MOTOR CARRIERS

Establishing System 

for Self-Reporting 

Equipment Problems 

Appears Feasible, but 

Safety Benefits 

Questionable and 

Costs Unknown

Report to Congressional Committees

December 2016

United States Government Accountability Office

GAO-17-132
United States Government Accountability Office

Highlights of GAO-17-132, a report to 

congressional committees

December 2016

MOTOR CARRIERS

Establishing System for Self-Reporting Equipment 

Problems Appears Feasible, but Safety Benefits 

Questionable and Costs Unknown 

What GAO Found

Establishing a system that would provide incentives for trucking companies to 

self-report equipment problems may not necessarily yield safety benefits. Most 

stakeholders GAO interviewed—including selected carriers and drivers—thought 

a self-reporting system would be unlikely to produce safety benefits, stating that 

it would not incentivize quicker repairs. If repairs are not made more quickly, 

there would be no positive impact on safety. Three drivers, however, thought a 

self-reporting system could yield some safety benefits if it incentivized drivers to 

do more thorough inspections of their vehicles. Officials from industry groups and 

the Federal Motor Carrier Safety Administration (FMCSA) noted that a selfreporting system could negatively impact safety, such as by encouraging 

distracted driving if drivers report equipment problems on their cell phones while 

driving. Moreover, estimating the potential safety impacts of such a system 

requires information that is not currently available, such as how equipment 

problems that would be permitted to be self-reported are related to crashes.

Example of a Driver Receiving a Violation for a Previously Identified Equipment Problem

under Current System and under a Self-Reporting One

FMCSA has the statutory and regulatory authority to establish a system for selfreporting equipment problems, and technology exists to create it, but its costs 

are unknown. Also, establishing such a system could pose challenges for 

FMCSA, carriers, and drivers. For example, developing a new system could 

delay efforts FMCSA has under way to improve its information technology, and 

carriers or drivers may have difficulty selecting their specific equipment problem 

from the more than 300 potential vehicle maintenance violations. Further, without 

information on key design features of a self-reporting system, such as whether 

reporting would be through a telephone hotline or a web-application, it is not 

possible to estimate costs with any reasonable degree of confidence. FMCSA 

developed a rough estimate that a self-reporting system would cost between $5 

and $10 million to establish and operate for the first year. View GAO-17-132. For more information, 

contact Susan Fleming at (202) 512-2834 or 

flemings@gao.gov. 

Why GAO Did This Study

In 2015, more than 4,000 people were 

killed in crashes involving large trucks. 

To identify carriers with the highest 

crash risk, FMCSA uses information 

from roadside inspections and crashes 

to rank each carrier’s safety 

performance relative to other carriers 

in seven categories, including one on

vehicle maintenance. Some

stakeholders have proposed a system 

for carriers or their drivers to self-report

en route vehicle equipment problems 

to FMCSA. Reported equipment 

problems that were repaired within a 

certain time period would not affect the 

carrier’s relative ranking, potentially 

incentivizing carriers to make repairs 

more quickly.

The Fixing America’s Surface 

Transportation Act included a provision 

for GAO to examine the cost and 

feasibility of establishing a system for 

carriers or drivers to self-report vehicle 

equipment problems to FMCSA. This 

report examines (1) the potential safety 

impacts of a self-reporting system and 

(2) factors that could affect its

feasibility and cost. 

GAO reviewed relevant regulations, 

information on other existing DOT selfreporting systems, and prior related 

GAO work. GAO also interviewed a 

non-generalizable sample of 

representatives from six industry and 

safety associations, six carriers, and 

six drivers about this potential system 

for self-reporting equipment problems.

GAO selected carriers to include those 

with diverse fleet sizes and average 

distances traveled, and drivers from six 

additional carriers. 

DOT provided technical comments, 

which were incorporated as 

appropriate.
Page i GAO-17-132 Motor Carrier Self-Reporting System

Letter 1

Background 5

While Potential Safety Impact of a Self-Reporting System Is 

Difficult to Determine, FMCSA and Selected Stakeholders 

Suggested Safety Benefits Are Unlikely 9

FMCSA Has the Statutory and Regulatory Capability to Establish 

a Self-Reporting System, but FMCSA and System Users May 

Face Challenges, and Costs are Unknown 14

Agency Comments 19

Appendix I GAO Contact and Staff Acknowledgments 20

Figures

Figure 1: Examples of Non-Out-of-Service versus Out-of-Service 

Vehicle Maintenance Violations 8

Figure 2: Example of a Driver Receiving a Violation for a 

Previously Identified Equipment Problem, Currently and 

with a System for Self-Reporting Equipment Problems 11

Contents
Page ii GAO-17-132 Motor Carrier Self-Reporting System

Abbreviations

ASAP Aviation Safety Action Program

BASIC Behavior Analysis and Safety Improvement Category

CSA Compliance, Safety, Accountability 

DOT Department of Transportation

DVIR Daily Vehicle Inspection Report

FAA Federal Aviation Administration

FAST Act Fixing America’s Surface Transportation Act

FMCSA Federal Motor Carrier Safety Administration 

MCMIS Motor Carrier Management Information System 

NCCDB National Consumer Complaint Database

OMB Office of Management and Budget

SMS Safety Measurement System

VIN Vehicle Identification Number

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without further permission from GAO. However, because this work may contain 

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Page 1 GAO-17-132 Motor Carrier Self-Reporting System

441 G St. N.W.

Washington, DC 20548

December 2, 2016

The Honorable John Thune

Chairman

The Honorable Bill Nelson

Ranking Member

Committee on Commerce, Science, &Transportation

United States Senate

The Honorable Bill Shuster

Chairman

The Honorable Peter DeFazio

Ranking Member

Committee on Transportation & Infrastructure

House of Representatives

Large trucks and buses transport billions of tons of freight and travel 

hundreds of billions of miles every year on our nation’s highways.

1

Because these commercial motor vehicles travel alongside citizens in 

passenger vehicles, safety is an important concern. In 2015, more than 

4,000 people were killed in crashes involving large trucks, the majority of 

whom were either in another vehicle or were pedestrians or bicyclists. 

Crashes involving commercial motor vehicles can be caused by a variety 

of factors, including driver error or equipment problems such as faulty 

brakes or flat tires. The Federal Motor Carrier Safety Administration 

(FMCSA) sets requirements in regulations for the operating condition of 

vehicles operated by commercial motor carriers (“carriers”).

2 These 

include requirements for the maintenance of commercial motor vehicle 

parts and accessories such as lights, reflectors, brakes, fuel systems, and 

tires. Carriers and commercial motor vehicle drivers are responsible for 

ensuring their vehicles meet those requirements at all times. If a driver 

identifies some aspect of his or her vehicle’s equipment that is out of 

compliance with these regulations—for instance brakes that do not 

adequately stop and hold the vehicle—the carrier (or its agent, e.g., the 

 1

A large truck is defined as a truck weighing greater than 10,000 pounds. 49 C.F.R. § 

350.105.

2

FMCSA establishes safety requirements through regulations for all interstate motor 

carriers and intrastate hazardous material carriers. 49 C.F.R. §§ 300-399.

Letter
Page 2 GAO-17-132 Motor Carrier Self-Reporting System

driver or a repair facility) is responsible for repairing the problem before 

the vehicle is on the road.

To enforce compliance with FMCSA regulations, FMCSA partners with 

states’ law enforcement agencies and others to perform roadside 

inspections of commercial motor vehicles. Inspectors compare the 

vehicle’s condition to requirements listed in FMCSA’s regulations, and 

review the driver’s credentials. If an inspector determines that a vehicle is 

out of compliance with those regulations, the carrier is issued a violation, 

which is reported to FMCSA. In 2015, federal and state inspectors 

conducted approximately 3.4 million roadside inspections, including 2.3 

million vehicle inspections that resulted in 3.8 million vehicle maintenance 

violations, ranging from less severe (e.g., one of several marker lights 

out) to more severe (e.g., a problem with brakes that could lead to a 

crash). With inspection and crash information, FMCSA uses its Safety 

Measurement System (SMS) to generate a percentile ranking of a 

carrier’s safety performance relative to other carriers in several different 

categories. Each category is referred to as a Behavior Analysis and 

Safety Improvement Category (BASIC), and includes vehicle 

maintenance, among other things.

3

Some industry stakeholders have raised the possibility of instituting a 

system for carriers and their drivers to self-report equipment problems 

that they identify to FMCSA. These stakeholders have suggested that if 

an inspector identified a self-reported equipment problem during an 

inspection, it should not count against the carrier’s vehicle maintenance 

BASIC percentile if repaired within a specified time frame.

The Fixing America’s Surface Transportation Act (FAST Act) included a 

provision for us to examine the cost and feasibility of establishing a 

system for self-reporting en route equipment problems for commercial 

motor carriers, and report by December 4, 2016.4 The provision described 

some parameters of a potential system for self-reporting equipment 

problems, including that it would apply only to equipment problems 

identified en route,5 which we defined as those identified after a driver 

 3

Carriers can receive a BASIC percentile in up to 7 categories—Vehicle Maintenance, 

Unsafe Driving, Hazardous Materials, Hours-of-Service Compliance, Driver Fitness, 

Controlled Substances and Alcohol, and Crash Indicator.

4

Pub. L. No. 114-94, § 5303, 129 Stat. 1312, 1542. 

5

Pub. L. No. 114-94, § 5303, 129 Stat. 1312, 1543-44 (2015).
Page 3 GAO-17-132 Motor Carrier Self-Reporting System

conducted his required pre-trip inspection at the beginning of each work 

day and before a driver conducted his required inspection report at the 

end of each work day. In addition, carriers or drivers that self-reported an 

equipment problem and subsequently received an inspection and 

violation for that problem would have to self-report that the problem had 

been repaired for FMCSA to exclude the violation from the carrier’s 

vehicle maintenance BASIC percentile.

6

This report examines (1) potential safety impacts of establishing a system 

for self-reporting equipment problems and repairs for commercial motor 

carriers and their drivers, and (2) factors that could affect the feasibility 

and cost of establishing a system for self-reporting equipment problems 

and repairs.

To perform this work, we reviewed relevant regulations, information on 

other existing systems for self-reporting safety-related information, 

(FMCSA’s National Consumer Complaint Database and the Federal 

Aviation Administration’s (FAA) Aviation Safety Action Program), and our 

past work on FMCSA’s Compliance, Safety, Accountability (CSA) 

program.

7 We also interviewed FMCSA officials and selected 

stakeholders—representatives from six associations (industry and safety 

groups), representatives of six commercial motor carriers, and six 

commercial motor vehicle drivers. The six carriers included two large, two 

medium, and two owner-operators, who are individuals who own and 

operate their own trucks as an independent company. The six drivers 

were from six additional carriers and included four drivers for large 

carriers and two drivers for medium-sized carriers. Associations were 

selected for their work in the motor carrier and highway safety arenas. 

Carriers were selected for diversity in fleet size and haul distance. 

Additional carriers provided a list of drivers from which we selected 

 6

Pub. L. No. 114-94, § 5303 (b)(1)(B) and (C), 129 Stat. 1312, 1543-44.

7

FMCSA’s Safety Measurement System BASIC percentiles discussed in this report are a 

key component of its CSA program, the subject of our 2014 report. See GAO-14-114.
Page 4 GAO-17-132 Motor Carrier Self-Reporting System

drivers for diversity in haul distance.

8 Views we gathered from these 

stakeholders are not generalizable to all industry and safety groups, 

motor carriers, or drivers.

Because the self-reporting system is hypothetical at this point, we made 

three broad assumptions about the system, based on its description in the 

FAST Act and our review of relevant regulations.

• First, only equipment problems that do not render a commercial motor 

vehicle “out-of-service” under FMCSA regulations would be reportable 

under a self-reporting system.

9

• Second, the term “en route” refers to equipment problems that were 

identified while the driver was on his daily trip—that is, after a driver 

conducted his required pre-trip inspection at the beginning of each 

work day, and before a driver conducted his required inspection report 

at the end of each work day.

10

• Finally, any equipment problems identified and reported would have to 

be repaired before the driver’s next day on duty.

11

 8

In this report we describe the views of carriers and drivers together. There is overlap 

between the two groups as owner operators are individuals who own one truck and 

operate it as a carrier, and because either a carrier or a driver could potentially send a 

report to FMCSA under a system for self-reporting equipment problems. We were not able 

to interview any drivers for small carriers—carriers operating between two and five 

trucks—because the drivers we attempted to reach were on duty each time we had an 

interview scheduled with them. Therefore, we relied on our interview with the National 

Association of Small Trucking Companies to capture the views of small carriers and their 

drivers.

9

We make this assumption because current regulations prohibit carriers from operating 

such vehicles because they have equipment problems severe enough that the vehicle’s 

continued operation could to lead to a crash. See 49 C.F.R. §§ 386.72, 392.5, 395.13, 

396.9. Consequently, we assumed that any potential self-reporting system would not allow 

carriers or drivers to report equipment problems of this severity and continue driving until 

repairing the vehicle at a later time.

10Note we do not define “en route,” as a multiple day trip from a starting point to a 

destination. For example, if a driver was on a 4-day trip between Atlanta and San Diego, 

an “en route” equipment problem would be one that occurred after any daily “pre-trip”

inspection and before the end of the day, each day.

11FMCSA regulations require any problems identified during a driver’s pre-trip inspection 

to be repaired before the trip begins. “...prior to requiring or permitting a driver to operate 

a vehicle, every motor carrier or its agent shall repair any defect or deficiency listed on the 

driver vehicle inspection report which would be likely to affect the safety of operation of the 

vehicle.” 49 C.F.R. § 396.11(a)(3).
Page 5 GAO-17-132 Motor Carrier Self-Reporting System

When interviewing stakeholders, we asked for their views on how, if at all, 

they or others (in the case of associations) might use such a system, and 

an estimation of its potential safety impacts. We did not systematically try 

to identify any unintended consequences of establishing a self-reporting 

system, such as whether carriers or drivers would “game the system” by, 

for example, using it to report equipment problems during a trip that 

should have been identified in a pre-trip inspection and repaired before 

the trip began.

To examine the potential safety impacts of this hypothetical self-reporting 

system, we identified existing guidance (Office of Management and 

Budget and Department of Transportation) on estimating the benefits of a 

new government program. We then determined if there was sufficient 

information available to apply such guidance and estimate the benefits of 

a self-reporting system. To identify published data on the relationship 

between non-out-of-service equipment problems and safety outcomes, 

we used a literature review conducted for a 2014 GAO report on FMCSA 

as a starting point, and consulted with GAO experts and FMCSA to 

identify any data published since 2014.

We conducted this performance audit from March 2016 to December 

2016 in accordance with generally accepted government auditing 

standards. Those standards require that we plan and perform the audit to 

obtain sufficient, appropriate evidence to provide a reasonable basis for 

our findings and conclusions based on our audit objectives. We believe 

that the evidence obtained provides a reasonable basis for our findings 

and conclusions based on the audit objectives.

The commercial motor-carrier industry is a vital part of the U.S. economy. 

As of December 2015, FMCSA estimated that there were 551,150 active 

carriers and approximately 6 million commercial drivers operating in the 

United States.12 The domestic commercial motor-carrier industry includes 

a range of businesses, including private and for-hire freight transportation, 

passenger carriers, and specialized transporters of hazardous 

materials.

13 These carriers also range from small carriers with only one 

 12According to FMCSA officials, this estimate of drivers includes intrastate non-hazardous 

materials carriers, but the number of carriers does not.

13Private carriers run an internal trucking operation to support a primary business in 

another industry, such as a retail store chain, while for-hire carriers sell their trucking 

services on the open market. 

Background
Page 6 GAO-17-132 Motor Carrier Self-Reporting System

vehicle that is owned and operated by a single individual, to large 

corporations that own tens of thousands of vehicles.

FMCSA is responsible for overseeing this large and diverse industry. In 

fiscal year 2016, FMCSA had a budget of approximately $580 million and 

more than 1,000 staff members located at its Washington, D.C., 

headquarters, four regional service centers, and 52 division offices.14

FMCSA establishes regulations for all interstate motor carriers in addition 

to intrastate hazardous-material carriers.

15 FMCSA regulations set 

requirements, among others, for the motor vehicle parts and 

accessories—“equipment”—required for safe operation.

16 For example, 

FMCSA’s regulations require vehicles to have certain lights, tire tread 

depth, and parking brakes.

17

Other FMCSA regulations require carriers and their drivers to 

systematically inspect, repair, and maintain their vehicles.

18 Before 

beginning their trip each day, commercial motor vehicle drivers must 

conduct a pre-trip inspection to ensure that their vehicles are in safe 

operating condition, meaning that they meet the maintenance 

requirements set forth in FMCSA regulations.

19 Commercial driver’s 

license tests require drivers to show they can inspect the engine 

components, brakes, steering, and other equipment.

20 If during the pretrip inspection the driver identifies an equipment problem that would affect 

the safe operation of the vehicle, the driver must ensure it is repaired 

before starting a trip. At the end of each day, drivers are also required to 

prepare a daily vehicle inspection report (DVIR), which lists any 

equipment problems identified that day.

21 Drivers submit the DVIRs to 

 14FMCSA officials reported that they also have staff at more than 27 border offices. 

1549 C.F.R. §§ 300-399.

16FMCSA regulations also set requirements for commercial driver qualifications (e.g. 

drivers must be at least 21 years old). 49 C.F.R. § 391.11(b)(1).

1749 C.F.R. § 393.

1849 C.F.R. § 396. 

1949 C.F.R. § 396.13.

2049 C.F.R. § 383.

21The driver of a passenger-carrying commercial motor vehicle must prepare and submit a 

report even if no defect is identified; drivers of all other commercial motor vehicles are only 

required to submit a report if a defect is identified. 49 C.F.R. § 396.11.
Page 7 GAO-17-132 Motor Carrier Self-Reporting System

their carrier, which must repair any issues before sending the vehicle on 

another trip. Regulations also require carriers to conduct comprehensive 

inspections of their vehicles annually.

22 FMCSA regulations set the 

minimum requirements for commercial motor vehicles, but individual 

carriers may have their own additional requirements regarding when and 

how their vehicles are inspected and repaired.

To oversee the safety performance of the commercial motor carrier 

industry, FMCSA and state agencies such as highway patrols perform 

roadside inspections of carriers’ vehicles. These roadside inspections are 

intended to provide a snapshot of commercial motor vehicles’

maintenance and assess the effectiveness of carriers’ maintenance 

programs.

Specially trained and certified personnel serve as inspectors and select 

commercial motor vehicles for inspection as they pass through a roadside 

inspection location such as a weigh station. The inspector compares the 

vehicle’s condition to requirements listed in FMCSA’s regulations and 

issues a violation if there are discrepancies.

23 If the inspector determines 

that the violation could likely cause an accident or breakdown (for 

example, if more than 20 percent of the vehicle’s brakes are defective) 

the vehicle is placed out-of-service until it is repaired.

24 FMCSA 

regulations prohibit carriers from operating a vehicle that has been 

deemed “out-of-service” by an inspector. The Commercial Vehicle Safety 

Alliance, an association comprised of federal and state commercialvehicle safety officials and private industry representatives, provides 

guidance on the criteria that render a vehicle out-of-service. Even if 

violations are found, if the vehicle is not deemed out-of-service, the driver 

is allowed to continue driving, though FMCSA regulations require carriers 

to repair all violations before the vehicle starts another trip.

25 In addition, 

within 15 days of receiving the violation, carriers must certify they have 

made repairs by signing a copy of the inspection report and sending it to 

 2249 C.F.R. § 396.17(c).

23Violations of FMCSA regulations differ from citations, which inspectors would issue if the 

driver were violating state laws, such as the speed limit. Violations affect the carriers’

BASIC percentile, while citations affect the driver’s commercial driver’s license (CDL) 

record.

2449 C.F.R. §§ 386.72, 392.5, 395.13, 396.9.

2549 C.F.R. § 396.11(a)(3).
Page 8 GAO-17-132 Motor Carrier Self-Reporting System

the state department of transportation.

26 See figure 1 for four examples of 

vehicle maintenance violations—the top two depict improper load 

securement and the bottom two depict missing wheel fasteners. In both 

rows, the violation on the right is an out-of-service violation.

Figure 1: Examples of Non-Out-of-Service versus Out-of-Service Vehicle 

Maintenance Violations

FMCSA uses the data on violations submitted by inspectors to rank 

carriers’ relative safety performance in seven categories and assign 

carriers to a percentile in each.

27 One of the categories, the vehicle 

maintenance Behavior Analysis and Safety Improvement Category 

(BASIC), takes into account violations related to failing to properly 

maintain a commercial motor vehicle and failing to secure loads. FMCSA 

 2649 C.F.R. § 396.9(d)(3).

27Inspectors submit violation information to FMCSA after conducting an inspection. 
Page 9 GAO-17-132 Motor Carrier Self-Reporting System

uses these BASIC percentiles to identify and target “high-risk” carriers for 

interventions, such as warning letters and on-site investigations.

In 2014, we reported on the effectiveness of SMS and found that FMCSA 

faces challenges in reliably assessing safety risks for the majority of 

carriers.

28 We recommended that FMCSA revise the SMS methodology to 

better account for limitations in drawing comparisons of safety 

performance information across carriers.

29 As of November 2016, FMCSA 

has not implemented our recommendation. The FAST Act directed 

FMCSA to address the issues raised in our report and required that 

FMCSA remove the BASIC percentiles from public view on its website 

until then, which it has done.

30

One of the challenges in assessing the safety impact of a potential 

system for self-reporting equipment problems is its hypothetical nature. 

As described above, based on one of the provisions in the FAST Act and 

discussions with FMCSA and stakeholders, we made a number of 

 28GAO-14-114.

29FMCSA did not concur with our recommendation, but stated that it would analyze the 

recommendation as the agency continued to improve the effectiveness of the Safety 

Measurement System.

30The FAST act states that the relative percentile for each BASIC may not be made 

available to the public until “the Administrator of the Federal Motor Carrier Safety 

Administration has fully implemented or satisfactorily addressed the issues raised in the 

report.” Pub. L. No. 114-94, § 5223, 129 Stat. 1312,1541.

While Potential Safety 

Impact of a SelfReporting System Is 

Difficult to Determine, 

FMCSA and Selected 

Stakeholders 

Suggested Safety 

Benefits Are Unlikely

Identifying Potential Safety 

Impact of a System for 

Self-Reporting Equipment 

Problems Is Challenging
Page 10 GAO-17-132 Motor Carrier Self-Reporting System

assumptions about such a system. We assumed that a self-reporting 

system would:

• apply only to problems identified during a driver’s day, that is between 

the pre-trip inspection and the end of the day when the driver vehicle 

inspection report is completed;

• not apply to equipment problems that would result in out-of-service 

violations;

• require drivers to report equipment problems and repairs through a 

telephone hotline or Internet website or other electronic platform;

• require repairs to be made before the beginning of the next day on 

duty (e.g., within a day of when the problem was reported, if the driver 

ended his trip that evening and planned another trip the following 

day);

• still result in a carrier receiving a violation for the equipment problem if 

pulled over for a roadside inspection, but once a self-reported 

equipment problem was repaired within the requisite time frame and 

FMCSA was so notified, FMCSA would exclude the violation from the 

carrier’s relative safety ranking (i.e., BASIC percentile for vehicle 

maintenance); and

• not prompt FMCSA to take action if a carrier or driver self-reported an 

equipment problem, but never received a violation for that equipment 

problem.

Figure 2 below illustrates some of the key differences between the current 

process for identifying and repairing equipment problems and the process 

under a potential self-reporting system with the features assumed above.
Page 11 GAO-17-132 Motor Carrier Self-Reporting System

Figure 2: Example of a Driver Receiving a Violation for a Previously Identified 

Equipment Problem, Currently and with a System for Self-Reporting Equipment 

Problems

The Office of Management and (OMB) and the Department of 

Transportation (DOT) provide guidance on estimating a program’s 

societal impact, such as its health and safety benefits, through a benefitcost analysis. For example, DOT’s Economic Analysis Primer states that 

a benefit-cost analysis requires the identification of a base case—usually 

the status quo—so that the benefits and costs associated with 

implementing the new program can be compared against this base.

31 For 

a new program designed to affect safety, identifying the base case and 

the potential benefits of the new program generally requires data on past 

events related to the type of bad outcomes (i.e., injuries and deaths) that 

the new program is expected to reduce.

Even after putting some parameters on a hypothetical system for selfreporting equipment problems (i.e., our assumptions), estimating its 

overall safety impact is challenging for two key reasons:

1. We did not identify any conclusive data on the “base case” or status 

quo for a self-reporting system—that is, data on how non-out-ofservice equipment problems are related to safety outcomes. FMCSA 

and the National Highway Traffic Safety Administration estimated that 

 31Department of Transportation Federal Highway Administration Office of Asset 

Management, Economic Analysis Primer (August 2003).
Page 12 GAO-17-132 Motor Carrier Self-Reporting System

equipment problems such as braking capacity, tire or wheel failure, or 

shifting cargo were the critical reason for a crash in about 10 percent 

of the crashes for which a critical reason was assigned to a truck, as 

reported in the Large Truck Crash Causation Study.

32 However, this 

study was issued 11 years ago and did not separately present data for 

or otherwise discuss the extent to which non-out-of-service equipment

problems were related to crashes. Further, our review of literature and 

interviews with FMCSA did not identify any additional data. 

Consequently, there is no baseline against which to evaluate the 

extent to which safety may be improved with the implementation of 

such a system.

2. Even if such data were available, we determined that an assessment 

of potential safety impacts would also require information on the 

extent to which a self-reporting system would change the frequency or 

speed with which drivers make equipment repairs. This would require 

information on both the frequency and speed with which carriers 

currently make repairs, and how a self-reporting system would change 

that behavior. Both, however, are unknown and difficult to determine 

because they would require predicting behavior under hypothetical 

conditions.

For a self-reporting system to impact safety, carriers and drivers would 

have to use it, but the majority of carriers and drivers we interviewed said 

their use of a potential self-reporting system would depend on various 

factors. The most frequently cited factor was ease of use. For example, 

some said they preferred a telephone hotline to a web-based application; 

others said the opposite. One carrier and one driver said they would use 

a self-reporting system if they thought they were traveling a route where 

an inspection was likely. Another carrier said it might use a self-reporting 

system if it afforded them increased flexibility to wait to repair low risk 

equipment problems at a less expensive repair facility, such as the 

carrier’s own maintenance facility.

Representatives from five of six industry and safety associations we 

interviewed said they would be unlikely to support a self-reporting system 

 32In the study, trucks were assigned a “critical reason” in 55 percent of the crashes. 

FMCSA and NHTSA conducted a multiyear, nationwide study of factors that contribute to 

truck crashes. A nationally representative sample of large truck fatal and injury crashes 

was investigated from 2001 through 2003 at 24 sites in 17 states. See U.S. Department of 

Transportation, Federal Motor Carrier Safety Administration, Report to Congress on the 

Large Truck Crash Causation Study, MC-R/MC-RIA (November 2005).

Most Selected 

Stakeholders Told Us 

Their Use of a SelfReporting System Would 

Be Affected by Factors 

Such as Ease of Use
Page 13 GAO-17-132 Motor Carrier Self-Reporting System

as outlined above. Industry and safety representatives cited reasons such 

as an administrative burden for drivers and carriers, and potentially 

negative safety impacts, as described below. Representatives from one 

industry association noted that a self-reporting system should allow 

drivers to simply record an equipment problem in their driver vehicle 

inspection report (DVIR) when they notice the problem. If by chance a 

driver was pulled over subsequent to recording in the DVIR, the driver 

could show the record to the inspector and not receive a violation for that 

equipment problem. However, as discussed above, for FMCSA to ensure 

that self-reported equipment problems were repaired, FMCSA would first 

have to receive a record of a violation. Then, after receiving certification 

of the accompanying repair, FMCSA would ensure that the violation was 

not included in the calculation of the carrier’s vehicle maintenance BASIC 

percentile. Thus, noting the equipment problem on a DVIR would not be 

sufficient.

To impact safety, a self-reporting system would also have to prompt 

drivers and carriers to change the way they identify and repair equipment 

problems, yet the majority of carriers and drivers we interviewed said the 

system would not change, for example, how quickly they made repairs. 

As described above, FMCSA regulations require drivers to conduct a pretrip and end-of-day inspection of their vehicle and to ensure that any 

identified issues are repaired before driving.

33 Carriers and drivers we 

interviewed said that if they identify an equipment problem en route, that 

is, after their pre-trip inspection, they work with their carrier to determine 

when and where to repair the problem. Many carriers and drivers we 

interviewed said they would continue to identify and repair equipment 

problems the same way and with the same speed under a system for selfreporting equipment problems.

More generally, the majority of carriers and drivers we interviewed stated 

that any safety impacts of a self-reporting system—positive or negative—

would be minimal. For example, three drivers thought a self-reporting 

system could potentially yield some safety benefits if it incentivized 

drivers to do more thorough pre-trip or en route inspections. This could 

lead to better identification and quicker repair of equipment problems. On 

the other hand, three carriers and two other drivers we interviewed 

thought a self-reporting system could potentially yield some negative 

 3349 C.F.R. §§ 396.11, 396.13.

Most Carriers and Drivers 

Anticipated No Significant 

Safety Benefits of a SelfReporting System, and 

FMCSA and Other 

Stakeholders Said It May 

Negatively Impact Safety
Page 14 GAO-17-132 Motor Carrier Self-Reporting System

safety impacts if it incentivized some drivers to delay or avoid making 

repairs for problems they had self-reported.

Further, FMCSA officials and safety association representatives we 

interviewed stated that they believed a self-reporting system could lead to 

negative safety outcomes. FMCSA officials said that a self-reporting 

system could result in carriers trying to “game the system,” for example 

by using it to report equipment problems during a trip that should have 

been identified in a pre-trip inspection and repaired before the trip began. 

FMCSA officials said that this type of delayed repair could lead to a more 

serious maintenance condition occurring. Representatives from safety 

associations said that carriers and drivers might delay making repairs 

until the end of any permitted time period or might engage in distracted 

driving while typing or calling in an en route equipment problem on their 

cell phones.

Neither we nor FMCSA identified any statutory or regulatory barriers to 

establishing a system for self-reporting equipment problems. When 

Congress established FMCSA in 1999, it granted the agency authority to 

develop and enforce commercial motor-vehicle safety regulations and 

practices to promote a safe and efficient transportation system.

34 With this 

authority, FMCSA created regulations setting requirements for vehicles’

operating condition and roadside inspections. Under this authority, 

FMCSA could create a system for self-reporting equipment problems. 

 34Pub. L. No. 106-159, 113 Stat. 1748. (1999). 

FMCSA Has the 

Statutory and 

Regulatory Capability 

to Establish a SelfReporting System, 

but FMCSA and 

System Users May 

Face Challenges, and 

Costs are Unknown

We Did Not Identify Any 

Statutory or Regulatory 

Barriers to Establishing a 

System for Self-Reporting 

Equipment Problems
Page 15 GAO-17-132 Motor Carrier Self-Reporting System

Similarly, we did not identify any barrier in existing regulations to 

establishing a self-reporting system. FMCSA officials stated that if a selfreporting system were in place, vehicles would still be required to meet 

the minimum vehicle condition requirements and inspectors would 

continue to inspect vehicles to ensure compliance with these regulations 

and issue violations. Rather than altering existing regulations, FMCSA 

officials said a potential self-reporting system would require FMCSA to 

change its internal policy document that outlines how FMCSA calculates 

carriers’ vehicle maintenance BASIC percentiles.

35

While the technology exists for FMCSA to establish a system for selfreporting equipment problems, the agency may face challenges 

implementing such a system. FMCSA officials stated they could design a 

self-reporting system to be compatible with the agency’s existing IT 

systems. FMCSA currently uses its Motor Carrier Management 

Information System (MCMIS) to manage motor carrier and driver 

performance data, including inspection and investigation results.

36

FMCSA officials said they could potentially use MCMIS to manage selfreported equipment problem information, but there might be challenges 

matching self-reported vehicle maintenance issues with violations issued 

by inspectors in the MCMIS database. For example, to exclude 

equipment problem violations that were self-reported and repaired from 

BASIC percentile calculations, FMCSA would have to match the selfreported equipment problem and repair to a corresponding report of a 

violation issued by an inspector for that same equipment problem. This 

could be difficult if, for example, the driver and inspector coded the 

equipment problem differently (e.g., driver recorded “inoperative required 

lamps” and inspector recorded “inoperative head lamps”). Safety 

advocacy groups believed more oversight would be necessary to ensure 

carriers actually made repairs, but FMCSA and multiple carriers believed 

showing proof of repairs for every report (e.g., receipts or written repair 

orders) as opposed to simply self-certifying a repair, would be too timeconsuming.

 35Carrier Safety Measurement System Methodology 3.0.3, Federal Motor Carrier Safety 

Administration, 2014.

36MCMIS also includes data on enforcement actions, such as inspection and compliance 

reviews, and state-reported crashes involving commercial motor carriers.

FMCSA and Users Could 

Face Challenges 

Implementing a SelfReporting System
Page 16 GAO-17-132 Motor Carrier Self-Reporting System

In addition, we found in October 2016 that FMCSA has faced longstanding delays with software development.

37 Creating a self-reporting 

system could place new demands on FMCSA’s information technology 

resources. FMCSA has put a hold on rolling out new enforcement 

strategies, such as offsite investigations (investigations conducted 

remotely using documents submitted by carriers, such as toll receipts, 

border crossing records, or drug testing records), until the agency has 

finished creating an improved software system to manage these 

enforcement activities. Developing a self-reporting system could further 

delay these software improvements. FMCSA officials estimated it could 

take between 3 and 5 years to develop a self-reporting system. FMCSA 

officials, one safety advocacy group, and an industry group we 

interviewed echoed this concern, suggesting that a self-reporting system 

could divert FMCSA resources from other IT priorities. For example, one 

industry group thought FMCSA should focus on improving its DataQ 

system, which allows carriers to challenge, and correct as appropriate, 

violations appearing on their records.

Finally, FMCSA officials told us that building, implementing, and 

maintaining a self-reporting system would require significant resources. 

For example, FMCSA would need to comply with the Paperwork 

Reduction Act of 1995 (PRA), a process that FMCSA officials said has 

been time consuming in the past. The PRA requires agencies to minimize 

the paperwork burden of their information collections (e.g., driver’s license 

and Vehicle Identification Number (VIN) information in the case of a selfreporting system) and evaluate whether a proposed information collection 

is necessary for the proper performance of agency functions.

38 To do so, 

the agency must complete an “information collection request,” which 

includes a report on why certain information is being collected and an 

estimate of the cost to the public.

Carriers and drivers could also face challenges using a potential system 

for self-reporting equipment problems. For example, both a web 

application and telephone hotline would require drivers to have cell 

service—which is not always the case for drivers in remote areas of the 

country. It could be possible, therefore, for a driver to be stopped for an 

 37GAO, Motor Carriers: Better Information Needed to Assess Effectiveness and Efficiency 

of Safety Interventions, GAO-17-49 (Washington, D.C.: Oct. 27, 2016).

38Paperwork Reduction Act of 1995, Pub. L. No. 104-13, 109 Stat. 163 (codified as 

amended at 44 U.S.C. §§ 3501-3520).
Page 17 GAO-17-132 Motor Carrier Self-Reporting System

inspection before he was able to report an equipment problem. If the 

system were a web application, drivers would need smartphones to report 

an equipment problem, but some drivers may not have one. If the system 

were a telephone hotline, two carriers and one driver worried the hotline 

could become inundated with calls with long wait times, though as noted 

above, it is not clear how many carriers would utilize such a system.

Carriers or drivers could also face challenges accurately entering required 

information. For example, FMCSA could require drivers to enter their 17-

digit VIN along with their Commercial Driver’s License number when 

reporting an equipment problem or repair, but entering this many digits 

could yield errors. Additionally, drivers would need to identify the violation 

that most closely matched their equipment problem, out of more than 300 

potential vehicle maintenance violations. In some instances, that may be 

difficult to do; for example, there are 17 different violations related to 

reflective sheeting (e.g., not having reflectors on mud flaps). As discussed 

above, the way a driver or carrier self-reported a problem could differ from 

the way an inspector reported the violation. Similarly, identifying whether 

an equipment problem could render a vehicle out of service could be 

challenging. Equipment problems may or may not place a vehicle out-ofservice depending on their severity. For example, regulations require a 

vehicle’s front tire treads to be at least 4/32 of an inch deep.

39 Drivers will 

receive a violation if the tread is less than that requirement, but will only 

be placed out of service if the tread is less than 2/32 of an inch deep. 

Thus, it is possible that a driver could self-report a “tire tread depth”

problem into a self-reporting system, but be operating with an out-ofservice tread depth.

According to our cost-estimating guidance, creating an accurate cost 

estimate for any program requires a description of the system and its 

technical and performance characteristics—characteristics that are not 

currently known for this self-reporting system.

40 For example, we do not 

know whether the system would be a web-based application or a staffed 

hotline, nor do we know the extent to which FMCSA would need to review 

reports submitted in the system. Design options such as these would 

affect the number of FMCSA staff needed to operate and maintain the 

system and would require different amounts of IT investment. Therefore, 

 3949 C.F.R. § 393.75.

40GAO, GAO Cost Estimating and Assessment Guide, GAO-09-3SP (Washington, D.C.: 

March 2009).

Without Details of 

System’s Design, Total 

Costs Cannot Be 

Quantified
Page 18 GAO-17-132 Motor Carrier Self-Reporting System

without knowing these design characteristics, we cannot estimate the 

initial cost of developing a potential self-reporting system or the continued 

costs of maintaining it with any degree of confidence.

However, two existing DOT self-reporting systems can provide a 

benchmark for potential costs of a self-reporting system, though these 

systems differ from an equipment problem self-reporting system in 

substantive ways. FMCSA maintains the National Consumer Complaint 

Database (NCDDB), which allows drivers and the general public to submit 

complaints ranging from moving companies damaging household goods 

to drivers being forced to operate unsafe equipment. According to 

FMCSA officials, this database received approximately 20,000 reports in 

2015, and cost approximately $1 million to operate in that year. While the 

NCCDB seems similar to a system for self-reporting equipment problems 

in that it allows drivers to self-report information through both a website 

and hotline, it differs in that NCCDB complaints do not feed into another 

FMCSA IT system, as self-reported equipment problems would need to. 

FMCSA officials thought that linking the self-reported equipment problems 

and MCMIS data systems would be the most costly part of developing a 

system for self-reporting equipment problems.

FAA maintains the Aviation Safety Action Program (ASAP), which allows 

pilots, flight attendants, and maintenance employees to voluntarily report 

safety incidents to help FAA identify potential precursors to accidents. 

FAA officials reported that in 2015 ASAP received 98,000 reports and 

cost approximately $23 million in personnel costs only. This amount did 

not include the cost to establish ASAP or costs for operating the system 

itself. ASAP is similar to a motor carrier system for self-reporting 

equipment problems in that by self-reporting, users can avoid violations, 

but differs in a number of key ways. For example, ASAP does not include 

reporting for equipment problems, its focus is on identifying potential 

precursors to accidents, and it devotes significant resources to 

assembling committees to review each ASAP report and identify a 

corresponding corrective action, something which a motor carrier selfreporting system likely would not.

While we cannot estimate costs for the type of self-reporting system 

described in this report with any degree of confidence, FMCSA broadly 

estimated that a self-reporting system would cost between $5 and $10 

million to establish and operate for the first year. FMCSA officials said this 

estimate did not use other DOT self-reporting systems as a benchmark 

nor did it explicitly include training, testing, or data storage—some of the

factors that GAO’s cost-estimating guide identifies as key to establishing 
Page 19 GAO-17-132 Motor Carrier Self-Reporting System

and maintaining a new electronic system. Therefore, this estimate may 

not cover the full cost of establishing a system for self-reporting 

equipment problems.

We provided a draft of this report to DOT for review and comment. DOT 

provided technical comments, which we incorporated as appropriate.

We are sending copies of this report to relevant congressional 

committees, the Secretary of Transportation, and the Administrator of 

FMCSA. In addition, the report is available at no charge on GAO’s 

website at http://www.gao.gov.

If you or your staff have any questions about this report, please contact 

me at (202) 512-2834 or flemings@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made major contributions to 

this report are listed in appendix I.

Susan Fleming

Director, Physical Infrastructure Issues

Agency Comments
Appendix I: GAO Contact and Staff 

Acknowledgments

Page 20 GAO-17-132 Motor Carrier Self-Reporting System

Susan A. Fleming, (202) 512-2834 or flemings@gao.gov

In addition to the individual named above, H. Brandon Haller (Assistant 

Director), Sarah Farkas (Analyst-in-Charge), Amy Abramowitz, Russell 

Burnett, David Hooper, Catrin Jones, Delwen Jones, and Malika Rice 

made key contributions to this report.

Appendix I: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(100747)
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