Comprehensive Safety Analysis 2010 - Regulatory Changes, Enforcement Measures and More!

1. Attention Attendees: • Thank you for attending! • The presentation will start in a few minutes at 1:00 PM Central. • Please use your computer speakers to listen to the event. If you have audio issues, dial-in info is below. • You will be muted during the event. • Please use the Question feature to text questions to “Q & A”. We’ll try to answer them during the Q&A period if they are not covered in the presentation. • The slides will be posted in 1-2 days and the recording in 7 days at http://www.jjkeller.com/nptcinfo Comprehensive Safety Analysis 2010 - Regulatory Changes, Enforcement Measures and More! This webcast will cover ... CSA 2010 Background, CSA 2010 Compliance Essentials, Old Castle’s CSA 2010 Compliance Program, and Question & Answer Moderator Dr. Gary Petty, President & CEO, NPTC Panelists Tom Moore, Vice President of Education, NPTC Tom Bray, Editor – Transportation Management, J. J. Keller & Associates, Inc. Larry Ahlers, VP Transportation, Oldcastle Architectural, Inc.

2. Dr. Gary Petty President & CEO National Private Truck Council

3. Introduction • CSA 2010 Background – Tom Moore • CSA 2010 Compliance Essentials – Tom Bray • Oldcastle’s CSA 2010 Compliance Program – Larry Ahlers • Housekeeping issues: • You will be muted during the event. • Please use the Question feature to text questions to the Q&A Panelist. We’ll try to answer them during the Q&A period if they are not covered in the presentation. • If you lose sound at any point, you can dial-in by phone using the number and Pass Code listed below. • If you lose the program window and need to re-loginbe sure to enter a different e-mail address to avoid being denied access for multiple logins. Gary Petty National Private Truck Council

4. Introduction and Disclaimers • Bulk of today’s webcast will be on FMCSA’s Comprehensive Safety Analysis 2010 • The content in this webcast is intended for information purposes only and should not be construed as providing legal advice. • This is an introductory course and is intended to highlight critical safety and compliance topics. Time constraints limit our ability to go in depth. Gary Petty National Private Truck Council

5. Tom Moore, CTP Vice President of Education National Private Truck Council

6. Why Comprehensive Safety Analysis 2010? Tom MooreNational Private Truck Council

7. Then and Now Tom MooreNational Private Truck Council

8. CSA 2010 Operational Model Tom MooreNational Private Truck Council

9. FMCSA Next Steps • Further validate data integrity and timeliness in 9 test states: Colorado, Georgia, Missouri, New Jersey, Minnesota, Montana, Kansas, Maryland, Delaware • Train staff nationwide • Pass SFD/Comprehensive Review/Unfit regulations (proposal due out May 2010) Tom MooreNational Private Truck Council

10. Next Stages of Rollout • 2nd quarter 2010 — CSA 2010 data “visible” • Roughly July 2010 — CSA 2010 SMS takes over for SafeStat • SMS startup to December 2010 — State FMCSA offices begin using new interventions Tom MooreNational Private Truck Council

11. Tom Bray Editor, Transportation Management J. J. Keller & Associates, Inc.

12. CSA 2010 Summary of Changes CSA 2010 essentially has two components: Replacement for SafeStat/Compliance Review process of selecting carriers for interventions (no rulemaking required) Use data to “rate” carriers and place poor-performing carriers out of service based on the data/rating system (requires rulemaking) Tom BrayJ. J. Keller & Associates, Inc.

13. CSA 2010 Process Data collection New Safety Measurement System (SMS) Safety Evaluation based on SMS Comprehensive interventions Tom BrayJ. J. Keller & Associates, Inc.

14. Data Collection All DOT recordable crash data Roadside inspection data Intervention data Tom BrayJ. J. Keller & Associates, Inc. Motor Carrier Compliance Activities & Crash Reports Safety Data

15. Safety Measurement System (SMS) Uses seven “BASICs” (Behavior Analysis and Safety Improvement Categories) to analyze carriers Measures safety performance using all violations discovered during inspections Violations are weighted based on time and severity Tom BrayJ. J. Keller & Associates, Inc. • MEASUREMENT • On-Road Safety Performance • (BASICs) • Unsafe Driving • Fatigued Driving (HOS) • Driver Fitness • Controlled Substances and Alcohol • Vehicle Maintenance • Cargo Related • Crash Indicator • Intervention Findings • Essential Safety Management Violations • Fundamental Violations

16. Seven BASICs Unsafe Driving (Part 392, 397, and traffic laws) Fatigued Driving (Parts 392 and 395) Driver Fitness (Parts 383 and 391) Controlled Substances/Alcohol (Part 382 and 392) Vehicle Maintenance (Parts 393 and 396) Cargo (Part 393, Subpart I and HM regulations) Crash Indicator Tom BrayJ. J. Keller & Associates, Inc.

17. SMS BASIC Process Relevant intervention, inspection, violation and crash data assigned to the carrier Violations and crashes are classified into the correct BASIC Events are severity weighted and time weighted Data totaled, normalized, and peer grouped Percentile assigned (BASIC Score) Tom BrayJ. J. Keller & Associates, Inc.

18. SMS BASIC Process • Events are severity weighted • Violations 1 to 10 • Accidents 1 to 3 • Events are time weighted • 0 to 6 months = 3 • 6 to 12 months = 2 • 12 + months = 1 • Full value is determined by these formulas: • Violations = Severity + OOS x time weight • Crash = Severity + 1 if HM spilled x time weight Tom BrayJ. J. Keller & Associates, Inc.

19. SMS BASIC Process Example of violation weighting: A driver is placed out of service for an over-hours violation in the last six months. 7 Severity weighting + 2 Out-of-service 9 Total severity weighting Time weighting = 3 (occurred in last six months) 9 Total severity weighting x 3 Time weighting 27 total Fatigued Driving BASIC value. Tom BrayJ. J. Keller & Associates, Inc.

20. SMS BASIC Process • BASIC Scoring Process • Event values in each BASIC are totaled • Each “BASIC Measure” determined by dividing total event scores by “normalizing factor” (vehicle count or number of inspections) • Peer grouped in each BASIC based on measure (groups are based on vehicle count or number of inspections) • Percentile ranking in peer group assigned in each BASIC (this is the “BASIC Score”) Tom BrayJ. J. Keller & Associates, Inc.

21. SMS BASIC Process “Safeties” Minimum required to activate scoring Stacking prevented Per BASIC limit Tom BrayJ. J. Keller & Associates, Inc.

22. Driver Safety Measurement System (DSMS) Will use same principles as Carrier SMS Data collection Safety measurement (BASICs) Safety evaluation Intervention if necessary Interventions under development Driver BASIC Measures and BASIC Scores will be confidential Tom BrayJ. J. Keller & Associates, Inc.

23. Safety Evaluation v. Determination • Presently “Evaluation” is performed, in future “Determination” (rating) will be given • BASIC Score over intervention threshold triggers an intervention • Evaluations/Determinations • Continue to Operate (no contact) • Marginal (progressive interventions) • Proposed “Unfit Determination” (correct or cease operations) Tom BrayJ. J. Keller & Associates, Inc.

24. Interventions • Warning letter • Targeted roadside enforcement (ISS-D) • Focused off-site investigation • Focused on-site investigation • Comprehensive review (compliance review) • Cooperative (corrective) safety plan • Notice of Violation • Notice of Claim/Consent Agreement • Declare Unfit/Suspend (proposed) Tom BrayJ. J. Keller & Associates, Inc.

25. Getting Prepared • Learn the system • View your existing data through the “CSA 2010 lens” • Get good data going in now • Good data means good inspections (no violations) and no preventable crashes • Stop “foolish” inspections • Appeal incorrect data • Train and track drivers on: • CSA 2010 awareness • Defensive driving • Compliance with the safety regulations (hours, qualifications, etc.) • Vehicle inspection • Roadside inspection performance Tom BrayJ. J. Keller & Associates, Inc.

26. Larry Ahlers, CTPVice President of Transportation Oldcastle Architectural, Inc.

27. Oldcastle Fleet Operations • Fleet consists of : • 557 Power Units of varied types • 402 Trailers • 526 CDL Drivers • Oldcastle transportation operations include everything from raw material pickups to finished goods deliveries primarily on flatbeds from 212 plants and distribution centers within the U.S. and eastern Canada. Larry AhlersOldcastle Architectural, Inc.

28. Impact of CSA 2010 on Oldcastle • Conducted an Impact Assessment • Reviewed SMS process (BASICs, weighting, measurement) • Met with local motor truck association • Met with local DOT officials • Studied “high severity” violations • Revising Policies and Procedures • Developing Specific Communications • Including SMS Focus in Training • Revising Data and Reporting Larry AhlersOldcastle Architectural, Inc.

29. Driver Policies and Procedures • Driver Qualification - due diligence (FMCSA Pre-employment Screening Program) • Rewards - add rewards for clean roadside inspections • Coaching and Training - emphasis on critical areas (e.g., HOS, defensive driving, roadside inspections) • Disciplinary Action and Termination Larry AhlersOldcastle Architectural, Inc.

30. Maintenance Policies and Procedures • Monitor and Audit Vehicle Inspections and Repairs Documentation • Acknowledgement – recognize clean roadside inspections • Update Periodic Maintenance Intervals • Technician Coaching and Training • Disciplinary Action and Termination Larry AhlersOldcastle Architectural, Inc.

31. Data Accuracy Measures • Review and update MCS 150 profile at regular intervals: https://www.fmcsa.dot.gov/registration-licensing/gettingstarted/forms.htm • Review roadside inspections data frequently: https://portal.fmcsa.dot.gov • Challenge inaccurate data: https://dataqs.fmcsa.dot.gov Larry AhlersOldcastle Architectural, Inc.

32. FMCSA’s CSI System Larry AhlersOldcastle Architectural, Inc.

33. FMCSA’s CSI System Larry AhlersOldcastle Architectural, Inc.

34. FMCSA’s CSI System Larry AhlersOldcastle Architectural, Inc.

35. FMCSA’s CSI System Larry AhlersOldcastle Architectural, Inc.

36. FMCSA’s CSI System Larry AhlersOldcastle Architectural, Inc.

37. FMCSA’s CSI System Larry AhlersOldcastle Architectural, Inc.

38. FMCSA’s CSI System Larry AhlersOldcastle Architectural, Inc.

39. FMCSA’s CSI System Larry AhlersOldcastle Architectural, Inc.

40. Focusing Compliance Efforts • CSI system is a good start in identifying deficiencies • Driver Management • Equipment Management • Load Management • Benchmark your ratings against others • Peer Group • Outside Carrier Assessment • Download data and identify at risk BASICs • Interact with drivers, maintenance, and operations Larry AhlersOldcastle Architectural, Inc.

41. Carrier Compliance Efforts • Focused on Safety of Employees and Contractors • Study “high severity” violations of Carriers • Policy is to “not use unsafe Carriers” • Developing Specific Communication with Carriers • Offer Carriers support and alternatives for assistance • Revised Data and Reporting on Carrier Compliance Larry AhlersOldcastle Architectural, Inc.

42. Driver Training • CSA 2010 • Defensive driving • Compliance with the safety regulations (hours, qualifications, etc.) • Vehicle inspection • Roadside inspection performance • Avoiding roadside inspections conducted due to • Speeding and other traffic violations • Entering scale with lights not working or overweight • Notification of any citations /warnings with response Larry AhlersOldcastle Architectural, Inc.

43. Question & Answer Please submit questions to “Q&A” using the Q&A tool Tom BrayJ. J. Keller & Associates, Inc. Larry AhlersOldcastle Architectural, Inc. Tom MooreNational Private Truck Council Gary Petty National Private Truck Council

44. Closing Remarks Past CSA 2010 webcast recording (12/3 air date): http://www.jjkeller.com/CSA_2010 Checkout the archive of past topics at: http://www.jjkeller.com/nptcinfo PowerPoint slides up in 1-2 days Recording up in 1 week Topics for 2010: June 2 – Enhanced Driver Qualification – Testing, Physicals and Background Checks August 25 – Fleet Excellence – Customer Service October 20 – Fleet Excellence – Driver Recruiting & Retention Gary Petty National Private Truck Council