CSA 2010 Update:

FMCSA’s Challenge: Industry Volume

• Significantly more carriers than federal/state investigators– FMCSA regulates ~725,000 interstate and foreign-

based truck and bus companies

• Compliance Review (CR) is effective, but it is labor intensive– Only able to reach < 2% (~12,000) of total carrier

population annually

FMCSA’s Existing Model

• SafeStat (over 53% of audits due to Safestat)

• Compliance Review Process

• Safety Ratings tied exclusively to Compliance

Review

• Focus is on the motor carrier

FMCSA’s Challenge: CMV-Related Fatalities

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CR/ Safety Rating (1986) PRISM SafeStat

On-line (1999)

CSA 2010 Description

• CSA 2010 Operational Model ---– Target unsafe behavior.– Safety fitness tied to data; not CR or only

acute/critical violations.– Broad array of progressive interventions.– Focus is on carriers and drivers. – Leverage new technology, training, and

information.

CSA 2010: Meeting the Challenge

CSA 2010 is pro-active in improving FMCSA’s enforcement efficiencies and protecting lives:

– Extending their reach to more carriers and drivers

– Improving their ability to identify safety problems earlier

Target The Masses

• Studies have shown that when you look at a group of workers that they can broken down for the most part into three groups:

• 20% are self-starters/leaders. These people are already doing things the right way.

• 74% are followers. These people can go either way depending on the person leading.

• 6% are malcontents/non-conformers. These people will challenge authority.

• The key to your safety training success is to target the masses (the 74%). A small percentage change in this target group will have a huge impact on your program’s performance.

CSA 2010: Extending our Reach

CSA 2010 Safety Measurement System (SMS)

• Performance-based for determining motor carrier and driver safety

• Measures safety performance using all roadside inspection safety-based violations– This means not just out of service violations –

but ALL violations listed

• Weights time and severity of violations based on relationship to crash risk

• Calculates safety performance in 7 Behavior Analysis and Safety Improvement Categories (BASICs)

Behavioral Analysis & Safety Improvement Categories

BASICs for Carriers and Drivers

Behaviors That Lead To Crashes1. Unsafe Driving

2. Fatigued Driving

3. Driver Fitness

4. Controlled Substances and Alcohol

5. Vehicle Maintenance

6. Improper Loading/Cargo

7. Crash Indicator

Benefits of CSA 2010’s SMS

Today’s Measurement System CSA 2010 SMS

Organized by broad Safety Evaluation Areas (SEA)

Organized by specific Behavior Analysis Safety Improvement Categories

Identifies carrier for one-size-fits-all compliance review (CR) regardless of area to be improved

Identifies carriers for different level investigations based on specific safety issues

Weighs all Out-of-Service (OOS) and acute/critical violations equally

Uses risk-based weightings to incorporate link to crash causation

Assesses carriers only Assesses carriers and drivers

Uses only OOS and acute/critical violations Uses all roadside data

CSA 2010 Interventions - Carrier

•Warning Letter

•Targeted Roadside Inspection

•Off-Site Investigation

•On-Site Investigation - Focused

•Cooperative Safety Plan

•Notice of Violation

•On-Site Investigation - Comprehensive

•Notice of Claim

•Settlement Agreement

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CSA 2010 Proposed Operational Model

Benefits of CSA 2010’s Intervention Toolbox

Today’s Model CSA 2010 Interventions

One tool; one-size-fits-all Set of tools to use based on carriers’ safety problems

Broad examination of carrier; audit approach

Investigator can focus on carrier’s specific safety problems

Focuses on broad compliance based on rigid set of acute/critical violations

Focuses on improving behaviors that are linked to crash causation

Very resource intensive Less resource intensive

One size fits all approach regardless of level of safety deficiency

New approach to investigating and contacting carriers

Less carriers contacted More carriers contacted

Discover what safety problem is and issue a fine

Discover why carrier has a safety problem

Benefits of CSA 2010’s Safety Fitness Determination

Today’s Safety Fitness Rating SFD

Based on only critical/acute and vehicle out-of-service violations (OOS)

Uses violations of all safety based regulations

Adverse rating generally only issued with multiple deficiencies

Adverse rating can be issued based on 1 deficient area (stand alone BASICs and fundamental violations)

Only uses vehicle OOS violations found during roadside and acute/critical violations found during compliance review

Uses all violations found on the roadside and violations found during investigations

Issues 3 labels: Unsatisfactory, Conditional, Satisfactory

Issues 3 labels: Unfit, Marginal, Continue to Operate. Gets away from “seal of approval”

Updated only with a compliance review conducted

Updated monthly

CSA 2010 and Compliance Reviews

Question: Does CSA 2010 replace the compliance review, which is effective, with less intensive interventions?

Answer: No.

Under CSA 2010, FMCSA is not replacing the compliance review with less intensive alternatives where the onsite comprehensive review is needed to change unsafe behavior.

Instead, FMCSA is augmenting the CR with other interventions (warning letter, off-site and targeted on-site reviews) to address safety problems early before the carrier is considered a high crash-risk.

CSA 2010 and Enforcement

Question: Is CSA 2010 “light” on enforcement?

Answer: No. Under CSA 2010 FMCSA will still issue Unfit

Determinations, Notices of Claim, and Notices of Violation.

Once the SFD rule is in place, FMCSA can deem a carrier “Unfit” by on-road performance data alone.

It is anticipated that this rule will result in more carriers (5x as many) being placed out-of-service (OOS).

CSA 2010 Status

• Operational Model Design - Completed January 2008

• Operational Model Field Test – Began February 2008; Completion Planned June 2010– Test the validity, efficiency and effectiveness

of CSA 2010– Independent 3rd party evaluation conducted

by University of Michigan’s Transportation Research Institute

– Federal and State Work Group (FSWG)

• CSA 2010 National Implementation – Roll-out being planned for July through December 2010

CSA 2010 Field Test Design

• 30-month field test in 4 States: Colorado, Georgia, Missouri, New Jersey

• Randomly divided into control (34,421) and test (34,033) groups ~ 50%/50%

• Phased implementation of field test:– Phase I Startup: Feb-08 to Sept-08

• 3 BASICS; emphasized off-site investigations; no A/B (high risk) carriers

– Phase II: Oct-08 to Jun-10• Fully operational – all BASICs, all interventions, and

issuing safety ratings

Next Steps in Field Test

• Additional states– May 2009: Minnesota, Montana, Oregon

• 100% of the State participates in CSA 2010– 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

Preliminary Field Test Output Phase I & II: Feb ‘08 – Jan’09

Summary Information Test Group Control Group

Number of Carriers in Population 34,168 34,546

Carriers Contacted 2,876 731

Percentage of Population Contacted 8.4% 2.1%

Warning Letters Sent 2,464 441

Roadside Inspections 101,498 106,513

Preliminary Field Test Output Phase II: Oct ‘08 – Jan ‘09

Investigation Type

Test Group

Control Group

Offsite 106 N/ AOnsite Focused 131 N/ AOnsite Comprehensive 40 160Total Completed 277 160

Completed Investigations

Preliminary Field Test OutputPhase II: Oct ‘08 – Jan ‘09

Post-Investigation Corrective Actions Type Test Group Control GroupCooperative Safety Plans (CSP) 106 N/ ANotices of Violation (NOV) 3 N/ ANotices of Claim (NOC) 25 35Total Follow-on Corrective Actions 134 35Corrective Actions As Percentage of Completed Investigations 48.40% 21.90%

Completed Post-Investigation Corrective Actions

Preliminary Field Test OutcomesEffectiveness of Interventions on Unsafe BASIC

Hazmat Carriers Feb - Apr May - Aug Sep - Nov

No. Carriers Deficient in Unsafe Driving BASIC

13 12 11

Total Carriers Intervened Upon in Feb-Mar

13 13 13

Percent 100.0 92.3 84.6

General Carriers Feb - Apr May - Aug Sep - Nov

No. Carriers Deficient in Unsafe Driving BASIC

22 17 11

Total Carriers with intervention in Feb-Mar

25 25 25

Percent 88.0 68.0 44.0

Performance of Test Group Carriers Deficient in Unsafe Driving BASIC After Being Intervened

Upon in Feb-Mar ‘08

Preliminary Field Test OutcomesEffectiveness of Interventions on Fatigue BASIC

Hazmat Carriers Feb - Apr May - Aug Sep - Nov

No. Carriers Deficient in Fatigued Driving BASIC

9 8 5

Total Carriers with intervention in Feb-Mar

10 9 9

Percent 90.0 88.9 55.6

General Carriers Feb - Apr May - Aug Sep - Nov

No. Carriers Deficient in Fatigued Driving BASIC

167 128 99

Total Carriers with intervention in Feb-Mar

178 178 178

Percent 93.8 71.9 55.6

Performance of Test Group Carriers Deficient in Fatigued Driving BASIC After Being Intervened

Upon in Feb-Mar ‘08

Preliminary Field Test Outcomes Program Effectiveness: Control vs. Test

Improvement in Relative Safety Performance of Carriers Exceeding a Phase 1 BASIC

75%

80%

85%

90%

95%

100%

Feb. - April Sept. - Nov

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Control Test (CSA 2010)

21% Of Test Carriers Compared to 7% of Control Carriers No Longer Deficient.

Preliminary evaluation results indicate that the CSA 2010 process is better at identifying and correcting behaviors leading to crashes:

Field Test: Warning Letter Feedback

FMCSA has received positive results from test group motor carriers.

• ~ 50 percent of carriers have logged onto website to view their performance data

• Received written feedback – Appreciative of notification of safety deficiencies– Advised FMCSA of their implemented corrective

actions

Meeting the Challenge: Summary

• New Safety Measurement System– More comprehensive– Better able to pinpoint specific violations– Better identifies high crash-risk behavior

• New Interventions Toolbox– More efficient/effective enforcement process– Wider range of interventions to compel compliance earlier– Match intervention with level of safety performance

• New Safety Fitness Determination rulemaking – Assess safety performance of larger segment of industry– Based on roadside performance, fundamental violations,

and intervention results