# Presentation: 521615

## Comprehensive Safety AnalysisCSA 2010 

- Commercial Vehicle Safety Alliance
- Pittsburgh, PA
- September 18, 2007

## What is CSA 2010?
Why CSA 2010?
CSA 2010 Description
Potential Benefits
Current Status/Operational Model Test
Outreach

- What is CSA 2010?
- Why CSA 2010?
- CSA 2010 Description
- Potential Benefits
- Current Status/Operational Model Test
- Outreach

## High priority FMCSA safety initiative -
Budget
Strategic planning
Entire Agency
To increase efficiency & effectiveness – compliance/enforcement
Ultimate Goal:  Achieve greater reduction in large truck and bus fatalities.

- High priority FMCSA safety initiative -
- Budget
- Strategic planning
- Entire Agency
- To increase efficiency & effectiveness – compliance/enforcement
- _Ultimate Goal:_  Achieve greater reduction in large truck and bus fatalities.

## Why CSA 2010?

## The Safety Problem

## CSA 2010 Description

- Current Operational Model Limitations
- Safety fitness determination tied to compliance review.
- Very labor intensive.
- _Result_:  We assess only small fraction of industry.
- Focus is on carriers.

## CSA 2010 Description

- CSA 2010 Operational Model ---
- Target unsafe behavior.
- Safety fitness tied to data; _not_ CR or acute/critical violations.
- Broad array of _progressive_ interventions.
- Focus is on carriers _and_ drivers.
- Leverage new technology, training, and information.

## Four major elements ---
Measurement
Interventions
Safety Fitness Determination
COMPASS

- Four major elements ---
- Measurement
- Interventions
- Safety Fitness Determination
- COMPASS

## Today’s Model - SafeStat
Four Safety Evaluation Areas (SEAs)
Only roadside out-of-service & moving violations
SafeStat – results support prioritization of compliance reviews
No risk-based violation weightings
Carriers

- _Today’s Model - SafeStat_
- Four Safety Evaluation Areas (SEAs)
- Only roadside out-of-service & moving violations
- SafeStat – results support prioritization of compliance reviews
- No risk-based violation weightings
- Carriers

- _CSA 2010_
- Seven Safety Behavioral Areas (BASICs)
- All roadside safety violations
- Results determine ---
- When to intervene
- When proposed notice of Unfit
- Risk-based violation weightings
- Carriers _and_ Drivers

## Behavioral Analysis & Safety Improvement Categories

**BASICs** for Carriers and Drivers
- _Behaviors That Lead To Crashes_
- Unsafe Driving
- Fatigued Driving
- Driver Fitness
- Drugs and Alcohol
- Vehicle Maintenance
- Cargo Securement
- Crash Experience

## Each BASIC –
Weighted for time/crash-risk
Normalized for exposure
Peer grouped
Data sufficiency tested
Updated every 30 days

- Weighted for time/crash-risk
- Normalized for exposure
- Peer grouped
- Data sufficiency tested
- Updated every 30 days

- CSA 2010 Measurement

**Notes:**
Design approach is similar to that of SafeStat.
New safety events are more relevant than older ones.
Peer grouping compares carriers or drivers with similar levels of exposure.
Only rank carriers or drivers with enough data to have a plausible measure.
Rank percentile provides relative assessment of safety performance.

## CSA 2010 Measurement

- Status ---
- Two Separate Measurement Systems – Prototype Stage
- Carriers and Drivers
- Potential to add others
- Measurement System Purpose ---
- To identify specific safety problems.
- To measure & monitor safety behavior.
- To “trigger” the intervention process & “unfit.”
- To provide stakeholders important safety information.

## Good data critical to CSA 2010 success
FMCSA has major quality assurance function
CSA 2010-related data initiatives ---
Commercial driver conviction data to better support the BASICs
Driver positive drug test results – rulemaking to commence
Increase the number of post-crash inspections
Better specify Part 392.2 violations; not generic
Capture driver-related factors in all large truck and bus police accident reports

- Good data critical to CSA 2010 success
- FMCSA has major quality assurance function
- CSA 2010-related data initiatives ---
- Commercial driver conviction data to better support the BASICs
- Driver positive drug test results – rulemaking to commence
- Increase the number of post-crash inspections
- Better specify Part 392.2 violations; not generic
- Capture driver-related factors in all large truck and bus police accident reports

## Today’s Model
Limited to compliance review (CR); one size fits all
CR is resource intense
CR assesses compliance through rigid set of acute/critical regulations
Generally, audit approach 
CR used to determine whether enforcement is needed

- _Today’s Model_
- Limited to compliance review (CR); one size fits all
- CR is resource intense
- CR assesses compliance through rigid set of acute/critical regulations
- Generally, audit approach
- CR used to determine whether enforcement is needed

- _CSA 2010_
- Broad array of _progressive _interventions
- More interventions; many less resource intense
- Interventions target unsafe behavior through weighted BASICs
- Investigative approach; root cause and educational element
- _Goal_:  Change unsafe behavior early, and enforcement

## CSA 2010 Interventions - Carrier 

- 	_Tier 1 – Informative_
- Warning Letter
- Focused Roadside Inspection
- 	_Tier 2 – Interactive_
- Off-Site Investigation
- Cooperative Safety Plan
- Notice of Violation
- Focused On-Site Investigation
- Comprehensive On-Site Investigation
- 	_Tier 3 – Prescriptive_
- Notice of Claim
- Consent Agreement
- Unfit Suspension
- (Safety Fitness Determination)

**Increasing Severity**

## CSA 2010 Interventions - Carrier

- Intervention process triggered by:
- One or more deficient BASICs,
- High crash indicator, or
- Complaint or fatal crash.
- Intervention selection influenced by:
- Safety performance,
- HM or passenger carrier, and
- Intervention history.

## CSA 2010 Interventions - Carrier

- Status ---
- Carrier interventions developed
- Operational definitions being developed
- Intervention selection algorithm being finalized

## Today’s Model
SFD tied to compliance review
Satisfactory, Conditional, or Unsatisfactory
SFD effective until next CR
SFD based on acute/critical violations

- _Today’s Model_
- SFD tied to compliance review
- Satisfactory, Conditional, or Unsatisfactory
- SFD effective until next CR
- SFD based on acute/critical violations

- _CSA 2010_
- SFD tied to performance data; not necessarily CR
- Continue Operation, Marginal, or Unfit
- SFD assigned to all carriers with sufficient data; updated regularly
- SFD based on performance data

## CSA 2010 Safety Fitness Determination - Carrier

- Status ---
- Major rulemaking
- Revise Part 385, Safety Fitness Procedures
- NPRM publication - Targeting spring/summer 2008

## COMPASS is FMCSA IT modernization initiative
COMPASS will support CSA 2010
COMPASS & CSA 2010 coordinating closely
COMPASS briefing today – Associate Administrator Terry Shelton

- COMPASS is FMCSA IT modernization initiative
- COMPASS will support CSA 2010
- COMPASS & CSA 2010 coordinating closely
- COMPASS briefing today – Associate Administrator Terry Shelton

**CSA 2010 Proposed Operational Model**

## Potential Benefits – CSA 2010

- Maximize effectiveness of resources.
- Correct unsafe behavior early.
- Assess larger segment of industry.
- _Achieve Goal_:  Greater reduction in large truck and bus related fatalities.

## Purpose ---
Test CSA 2010 in field environment
Validate measurement systems
Validate intervention process
Validate safety fitness determination (no regulatory relief)
Determine safety effectiveness 

- Purpose ---
- Test CSA 2010 in field environment
- Validate measurement systems
- Validate intervention process
- Validate safety fitness determination (no regulatory relief)
- Determine safety effectiveness

## When ---
January 2008 to June 2010 --- 30 months
Phase I – Startup Jan-08
Phase II – Fully Operational Jun-08
Report-out results throughout

- When ---
- January 2008 to June 2010 --- 30 months
- Phase I – Startup Jan-08
- Phase II – Fully Operational Jun-08
- Report-out results throughout

## Where ---
Approximately 40 investigators state and federal
Four states – one in each FMCSA Service Center
Colorado
Georgia
Missouri
New Jersey
Outreach --- September/October

- Where ---
- Approximately 40 investigators state and federal
- Four states – one in each FMCSA Service Center
- Colorado
- Georgia
- Missouri
- New Jersey
- Outreach --- September/October

## Which Carriers ---
Domiciled in one of the four test states
Exclusions
Carriers with compliance review in past 18 months
Chameleon carriers
SafeStat Category A/B carriers

- Which Carriers ---
- Domiciled in one of the four test states
- Exclusions
- Carriers with compliance review in past 18 months
- Chameleon carriers
- SafeStat Category A/B carriers

## How ---
Remaining carriers randomly split into two groups
Test group will receive CSA 2010 interventions
Control group will be subject to current process
For comparison purposes
FMCSA will be providing no regulatory relief
Being in test group does not preclude enforcement
Test group carriers with poor performance and unresponsive to CSA 2010 interventions --- 
Will undergo today’s CR, and appropriate compliance and enforcement

- How ---
- Remaining carriers randomly split into two groups
- Test group will receive CSA 2010 interventions
- Control group will be subject to current process
- For comparison purposes
- FMCSA will be providing _no_ regulatory relief
- Being in test group does not preclude enforcement
- Test group carriers with poor performance and unresponsive to CSA 2010 interventions ---
- Will undergo today’s CR, and appropriate compliance and enforcement

## CSA 2010 Status & Target Dates

- Will complete developmental work by Dec-07.
- Now entering test phase.
- Deploy carriers by 2010.  Drivers in reauthorization.

- 2006

- 2005

- 2008

- 2007

- 2010

- 2009

- Concept

- Development

- Test & Validate

- Deploy

- Add States

- Reauthorization

- CSA 2010 Team

## Six Listening Sessions --- Sept/Oct-04 
Listening Session – Nov-06
Washington, DC
Ninety-two persons
Four breakout sessions – 611 responses
Next Listening Session Targeting ---
Early Nov-07
St. Louis, MO
Federal Register notice
Three topics
Demonstrate Measurement Systems
Further describe Operational Model Test
Safety Fitness Determination Methodology 

- Six Listening Sessions --- Sept/Oct-04
- Listening Session – Nov-06
- Washington, DC
- Ninety-two persons
- Four breakout sessions – 611 responses
- Next Listening Session Targeting ---
- Early Nov-07
- St. Louis, MO
- Federal Register notice
- Three topics
- Demonstrate Measurement Systems
- Further describe Operational Model Test
- Safety Fitness Determination Methodology

## CSA 2010

- Commercial Vehicle Safety Alliance
- September 18, 2007
- Thank You
- Questions or Comments