Compliance, Safety, Accountability (CSA)

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1 Compliance, Safety, Accountability (CSA) A New Way To Measure and Address Commercial Motor Vehicle Safety Industry Briefing December 2010

2 Presentation Agenda Why Change? What is CSA? Field Test and National Rollout Summary 2

3 Why Change? 3

4 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 s (USDOT) Federal Motor Carrier Safety Administration (FMCSA) regulates ~725,000 interstate and foreignbased truck and bus companies USDOT/FMCSA audit (compliance review) was laborintensive Only able to reach < 2% (~12,000) of total carrier population annually 4

5 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. 5

6 What Is CSA? 6

7 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 7

8 The Operational Model 8

9 The Operational Model 9

10 The Operational Model 10

11 The Operational Model 11

12 The Operational Model 12

13 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 13

14 Safety Measurement System CSA introduces the Safety Measurement System (SMS) that Uses crash records and ALL roadside inspection safetybased 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) 14

BASICs BASICs focus on behaviors linked to crash risk 1.

Controlled Substances/Alcohol (Parts 382 & 392) 5.

15 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 15

16 SafeStat vs. SMS Previous Measurement System: SafeStat Organized by four broad categories called Safety Evaluation Areas (SEAs): Accident, Driver, Vehicle, and Safety Management Identified carrier for a compliance review (CR) Used only out-of-service (OOS) and moving violations from roadside inspections. Had no impact on safety rating Violations were not weighted based on relationship to crash risk Assessed carriers only CSA s SMS Organized by seven specific BASICs Identifies safety problems to determine whom to investigate and where to focus the investigation Uses all safety-based roadside inspection violations Used to propose adverse safety fitness determination based on carriers current on-road safety performance (future) Violations are weighted based on relationship to crash risk Measures both carriers and drivers the Driver SMS is a tool for investigators to identify drivers with safety problems during carrier investigations 16

17 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

18 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 18

19 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 19

20 Example of SafeStat vs. SMS The following slides provide examples of key differences between SafeStat and the SMS 20

21 Carrier Measurement: SafeStat Results 21

22 Carrier Measurement: SMS Results 22

23 Carrier Measurement: SMS Results 23

24 Violation Details Provided in SMS 24

25 Further Drilldown in SMS 25

26 Further Drilldown in SMS 26

27 Further Drilldown in SMS 27

28 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 28

29 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 29

30 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 30

31 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 31

32 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) 32

The Interventions Process The Interventions

broke down HOW Determining how to fix it/prevent

33 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 33

34 Safety Management Cycle 34

35 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) 35

36 Previous Process vs. CSA Intervention Process Previous CR Process Broad one-size-fits-all investigation Resource intensive for enforcement agencies and time-consuming for carrier/fewer carriers contacted Focused on broad compliance based on rigid set of acute/critical violations Discovered what violations exist at that time Major safety problems resulted in fines (NOC) Focused on carrier CSA Intervention Process Array of interventions can be tailored to address extent and scope of specific safety alerts Less resource intensive for enforcement agencies and less time-consuming for carrier/more carriers contacted Focuses on improving behaviors that are linked to crash risk Discovers what safety problem(s) are, why they exist, and how to correct them When problems found, major focus on carrier proving corrective action; significant problems continue to result in fines Expands focus to driver violations 36

37 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

38 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( ) 38

39 CSA Field Test and National Rollout 39

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

40 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) 40

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,

41 100% 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 41

42 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 42

43 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 *Since Phase II (Oct. 1, 2010) 43

44 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 44

45 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 30 th 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 45

46 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 46

47 Summary 47

48 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 48

49 What Can Carriers Do? Educate yourselves and your employees: Understand the SMS Methodology and the BASICs Check the website for information and updates ( 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: 49

50 For more information, please visit: 50

CSA Compliance, Safety & Accountability. Training By Patti Gillette, Director of Safety Colorado Motor Carriers Association

CSA Compliance, Safety & Accountability Training By Patti Gillette, Director of Safety Colorado Motor Carriers Association CSA What Is It? New, high-impact FMCSA safety program To improve large truck and