Compliance, Safety,
Accountability
(CSA)
A New Way To Measure and Address
Commercial Motor Vehicle Safety
Industry Briefing
December 2010
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
Presentation Agenda
• Why Change?
• What is CSA?
• Field Test and National
Rollout
• Summary
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
2
Why Change?
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
3
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
– U.S. Department of Transportation’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
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
4
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.
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
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What Is CSA?
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
6
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
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
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The Operational Model
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
8
The Operational Model
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
9
The Operational Model
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
10
The Operational Model
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
11
The Operational Model
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
12
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)
b)
Safety Measurement System results (on-road performance), and/or
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
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
13
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)
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
14
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
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
15
SafeStat vs. SMS
Previous Measurement System: SafeStat
CSA’s SMS
Organized by four broad categories called Safety
Evaluation Areas (SEAs): Accident, Driver,
Vehicle, and Safety Management
Organized by seven specific BASICs
Identified carrier for a compliance review (CR)
Identifies safety problems to determine whom to
investigate and where to focus the investigation
Used only out-of-service (OOS) and moving
violations from roadside inspections.
Uses all safety-based roadside inspection
violations
Had no impact on safety rating
Used to propose adverse safety fitness
determination based on carriers’ current on-road
safety performance (future)
Violations were not weighted based on
relationship to crash risk
Violations are weighted based on relationship to
crash risk
Assessed carriers only
Measures both carriers and drivers – the Driver
SMS is a tool for investigators to identify drivers
with safety problems during carrier investigations
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
16
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
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
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
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
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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 www.psp.fmcsa.dot.gov
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
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Example of SafeStat vs. SMS
The following slides provide
examples of key differences between
SafeStat and the SMS
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
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Carrier Measurement: SafeStat Results
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
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Carrier Measurement: SMS Results
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
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Carrier Measurement: SMS Results
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
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Violation Details Provided in SMS
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
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Further Drilldown in SMS
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
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Further Drilldown in SMS
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
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Further Drilldown in SMS
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
27
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
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
28
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
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
29
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
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
30
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
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
31
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)
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
32
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
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
33
Safety Management Cycle
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
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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)
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
35
Previous Process vs. CSA Intervention Process
Previous CR Process
CSA Intervention Process
Broad one-size-fits-all investigation
Array of interventions can be tailored to
address extent and scope of specific safety
alerts
Resource intensive for enforcement
agencies and time-consuming for
carrier/fewer carriers contacted
Less resource intensive for enforcement
agencies and less time-consuming for
carrier/more carriers contacted
Focused on broad compliance based on
rigid set of acute/critical violations
Focuses on improving behaviors that are
linked to crash risk
Discovered what violations exist at that
time
Discovers what safety problem(s) are, why
they exist, and how to correct them
Major safety problems resulted in fines
(NOC)
When problems found, major focus on
carrier proving corrective action; significant
problems continue to result in fines
Focused on carrier
Expands focus to driver violations
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
36
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 2011.
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
37
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(§385.17)
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
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CSA Field Test and
National Rollout
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
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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)
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
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, capabilities,
and benefits
– Tests integration with national program goals and
Congressional mandates
– Provides more data to evaluate test, including workload and
workforce analyses
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
41
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
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
42
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)
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
43
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
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
44
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 30th –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
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
45
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
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
46
Summary
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
47
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
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
48
What Can Carriers Do?
• Educate yourselves and your employees:
– Understand the SMS Methodology and the BASICs
– Check the website for information and updates (http://csa.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 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: https://dataqs.fmcsa.dot.gov)
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
49
For more information, please visit:
http://csa.fmcsa.dot.gov
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Industry Briefing, December 2010
FMC-CSA-10-002
50