State participates in CSA – 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 Results

CSA Field Test:• Reached its goal of contacting more carriers

– Research shows more contacts equals improved safety performance• Resulted in strong enforcement; similar to current model • Employed the full array of investigations

– Investigations in test states were done in the following proportions• Onsite Comprehensive Investigations (~25%)• Onsite Focused Investigations (~45%)• Offsite Investigations (~30%)

• Followed up with carriers: 50% of investigations result in one of following:

• NOC or NOV• CSP• Driver-Specific follow-on activities

– NOV– NOC

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More Preliminary Results

Warning letters are having a positive impact:

• Over 8,500* sent

• Almost 50%* of recipients logged in to view their data and safety assessments

• Feedback from test states indicate that some carriers appreciate the early alert

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*Since Phase II (Oct. 1, 2010)



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

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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 BASICSummer 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 SafeStatDecember 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

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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

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Summary

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In Summary…

CSA introduces improvements in three main areas1. 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

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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)

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For more information, please visit: http://csa.fmcsa.dot.gov

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