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

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 Crashes 1.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 SystemCSA 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 onlyAssesses carriers and drivers Uses only OOS and acute/critical violationsUses 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 Increasing Severity

CSA 2010 Proposed Operational Model

Benefits of CSA 2010’s Intervention Toolbox Today’s ModelCSA 2010 Interventions One tool; one-size-fits-allSet of tools to use based on carriers’ safety problems Broad examination of carrier; audit approachInvestigator 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 intensiveLess resource intensive One size fits all approach regardless of level of safety deficiency New approach to investigating and contacting carriers Less carriers contactedMore 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 RatingSFD 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 3 rd 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 InformationTest GroupControl Group Number of Carriers in Population34,16834,546 Carriers Contacted2, Percentage of Population Contacted8.4%2.1% Warning Letters Sent2, Roadside Inspections101,498106,513

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

Preliminary Field Test Outcomes Effectiveness of Interventions on Unsafe BASIC Hazmat Carriers Feb - AprMay - AugSep - Nov No. Carriers Deficient in Unsafe Driving BASIC Total Carriers Intervened Upon in Feb-Mar 13 Percent General Carriers Feb - AprMay - AugSep - Nov No. Carriers Deficient in Unsafe Driving BASIC Total Carriers with intervention in Feb-Mar 25 Percent Performance of Test Group Carriers Deficient in Unsafe Driving BASIC After Being Intervened Upon in Feb-Mar ‘08

Preliminary Field Test Outcomes Effectiveness of Interventions on Fatigue BASIC Hazmat Carriers Feb - AprMay - AugSep - Nov No. Carriers Deficient in Fatigued Driving BASIC 985 Total Carriers with intervention in Feb-Mar 1099 Percent General Carriers Feb - AprMay - AugSep - Nov No. Carriers Deficient in Fatigued Driving BASIC Total Carriers with intervention in Feb-Mar 178 Percent 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 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