U.S. Department of Transportation Federal Motor Carrier Safety Administration

1. Comprehensive Safety Analysis (CSA) 2010A New Way To Measure and Address Commercial Motor Vehicle SafetyIndustry BriefingAugust 2010 U.S. Department of Transportation Federal Motor Carrier Safety Administration

2. Presentation Agenda Why Change? CSA 2010: Defined Test and Implementation Summary

3. Why Change?

4. Commercial Motor Vehicle Fatalities Rate of Commercial Motor Vehicle Fatalities is Leveling Off

5. 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

6. Comprehensive Safety Analysis 2010 What is CSA 2010? CSA 2010 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.

7. 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 • 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

8. CSA 2010Defined

9. A New Operational Model (Op-Model)

10. A New Operational Model (Op-Model)

11. A New Operational Model (Op-Model)

12. A New Operational Model (Op-Model)

13. A New Operational Model (Op-Model)

14. Op-Model: Three Core Components • New Way to Assess Carrier SafetyImproved ability for earlier identification of demonstrated safety problems by specific Behavior Analysis Safety Improvement Categories (BASICs) from: • Safety Measurement System results (on-road performance), and/or • Investigation Findings • New intervention processEmploys an array of interventions instead of the current principal option -- a labor-intensive compliance review • New approach to Safety Fitness Determination (SFD)SFD would be tied to current safety performance; not limited to results of acute/critical violations from a compliance review

15. 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 • Assigns weights to time and severity of violations based on relationship to crash risk • Calculates safety performance based on 7 BASICs • Triggers the intervention process (eventually would feed Safety Fitness Determination)

16. BASICs 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

17. SafeStat vs SMS

18. Investigation Findings Included in BASIC assessments are serious violation findings from investigations • Serious Violations generally consist of • Non-compliance that’s so severe 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 Assessments • BASIC is considered deficient and displayed accordingly on a carrier’s record for 12 months

19. New Agency Plans for Drivers • The new 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 2010, individual drivers will not be assigned safety ratings or safety fitness determinations

20. New Agency Plans for Drivers (cont’d) • Other Agency initiatives are underway, including the Pre-employment Screening Program (PSP) • PSP was mandated by Congress and is not a part of CSA 2010 • “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

21. Example of SafeStat vs SMS The following slides provide examples of key differences between SafeStat and the new SMS

22. Carrier Measurement: SafeStat Results

23. Carrier Measurement: SMS Results

24. Violation Details Provided in SMS

25. Further Drilldown in SMS

26. Carrier Access to Data When will the Carriers’ SMS results be made available? • Currently, only test state carriers have access to full SMS results by using the Comprehensive Safety Information (CSI) system • As of August 16, 2010 all carriers have access to FMCSA’s Data Preview (https://csa2010.fmcsa.dot.gov/DataPreview) which includes carrier safety assessments by BASIC • Carriers will have access to full SMS results and BASIC assessments in December 2010 • Public will have access to SMS results and BASIC assessments in December 2010 except for the Crash Indicator

27. Roadside Data Uniformity • Data collected at the roadside is the foundation of all data driven traffic safety initiatives • CSA 2010 relies on roadside data in its SMS Methodology • The CSA 2010 SFD methodology would use roadside data as a component of the safety fitness determinations

28. Roadside Uniformity-Background • Effort organized into four core initiatives: • Consistent documentation of roadside inspection and violation data • Standardized processes for making a Request for Data Review (RDR) • Increased awareness of high-level goals of the inspection program • Good inspections can support systematic enforcement program • Screening vs. Inspection • Uniform inspection selection processes

29. FMCSA Data Quality Quality data is key to CSA 2010 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

30. 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 challenges that the violation should be assigned to the owner operator • Helpful Suggestions: • Attach document(s) that support the challenge • Be specific and detailed in your narrative • An owner operator with a valid lease agreement with another company submitting a challenge should include a lease agreement • Ensure contact information is accurate and updated • Check the status frequently, (additional information may be requested)

31. New Interventions Process The New 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

32. Safety Management Cycle

33. 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)

34. Current vs CSA 2010 Intervention Process

35. Safety Fitness Determination (SFD) SFD would: Incorporate on-road safety performance via new SMS which is updated on a monthly basis Continue to include major safety violations found as part of CSA 2010 investigations Produce a Safety Fitness Determination (SFD) of Unfit or Marginal or Continue Operation Draft rulemaking is currently in review within DOT; NPRM expected to be published in late 2010.

36. Current Rating Process in CSA 2010 • CSA 2010 incorporates the existing safety rating process and will continue to do so until SFD would go into effect • Drivers will not be rated • Ratings are issued based on investigation findings: • On-site 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)

37. CSA 2010 Test and National Roll-out

38. CSA 2010 Field Test Operational-Model Field Test Design: • Design completed January 2008 • Divides 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)

39. 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 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 39

40. Preliminary Results So far, CSA 2010 is: • Reaching its goal of contacting more carriers • Research shows more contacts equals improved safety performance • Resulting in strong enforcement; similar to current model • Employing the full array of investigations • Investigations in test states have been done in the following proportions • Onsite Investigations – Comprehensive (~25%) • Onsite Investigations – Focused (~45%) • Offsite Investigations (~30%) • Following up with carriers: 50% of investigations result in one of following: • Notice of Claim or Violation • Cooperative Safety Plan • Driver-Specific follow-on activities • Notice of Violation • Notice of Claim

41. More Preliminary Results Warning letters are having a positive impact: • Almost 5,500 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

42. Roll-Out Schedule Guiding Principles • Integrate lessons-learned from 9-state test and feedback from national stakeholder outreach • Create a phased approach to methodically step stakeholders into new measurement system (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 SMS by internalizing concepts of behaviors and BASICs • Maximize resources • Respond to industry information needs • Use new measurement system to identify and prioritize carriers with safety problems • Train field staff in new intervention process 42

43. CSA 2010 Roll-out Schedule April 12 – November 30, 2010 • Motor carriers can preview their own data by seeing their roadside inspections/violations and crash events organized by Behavior Analysis and Safety Improvement Category (BASIC) Summer 2010 • June 30th – The Operational Model (Op-Model) Test ended • July – The four test states partially applying the CSA 2010 Operational Model (Colorado, Georgia, Missouri, and New Jersey ) will fully switch over to CSA 2010, bringing total CSA 2010 states to nine • August • The Safety Measurement System (SMS) Methodology will be modified to increase its effectiveness • Motor carriers will be able to see an assessment of their violations based on the new Carrier Safety Measurement System (CSMS) that will replace SafeStat later in 2010 Fall/Winter 2010 • SafeStat will be replaced by the CSMS, which will be available to the public, including shippers and insurance companies • FMCSA/States will prioritize enforcement using the CSMS • FMCSA will begin to issue warning letters to carriers with deficient BASICs • Roadside inspectors will use the CSMS results to identify carriers for inspection 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

44. Summary

45. In Summary… CSA 2010 introduces improvements in three main areas • New 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 • 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 • Proposed change in evaluation: Safety Fitness Determination • 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

46. What Can Carriers Do To Prepare Now? • Educate Yourselves and Your Employees: • Understand the SMS Methodology and the BASICs • Check the website for information and updates (http://csa2010.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 Data Preview (https://csa2010.fmcsa.dot.gov/DataPreview), review BASIC assessments and address safety problems now! • Educate drivers about how their performance impacts their own driving record and the safety assessment 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)

47. For more information, please visit: csa2010.fmcsa.dot.gov