CSA Changes: December 2012

Transcription

1 CSA: HazMat BASIC & HazMat Carriers Update Boyd Stephenson American Trucking Associations January 10, 2013 CSA Changes: December 2012 Fatigued Driving BASIC HOS Compliance BASIC Intermodal Violations Count 392.2S Changes Violations tracked to type of inspection EOBR/Logbook Equalization 1

2 CSA Changes: December 2012 Displaying % inspections involving placardable quantities Driver violations for driver inspections & vehicle to vehicle Separating out fatality/injury information Speeding violation changes Equalizing severity weights for EOBR and logbook violations CSA Safety Events (Roadside Inspections, Crashes) Safety Fitness Determined (Subject to Future Rulemaking) Violations categorized and placed into BASICs Carriers selected for interventions Violations weighted Carriers ranked Measures adjusted for size/exposure 2

3 BASICs BASIC REGULATORY SECTIONS COVERED VIOLATION EXAMPLES Unsafe Driving Parts 392 & 397 Speeding, Following Too Closely, Improper Lane Change Hours-of-Service Compliance Parts 392 & 395 Hourly Violations (11,14, 60/70 hour), Form and Manner, False Log Driver Fitness Parts 383 & 391 Expired Med Card, Improper Endorsements, Driving While Disqualified Controlled Substances/ Alcohol Parts 382 & 392 Use or Possession of Drugs/Alcohol Vehicle Maintenance Parts 393 & 396 Lighting, Brake Adjustment, Tire Depth Hazardous Materials Compliance Parts 171, 172, 177, 383 & 397 Improper Placarding Weighting Violations & Crashes Violations Relationship to Crash Risk Crash Causation Crash Severity Age Violations: 1-10 points Crashes: 1-3 points Age Weights 0-6 months: 3x 6-12 months: 2x months: 1x Crashes Crash Severity Tow-Away (1 point) Injury or Fatality (2 points) HM Release (+1 point) Age Out of Service Violations +2 points Total points per inspection capped at 30 before age weight multiplier applied 3

4 Violation Example (f)(2) Intermediate bulk container (IBC) not secured to or within vehicle (DSMS), 14 months ago Violation severity weight: 10 points Age multiplier: 2x Total points: 20 Exposure Adjustment Number of Violations (Time and Severity Weighted) # of Relevant Inspections or Crashes * Utilization Factor (if present) 4

5 Exposure Adjustment Combination Unit Fleets (>or = 70%) Average mileage (VMT) per Power Unit Utilization Factor < 80, , , [(VMT per power unit-80,000) /80,000] 160, , > 200,000 1 No recent VMT information 1 Single Unit Fleets (>30%) Average mileage (VMT) per Power Unit Utilization Factor < 20, ,000 60,000 VMT per power unit /20,000 60, ,000 3 > 200,000 1 No recent VMT information 1 Safety Event Groups Hazardous Materials Compliance Safety Event Group Category Number of Relevant Inspections (Level 1, 2, 5, 6)

6 Safety Event Groups January Carrier A Carrier B Carrier C Carrier D Carrier E Raw Score Indexed Score February Carrier A Carrier B Carrier C Carrier D Carrier E Raw Score N/A Indexed Score N/A November Carrier A Carrier B Carrier C Carrier D Carrier E Raw Score N/A Indexed Score N/A

7 CSA: HazMat Compliance BASIC Separation of load securement and HM violations Compliance BASIC Hidden from public view until at least December 2013 CSA: HazMat BASIC Violations Removed: Failing to register with PHMSA (b) No copy of US DOT HM Registration Number 397.3AU Failing to comply with Alliance for Uniform HM Registration requirements 7

8 HM BASIC: Predictive Power HM BASIC: Predictive Power 8

9 HM BASIC: Predictive Power CSA: HM Carrier Defined CSA defines two kinds of carriers as HM Carriers: Carriers with a HazMat Safety Permit OR Carriers with at least 2 inspections on a vehicle transporting HM requiring placards within the last 24 months and with one of those inspections within the last 12 months AND At least 5% of total inspections involve a vehicle transporting HM requiring placards. 9

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11 Carrier Thresholds BASICs/Indicator: Unsafe Driving HOS Compliance Crash Indicator CARRIER TYPE THRESHOLD PERCENTILE Most Carriers 65% Hazardous Materials 60% Passenger 50% BASICs: Driver Fitness Drugs/Alcohol Vehicle Maintenance CARRIER TYPE THRESHOLD PERCENTILE Most Carriers 80% Hazardous Materials 75% Passenger 65% Carrier Thresholds CARRIER TYPE BASIC: Hazardous Materials Compliance THRESHOLD PERCENTILE Most Carriers 80% Hazardous Materials 80% Passenger 80% 11

12 Inspection Selection System Safety Algorithm Recommendation ISS Inspection Value Inspect (Inspection warranted top priority) Optional (Inspection warranted next level priority) Pass (Inspection not warranted) 1-49 Inspection Selection System Safety Algorithm, cont. Inspect Optional ISS-2010 Safety Algorithm Prioritization Carriers with a Serious Violation in the last 12 months High Risk Carriers Carriers with Two or Three Deficient BASICs Carriers with a Deficient Fatigued Driving (HOS) BASIC Carriers with a Deficient Unsafe Driving BASIC or a Deficient Crash Indicator Carriers with a Deficient Cargo-Related, Controlled Substances/Alcohol, Driver Fitness, OR Vehicle Maintenance BASIC Pass 1-49 All other carriers with sufficient data to measure 12

13 Inspection Selection System Insufficient Data Algorithm ISS-2010 Insufficient Data Algorithm Prioritization Inspect Optional Carriers a single Inspection from having enough inspections to receive a BASIC score Carriers with Zero Roadside Inspections Carriers with Some Inspections and a Low Inspection Rate Carriers with Some Inspections and a High Inspection Rate Continuing Concerns Crash Accountability Crash Underreporting & Regional Enforcement Disparities Warnings & Dismissed Citations Inappropriate Violation Weights 13

14 CSA: The Future Periodic Updates Safety Fitness Determinations Final Takeaway Overall, CSA has proven better at both targeting inspections & improving compliance than the former rating system. Portions of CSA very effectively measure safety performance Unsafe Driving BASIC Portions of CSA are not so effective Driver Fitness BASIC Hazardous Materials Compliance BASIC 14

15 Final Takeaway The less effective portions of CSA are undergoing constant reevaluation Effective use of CSA requires knowing which portions of CSA accurately predict safety performance & which do not Effective use of CSA requires knowing how to unpack CSA scores to get an accurate portrait of a motor carrier. Questions? Boyd Stephenson bstephenson@trucking.org (703)