1. Compliance, Safety, Accountability (CSA) Commercial Carrier Journal Forum Scottsdale, Arizona December 2012

2. Agenda Why this session about CSA is important
The “other” pieces of CSA
Technical discussion of Safety Measurement System (SMS) improvements implemented yesterday
CSA Analysis and Studies
Future Improvements to SMS and Crash Weighting

3. Why this session about CSA is important
Top Industry issues according to 2012 study by American Transportation Research Institute (ATRI)
CSA
Hours-of-Service
Economy
Driver Shortage
Fuel Issues
EOBR mandate
Driver retention
Truck parking
Driver health/wellness
Congestion and Highway Infrastructure (tied)

4. CSA – Three Major Elements
New Safety Measurement System (SMS)
Better targets carriers for Agency interventions
Broader array of interventions
Includes warning letters and focused on and off-site investigations to augment the full investigations
Planned revisions to Safety Fitness Determination (SFD) Regulations
To incorporate on-road performance into SFD methodology

5. CSA – Intervention Tools
Broader array of interventions to augment the Full Compliance Review
Reaches more carriers
Improves efficiency of investigations
Identifies root causes and corrective actions

6. Safety Management Cycle

7. New Safety Fitness Determination (SFD) Regulation and Status
CURRENT
One of three safety ratings issued following a Compliance Review
Satisfactory, Conditional, Unsatisfactory
Rating is snapshot based on date of most recent Compliance Review
NEW SAFETY FITNESS REGULATIONS TO BE PROPOSED WOULD
Incorporate on-road safety performance
Allow for proposed downgrade in formal SFD based on monthly update of measurement system
Continue to include major safety violations found as part of investigations
Notice of Proposed Rulemaking scheduled for 2013

8. SMS Improvements

9. SMS Improvements July 2012 moving forward:
Driver Fitness BASIC – Suspended License violations
Inspectors now collecting more detailed information roadside
Is license suspended for a safety-based reason?
Is the license suspended in the driver’s state of record?
Allows SMS to weigh more heavily safety-based suspensions a motor carrier can identify through MVR checks

10. SMS Improvements March 2012 Federal Register Notice
Announced the first set of improvements
Opened preview website for motor carriers and law enforcement
Opened comment period that was extended to end of July
August 24, 2012 Federal Register
Responded to public comments
Announced improvements implemented yesterday

11. December 2012 SMS Improvements:
Strengthen the Vehicle Maintenance BASIC by incorporating cargo/load securement violations from the Cargo-Related BASIC.
New HM BASIC
More accurately ID carriers that transport significant quantities of HM for more strict intervention thresholds
Better align SMS with Intermodal Equipment Provider (IEP) regulations.
Align violations included in SMS with CVSA inspection levels
More accurately ID carriers that should be subject to lower passenger carrier intervention thresholds
Modify SMS public display to:
Change terminology to fact-based descriptions instead of “insufficient data” and “inconclusive”
Break out crashes with injuries and crashes with fatalities

12. Additional SMS Improvements Implemented in December 2012
Based on careful consideration and stakeholder feedback during preview and comment period
Removal of 1-5 MPH speeding violations
Lowered severity weight for speeding violations with no MPH range above speed limit
Aligning severity weight of paper and electronic logbook violations
Renaming Fatigued Driving (HOS) BASIC to HOS Compliance BASIC

13. December 2012: Move Cargo Securement Violations into Vehicle Maintenance BASIC
Strengthen the Vehicle Maintenance BASIC by incorporating load securement violations from today’s Cargo-Related BASIC
Mitigates bias in the current Cargo-Related BASIC whereby flatbed operators are disproportionately identified for intervention.
Continues to identify motor carriers with systemic cargo securement compliance problems.
Makes Vehicle Maintenance BASIC more effective.
The Vehicle Maintenance BASIC will remain public.

14. December 2012: New HM BASIC
Change the Cargo-Related BASIC to Hazardous Materials (HM) BASIC
Removes load securement violations so that only HM violations remain.
Provides a more objective comparison with respect to HM compliance; consequences of crashes and cargo spills are increased when HM are involved.
Enables enforcement staff to better identify and address HM safety and compliance issues.
Not a public BASIC now

15. December 2012: New HM Intervention Threshold Criteria
More effectively identify carriers involved in transporting HM for stricter intervention thresholds in other BASICs
New Intervention Threshold definition:
At least 2 placardable HM inspections; 1 within past 12 months, and
At least 5% of total inspections indicated as placardable HM inspections.
The HM Intervention Threshold continues to apply to carriers with HM safety permits.
More stringent Intervention Thresholds are applied to all BASICs except the proposed HM BASIC.
New definition will enable FMCSA to focus resources on carriers involved in the majority of placardable HM transport.

16. Four Additional Changes
Removal of 1-5 MPH speeding violations from Unsafe Driving BASIC
Lowered severity weight for speeding violations that do not designate MPH range above the speed limit: Effective December 2012.
Specified MPH Range Above Speed Limit
Violation Severity Weight
Not Specified 1*
after January 1, 2011
1-5
6-10 4
11-14 7
15+ 10

17. Four Additional Changes
3. Alignment of paper and electronic logbook violation weights
All “form and manner” to be weighted 1 (Paper formerly 2)
All “no logbook” to be weighted 5 (Electronic “no logbook” formerly 1)
4. Renaming the Fatigued Driving (HOS) BASIC to the HOS Compliance BASIC
To reflect that BASIC includes HOS recordkeeping violations that do not, by themselves, indicate fatigued driving or driving in excess of HOS limitations

18. Net Impact – Increased effectiveness
Impact of SMS Enhancement Package #1:
Carriers with at least one BASIC Intervention Threshold
Have a 3.9% higher crash rate than those in the previous version of SMS; and
Have a 3.6% higher Hazardous Materials (HM) violation rate than under previous SMS.

19. CSA Analysis

20. CSA Effectiveness - Results
Now, more than ever, safety is everyone’s business.
CSA is doing its job.
In 2011, violations per roadside inspection were down 8%, and driver violations per inspection were down 10%
most dramatic decrease in violation rates in a decade
SMS Online in last 12 months, 40 million users sessions
10X increase from SafeStat
High risk carriers have twice crash rate of national average .

21. SMS Data – Industry Coverage
Category
Approximate Number
Percentage of Uploaded Crashes
Carriers listed as active
750K
100%
Carriers with recent activity
“pulse” in last three years
525K
Carriers with insufficient data
325K 8%
Carriers with sufficient data to be assessed in at least one BASIC
200K
92%
Carriers with sufficient negative information to have a percentile assigned
92K
83%
Carriers with at least one BASIC above FMCSA intervention threshold
50K
45%

22. FMCSA Effectiveness Testing
Objective
Quantify how effectively the SMS identifies high-risk motor carriers
Methodology
Use historical data to examine the future crash rate of motor carriers

23. FMCSA Testing – HOS Compliance BASIC
Strong relationship between HOS Compliance BASIC and future crash risk
UMTRI CSA Evaluation and Recent ATRI paper show similar findings

24. FMCSA Testing – Unsafe Driving BASIC
Strong relationship between Unsafe Driving BASIC and future crash risk
UMTRI CSA Evaluation and Recent ATRI paper show similar findings

25. FMCSA Testing – Vehicle Maintenance BASIC
Strong relationship between Vehicle Maintenance BASIC and future crash risk
UMTRI CSA Evaluation and Recent ATRI paper show similar findings

26. FMCSA Testing – Driver Fitness
Negative relationship between Driver Fitness BASIC and future crash risk
UMTRI CSA Evaluation and Recent ATRI paper show similar findings
Three quarters of carriers above Driver Fitness, exceed threshold in another BASIC

27. FMSCA Testing – Driver Fitness
Why does this negative relationship exist?
One significant area is lack of specificity in certain violations.
1) Most common violation in Driver Fitness: missing medical card.
The driver may have misplaced the card: Not safety-related.
The driver may have an expired medical card: Potentially safety-related.
The driver may be medically unqualified: Strongly safety-related.
2) “Operating while suspended“ violations do not specify reason. Recent ASPEN improvements provide for more precise severity weights for suspensions.
The inability to distinguish between these cases significantly clouds the relationship with future crashes.

28. Overall FMSCA Testing– Results
Strongest relationships with future crash risk exist for Unsafe Driving, Hours-of-Service, and Vehicle Maintenance BASICs and Crash Indicator
Other BASICs show a weaker relationship to crash risk
FMCSA optimizes resources and oversight responsibilities through more stringent Intervention Thresholds for BASICs with strongest associations to crash risk
Crash rates of Carriers above and below BASIC thresholds
BASIC
Above Threshold :
Crashes per 100 PU
Below Threshold:
Increase in Crash Rate
Unsafe Driving
7.10
3.90
82%
Hours of Service Compliance
6.97
4.00
74%
Driver Fitness
2.85
4.43
-36%
Controlled Substance / Alcohol
2.81
5.25
-47%
Vehicle Maintenance
5.79
3.87
50%
HM Compliance
5.27
4.04
31%
Crash
6.59
3.58
84%
1+ BASIC (any BASIC)
5.05
3.05
66%

29. Future Improvements to SMS and Crash Weighting

30. Future Improvements to SMS
What kind of changes to SMS are being considered for the next round of proposed improvements?
Comprehensive modifications to roadside violation severity weights which consider MCSAC input
Recalibration of the Utilization Factor used to incorporate VMT for the Crash and Unsafe Driving BASICs
Adjustment to safety event groupings in all BASICs

31. Crash Weighting
FMCSA receives over 100K crash reports each year from States with no indicator of carrier role in the crash
FMCSA uses crash involvement data in SMS to prioritize resources but does not display crash score to public – strong relationship to future crashes
FMCSA continues to consider carrier role in formal safety ratings
FMCSA is conducting a crash weighting research study to be completed in Summer 2013

32. Crash Weighting Research Objectives
Are police accident reports (PARs) sufficient?
Will a crash weighting determination process offer an even stronger predictor of crash risk than crash involvement and how will crash weighting be implemented into SMS?
How would the Agency manage the process for making crash weight determinations

33. Questions? bryan.price@dot.gov