CSA State of the Union - PDF Free Download

CSA State of the Union June 5, 2014 Steve Bryan s.bryan@vigillo.com

About Vigillo Founded in 2007 by a team of statisticians and software engineers with a talent for deciphering complex information and delivering it in an at-a-glance scorecard format, Vigillo specializes in taking copious amounts of data and turning it into factually reliable and usable information.

1. ATRI CSA Survey 2. GAO Audit 3. Methodology Changes 4. IG Audit 5. Crash Accountability 6. Safety Fitness Rule 7. ATA Advocacy 8. ASECTT Lawsuit 9. OOIDA Lawsuit 10. Disparate Enforcement 11. NTSB Comments 12. Expanded FMCSA Power https://vigillo.com/2014/03/csa-2014-state-union/

ATRI CSA Survey Feb 3 On average, drivers responded to the knowledge test with 42.4 percent accuracy, so three years after implementation drivers do not have a clear understanding of CSA, ATRI suggests. enforcement personnel completed the CSA knowledge test with an average of 66.5 percent accuracy with CSA in its third year of operation, enforcement personnel performed poorly on the items addressing BASICs Enforcement personnel also indicated a lack of training on DataQs (20 percent), RI standards (23.3 percent) and the reporting of RI violations (26.7 percent). http://www.ccjdigital.com/drivers-enforcement-still-unsure-on-csa-report-shows/

GAO Audit Feb 4 1. Recommendation: the Secretary of Transportation should direct the FMCSA Administrator to revise the SMS methodology to better account for limitations in drawing comparisons of safety performance information across carriers;, the Secretary of Transportation should direct the FMCSA Administrator to conduct a formal analysis that specifically identifies: (1) limitations in the data used to calculate SMS scores including variability in the carrier population and the quality and quantity of data available for carrier safety performance assessments, and (2) limitations in the resulting SMS scores including their precision, confidence, and reliability for the purposes for which they are used 2. Recommendation: To improve the CSA program, the Secretary of Transportation should direct the FMCSA Administrator to ensure that any determination of a carrier s fitness to operate properly accounts for limitations we have identified regarding safety performance information. http://www.gao.gov/products/gao-14-114

Methodology Changes Comment Period Closed 1/6 The Federal Motor Carrier Safety Administration (FMCSA) is proposing enhancements to the display of information on the SMS Website. The proposed redesign is intended to advance FMCSA s safety mission by making important information easier to understand for motor carriers who want to improve their safety performance and for public users interested in FMCSA data the proposed enhancements do not include changes to the CSA Methodology 1. Safety Event Groups Available 2. New Disclaimer language 3. Newly designed website https://csa.fmcsa.dot.gov/whats_new.aspx

OOIDA Lawsuit March 6 Court rules in OOIDA's favor in Data Q jurisdictional legal battle By Land Line staff, OOIDA Member Fred Weaver will have his day in federal district court over a violation that remains on his driver profile with the Federal Motor Carrier Safety Administration even though the ticket was dismissed thanks to a ruling Friday by the U.S. Court of Appeals for the District of Columbia. The Owner-Operator Independent Drivers Association filed suit on behalf of OOIDA Member Fred Weaver in May 2013. Weaver was cited by an officer in Montana for failure to stop at a weigh station. That charge was later dismissed by a Montana state court, but the Federal Motor Carrier Safety Administration denied Weaver s Data Q request to have the record of that charge removed from the Motor Carrier Management Information System (MCMIS) database. http://m.landlinemag.com/story.aspx?storyid=26626#.uydxtwdowid

OOIDA Lawsuit March 6 http://m.landlinemag.com/story.aspx?storyid=26626#.uydxtwdowid

IG Audit - March 10 Recommendation 1: Issue updated DataQs guidance. Recommendation 2: Implement the process for deactivating USDOT numbers when carriers do not submit required census data, as described in FMCSA memorandum MC-ES-2013-0009. Recommendation 3: Develop a comprehensive plan to fully implement CSA enforcement interventions in the remaining 41 States. The plan should include an estimated completion date and milestones for releasing Sentri software, developing and delivering training, and using the enforcement interventions. Recommendation 4: Update the CSMS requirements document to (a) specify all sources of CSMS data, including each of the MCMIS fields used, and (b) fully describe CSMS validation procedures. * Recommendation 5: Develop and implement a process for managing CSMS system documentation that includes a central file for validation records and testing results. Recommendation 6: Develop and implement a configuration management policy that includes documentation of system changes and associated testing for CSMS. *FMCSA has limited documentation demonstrating that it followed information technology system best practices and Federal guidance while developing and testing CSMS. http://www.oig.dot.gov/sites/dot/files/csa%20report.pdf

NTSB Comments The National Transportation Safety Board has sharply criticized the Federal Motor Carrier Safety Administration's oversight processes in light of several deadly crashes that the board investigated, saying the findings from these investigations raise serious questions about the oversight of motor carrier operations and is recommended audits of the agency s oversight processes. http://www.truckinginfo.com/channel/drivers/news/story/2013/11/ntsb-calls-for-audit-of-fmcsa-s-safety-oversight.aspx

ATA Advocacy - Ongoing Two primary goals that ATA has for CSA this year 1. Remove CSA Scores from Public View 2. Crash Accountability Process

Expanded FMCSA Power Feb 21 Rep. Richard Hanna suggested that FMCSA is hurting the people that you are paid to help. http://www.ccjdigital.com/ferro-defends-hours-of-service-change-csa-in-house-hearing/ I m not hired to help the industry, Ferro responded.

Congress has drafted legislation: Congressmen Duncan (R-TN), Paulsen (R-MN), and Rodney Davis (R-IL) introduced H.R. 4727,

1. Crash Accountability 2. Safety Fitness Rule 3. ASECTT Lawsuit 4. Disparate Enforcement

DOT Reportable

1. Crash Accountability 2. Safety Fitness Rule 3. ASECTT Lawsuit 4. Disparate Enforcement

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Vehicle Maintenance Inspections/MCVMT RETURN 13.70 17.59 8.67 8.11 11.04 14.50 6.57 10.79 15.28 30.52 9.44 2.65 11.55 9.94 15.38 47.06 15.58 19.78 13.38 10.25 10.41 4.72 12.19 2.88 4.59 7.79 5.72 7.81 10.49 11.81 12.55 15.25 7.01 7.45 11.31 MD 25.80 6.22 VM Inspections/MCVMT 2.65 47.06 About Tableau maps: www.tableausoftware.com/mapdata Vehicle Maintenance CSA Points/MCVMT TX CT MO MN VA WY WI LA NM OR MI 175.4 88.4 57.7 55.6 49.9 40.4 38.6 37.7 37.0 35.7 30.8 AZ 105.3 MD 90.9 MT 72.1 IA 71.5 KS 58.6 NY 57.6 CA 57.2 NH 56.5 KY 52.6 NV 52.4 WA 51.4 ME 48.4 SD 46.5 VT 42.0 SC 40.9 NE 39.6 WV 39.5 OH 39.2 CO 39.0 MS 30.6 AR 30.5 NC 28.7 ID 28.4 GA 26.7 FL 24.4 UT AL NJ 25.1 MA PA 24.7 24.6 IN TN DE IL OK 16.9 ND Based on 2011 FHWA data. District of Columbia and Rhode Island have low Commercial Vehicle Miles and were removed from this view. 25

Regional Enforcement Disparity Example Traffic Enforcement vs Roadside Light:Speed Ratio 11.97 (US) Light:Speed Ratio 12.17 (South Carolina) Light:Speed Ratio 28.36 (Florida) Light:Speed Ratio 40.40 (Louisiana) Light:Speed Ratio 1.91 (Indiana) Light:Speed Ratio 321.02 (Texas)

1. Crash Accountability 2. Safety Fitness Rule 3. ASECTT Lawsuit 4. Disparate Enforcement

Safety Fitness Determination Rule Violation Data CSA Methodology SFD 1. Satisfactory 2. Unsatisfactory 3. Conditional 4. No Data

CSA State of the Union June 5, 2014 Steve Bryan s.bryan@vigillo.com