# Presentation: 602264

## CSA 2010 Update: Congress, NTSB, GAO, and OIG

**February 23, 2009**

- Federal Motor Carrier Safety Administration

## Today’s Presentation

- The challenge
- CSA 2010: Meeting the challenge
- CSA 2010: Design & Status
- Preliminary test results
- National implementation
- Summary & Discussion

## 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
- Compliance Review Process
- Safety Ratings tied to Compliance Review

## FMCSA’s Challenge:  CMV-Related Fatalities

**Fatalities per 100 Million Vehicle Miles Traveled**

**Notes:**
A graph showing number of fatalities per 100 million vehicle miles traveled by year.  The years shown are 1975 through 2007.  The graph shows a gradual reduction in the fatality rate with a leveling off in the last few years.  The graph also points to motor carrier programs that came into place during a particular year.  These are:  the roadside inspection program in 1984; CR/Safety Rating in 1986; and PRISM SafeStat On-Line in 1999.

## CSA 2010:  Meeting the Challenge

- CSA 2010 is pro-active in improving FMCSA’s enforcement efficiencies and protecting lives:
- Extending our reach to more carriers and drivers
- Improving our ability to identify safety problems earlier

## CSA 2010:  Extending our Reach

**Notes:**
An image of a bell curve showing that the current process, which is resource intensive, addresses entities that are the worst of the worst, at the “bad” end of bell curve. The “good” entities are depicted at the other end of the bell curve.  This leaves “everyone else”, the middle-of-the-road  entities, in the center of the bell curve.  These  middle-of-the-road entities will now be influenced by CSA 2010.  The majority of the crashes occur in this middle section of the curve.

## CSA 2010 Design

- New Safety Measurement System (SMS)
- Comprehensive Intervention Process
- Safety Fitness Determination

## 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
- Weights time and severity of violations based on relationship to crash risk
- Calculates safety performance in 7 Behavior Analysis and Safety Improvement Categories (BASICs)

## Behavior Analysis & Safety Improvement Categories (BASICs)

- Measure carrier and driver performance by BASICs:
- Unsafe Driving
- Fatigued Driving
- Driver Fitness
- Controlled Substances/Alcohol
- Vehicle Maintenance
- Improper Loading/Cargo
- 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 |

**Notes:**
A table with 2 columns and 6 rows that compares today’s Measurement System with the CSA 2010 Safety Measurement System.

## CSA 2010: New Intervention Toolbox

- CSA 2010’s Comprehensive Intervention Process provides more tools to reach more carriers and compel safety compliance before crashes occur
- Warning Letters
- Investigations
- On-site comprehensive investigations (enhanced compliance review)
- On-site focused investigations
- Off-site investigations
- Follow-on corrective actions
- Out-of-Service (OOS) orders
- Notice of Violation
- Notice of Claim
- Cooperative Safety Plan

## 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 |

**Notes:**
A table with 2 columns and 8 rows that compares today’s intervention with CSA 2010’s Intervention Toolbox.

## 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 |

**Notes:**
A table with 2 columns and 6 rows that compares Today’s Safety Fitness Rating with the Safety Fitness Determination.

## 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

**Notes:**
Image of a United States map highlighting in a bright blue color, the current Op-Model test states, Colorado, Georgia, Missouri, and New Jersey.  Highlighted in dark blue are the new states, Minnesota, Montana, and Oregon, that will be added to the Op-Model test.

## 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 |

**Notes:**
Table with 3 columns and 6 rows that shows summary information for the Op-Model test’s Test and Control Groups.  Data includes, the number of carriers in each population, the carriers contacted, the percentage of each group’s population that was contacted, the number of warning letters sent to each group and the number of roadside inspections conducted on carriers within each group.

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

**Notes:**
Table with 3 columns and 6 rows that shows summary information on the number of completed investigations for the test and control groups within the Op-Model test.  In addition to a total, investigations completed are broken down by Offsite, Onsite Focused, and Onsite Comprehensive.

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

**Notes:**
A table with 3 columns 7 rows shows a breakdown of completed post-investigation corrective actions by test and control groups.  These corrective actions are shown by type: Cooperative Safety Plans, Notice of Violation, and Notice of Claim.  Corrective actions as a percentage of completed investigations is also shown.

## Preliminary Field Test OutcomesEffectiveness 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**

**Carriers subject to the CSA 2010 process are showing improvements in their safety performance:**

**Notes:**
This slide highlights through data, that carriers subject to the CSA 2010 process are showing improvements in their safety performance. The data shows the performance of test group carriers deficient in the Unsafe Driving BASIC after being intervened upon in February or March 2008.

There are two tables, both with 4 columns and 4 rows. 

The first table highlights Hazmat Carriers and shows the number of carriers deficient in the Unsafe Driving BASIC, the total number of carriers with interventions in February or March 2008, and the percent .

The second table highlights Hazmat Carriers and shows the number of carriers deficient in the Unsafe Driving BASIC, the total number of carriers with interventions in February or March 2008, and the percent.

## Preliminary Field Test OutcomesEffectiveness 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**

**Carriers subject to the CSA 2010 process are showing improvements in their safety performance:**

**Notes:**
This slide highlights through data, that carriers subject to the CSA 2010 process are showing improvements in their safety performance.  The data shows the performance of test group carriers deficient in the Fatigued Driving BASIC after being intervened upon in February or March 2008.

There are two tables, both with 4 columns and 4 rows. 

The first table highlights Hazmat Carriers and shows the number of carriers deficient in the Fatigued Driving BASIC, the total number of carriers with interventions in February or March 2008, and the percent .

The second table highlights Hazmat Carriers and shows the number of carriers deficient in the Fatigued Driving BASIC, the total number of carriers with interventions in February or March 2008, and the percent.

## Preliminary Field Test OutcomesEffectiveness of Interventions on Vehicle Maintenance BASIC

| Hazmat Carriers | Feb - Apr | May - Aug | Sep - Nov |
| --- | --- | --- | --- |
| No. Carriers Deficient in Vehicle Maintenance  BASIC | 24 | 22 | 17 |
| Total Carriers with intervention in Feb-Mar | 24 | 24 | 24 |
| Percent | 100.0 | 91.7 | 70.8 |
|  |  |  |  |
| General Carriers | Feb - Apr | May - Aug | Sep - Nov |
| No. Carriers Deficient in Vehicle Maintenance  BASIC | 196 | 160 | 132 |
| Total Carriers with intervention in Feb-Mar | 202 | 200 | 200 |
| Percent | 97.0 | 80.0 | 66.0 |

**Performance of Test Group Carriers Deficient in Vehicle Maintenance BASIC After Being Intervened Upon in Feb-Mar ‘08**

**Carriers subject to the CSA 2010 process are showing improvements in their safety performance:**

**Notes:**
This slide highlights through data, that carriers subject to the CSA 2010 process are showing improvements in their safety performance.  The data shows the performance of test group carriers deficient in the Vehicle Maintenance BASIC after being intervened upon in February or March 2008.

There are two tables, both with 4 columns and 4 rows. 

The first table highlights Hazmat Carriers and shows the number of carriers deficient in the Vehicle Maintenance BASIC, the total number of carriers with interventions in February or March 2008, and the percent .

The second table highlights Hazmat Carriers and shows the number of carriers deficient in the Vehicle Maintenance BASIC, the total number of carriers with interventions in February or March 2008, and the percent.

## 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:**

**Notes:**
A chart showing the percent improvement in relative safety performance of carriers exceeding a Phase 1 BASIC for both the Test and Control Groups.  Two data points are shown February through April 2008 and September through November 2008.  21% of test carriers compared to 7% of control carrier are no longer deficient in the later time period.

## 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

## Field Test:  State Perspective 

- CSA 2010 enhances more than just investigations in the state (MCSAP)
- Increases emphasis on roadside data uniformity and accuracy
- Promotes strategic alignment of two primary traffic safety improvement initiatives
- Raises the bar for all traffic
- 	safety improvement initiatives
- Impact on job
- Safety professionals
- Reactions from employees

## National Implementation Elements CSA 2010

**Core Elements**
- Replace SafeStat with SMS
- Send warning letters nationwide
- Rollout Interventions Toolbox
- Inspect carriers with deficient BASICs

**Enabling Elements**
- Information Technology
- Outreach and Communication
- Training
- Workforce Analysis

## 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

## CSA 2010: Achieving the Mission, Enhancing the Nation’s Safety

- The purpose of CSA 2010 is to achieve a greater reduction in the number of large truck and bus related crashes and fatalities...
- We anticipate that it will achieve this goal.

## CSA 2010:  Meeting the Challenge

**Thank You**
**Discussion and Questions**