United States Government Accountability Office

GAO Report to the Chairman, Committee on 

Transportation and Infrastructure, 

House of Representatives 

MOTOR CARRIER 

SAFETY 

Federal Safety Agency 

Identifies Many 

High-Risk Carriers but 

Does Not Assess 

Maximum Fines as 

Often as Required by 

Law 

August 2007 

 

GAO-07-584 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

 August 2007

MOTOR CARRIER SAFETY 

Federal Safety Agency Identifies Many 

High-Risk Carriers but Does Not Assess 

Maximum Fines as Often as Required by 

Law 

Highlights of GAO-07-584, a report to the 

Chairman, Committee on Transportation 

and Infrastructure, House of 

Representatives 

The Federal Motor Carrier Safety 

Administration (FMCSA) has the 

primary federal responsibility for 

reducing crashes involving large 

trucks and buses. FMCSA uses its 

“SafeStat” tool to target carriers for 

reviews of their compliance with 

the agency’s safety regulations 

based on their crash rates and

safety violations. 

As requested, this study reports on 

(1) the extent to which FMCSA’s 

policy for prioritizing compliance

reviews targets carriers with a high 

risk of crashes, (2) how FMCSA 

ensures compliance reviews are 

thorough and consistent, and (3) 

the extent to which FMCSA follows 

up with carriers with serious safety 

violations. To complete this work, 

GAO reviewed FMCSA’s 

regulations, policies, and safety 

data and contacted FMCSA officials 

in headquarters and nine field 

offices. 

By and large, FMCSA does a good job of identifying carriers that pose high 

crash risks for subsequent compliance reviews, ensuring the thoroughness 

and consistency of those reviews, and following up with high-risk carriers. 

FMCSA’s policy for prioritizing compliance reviews targets many high-risk 

carriers but not other higher risk ones. Carriers must score among the worst 

25 percent of carriers in at least two of SafeStat’s four evaluation areas 

(accident, driver, vehicle, and safety management) to receive high priority 

for a compliance review. Using data from 2004, GAO found that 492 carriers 

that performed very poorly in only the accident evaluation area (i.e., those 

carriers that scored among the worst 5 percent of carriers in this area) 

subsequently had an aggregate crash rate that was more than twice as high 

as that of the 4,989 carriers to which FMCSA gave high priority. FMCSA told 

GAO that the agency plans to assess whether giving high priority to carriers 

that perform very poorly in only the accident evaluation area would be an 

effective use of its resources. 

 

FMCSA promotes thoroughness and consistency in its compliance reviews 

through its management processes, which meet GAO’s standards for internal

controls. For example, FMCSA uses an electronic manual to record and 

communicate its compliance review policies and procedures and teaches

proper compliance review procedures through both classroom and on-thejob training. Furthermore, its investigators use an information system to 

document their compliance reviews, and its managers review these data,

helping to ensure thoroughness and consistency between investigators. For 

the most part, FMCSA and state investigators cover the nine major 

applicable areas of the safety regulations (e.g., driver qualifications and 

vehicle condition) in 95 percent or more of compliance reviews, 

demonstrating thoroughness and consistency. 

FMCSA follows up with many carriers with serious safety violations, but it 

does not assess maximum fines against all of the serious violators that GAO 

believes the law requires. FMCSA followed up with more than 99 percent of 

the 1,196 carriers that received proposed unsatisfactory safety ratings from 

compliance reviews completed in fiscal year 2005, finding that 881 of these 

carriers made safety improvements and placing 309 others out of service. 

However, GAO found that FMCSA (1) does not assess maximum fines 

against carriers with a pattern of varied serious violations as GAO believes 

the law requires and (2) assesses maximum fines against carriers for the 

third instance of a violation, whereas GAO reads the statute as requiring

FMCSA to assess the maximum fine for the second. 

What GAO Recommends

GAO is making several 

recommendations, including that 

FMCSA (1) select certain high-risk 

carriers in the accident safety

evaluation area for compliance

reviews and (2) revise its policy for

assessing maximum fines. The 

Department of Transportation said 

that it would assess the efficacy of

the first recommendation, but it did

not comment on the other 

recommendations. 

www.gao.gov/cgi-bin/getrpt?GAO-07-584.

To view the full product, including the scope 

and methodology, click on the link above. 

For more information, contact Susan A. 

Fleming at (202) 512-2834 or 

flemings@gao.gov. 
Contents 

Letter 1

Results in Brief 5

Background 9

FMCSA’s Policy for Prioritizing Compliance Reviews Targets Many 

High-Risk Carriers, but Changes to the Policy Could Target 

Carriers with Even Higher Risk 17 

FMCSA’s Management of Its Compliance Reviews Promotes 

Thoroughness and Consistency 25 

FMCSA Follows Up with Many Carriers with Serious Safety 

Violations but Does Not Assess Maximum Fines against All of

the Serious Violators Required by Law 31 

Conclusions 45

Recommendations for Executive Action 46 

Agency Comments 46 

Appendix I Other Assessments of SafeStat’s Ability to Identify 

High-Risk Motor Carriers 48 

Appendix II FMCSA’s Crash Data Used to Compare Methods for 

Identifying High-Risk Carriers 51 

Appendix III Review of Studies on Predictors of Motor Carrier 

and Driver Crash Risk 57 

Appendix IV Scope and Methodology 62 

Appendix V GAO Contact and Staff Acknowledgments 67 

Tables 

Table 1: SafeStat Categories 15 

Table 2: How FMCSA Determines Carrier Safety Ratings Based on 

Ratings in Six Safety Areas 16 

Page i GAO-07-584 Motor Carrier Safety Oversight
Table 3: Crash Rates of Motor Carriers in Various SafeStat 

Categories in the 18 Months following the June 2004

SafeStat Categorization 18 

Table 4: Regression Model Approach Compared with Refined 

Prioritization Approach and with Current SafeStat 

Approach 21

Table 5: Percentages of Compliance Reviews for Fiscal Years 2001

through 2006 That Covered Each of the Major Applicable

Areas of the Safety Regulations 30 

Table 6: Time Elapsed before Carriers Rated Conditional Received 

Follow-up Compliance Reviews, Fiscal Years 2002 through 

2004, as of September 2006 37 

Table 7: Number of Motor Carriers That Would Have Been Subject 

to Maximum Fines under Various Definitions of a Pattern 

of Serious Violations, Fiscal Years 2004 through 2006 43 

Table 8: Number of Motor Carriers That Would Have Been Subject 

to Maximum Fines under Two Strikes and Three Strikes 

Repeat Violator Policies, Fiscal Years 2004 through 2006 44 

Figures 

Figure 1: Commercial Motor Vehicle Fatality Rate, 1975 to 2005 10 

Figure 2: FMCSA’s Safety Oversight Approach 12 

Figure 3: Percentage of Crashes Submitted to MCMIS within 90 

Days of Occurrence, Fiscal Years 2000 through 2006 52 

Abbreviations 

FMCSA Federal Motor Carrier Safety Administration 

MCMIS Motor Carrier Management Information System 

PRISM Performance Registration and Information System 

Management 

SafeStat Motor Carrier Safety Status Measurement System 

This is a work of the U.S. government and is not subject to copyright protection in the 

United States. The published product may be reproduced and distributed in its entirety 

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

copyrighted images or other material, permission from the copyright holder may be 

necessary if you wish to reproduce this material separately. 

Page ii GAO-07-584 Motor Carrier Safety Oversight
United States Government Accountability Office

Washington, DC 20548 

August 28, 2007 

The Honorable James L. Oberstar 

Chairman 

Committee on Transportation and Infrastructure 

House of Representatives 

Dear Mr. Chairman: 

About 5,500 people die each year as a result of crashes involving large 

commercial trucks or buses,1

 and about 160,000 more people are injured. 

These crashes may result from errors by truck, bus, or passenger vehicle 

drivers, vehicle condition, and other factors. The Federal Motor Carrier 

Safety Administration (FMCSA) within the U.S. Department of 

Transportation shoulders the primary federal responsibility for reducing 

crashes, injuries, and fatalities involving large trucks and buses. FMCSA’s 

primary means of preventing these crashes is to develop and enforce 

regulations to help ensure that drivers and motor carriers are operating 

safely. FMCSA uses several enforcement activities to ensure compliance 

with its safety regulations, including detailed inspections of motor carriers’ 

operations at their places of business, called compliance reviews. FMCSA 

also funds and oversees similar enforcement activities at the state level. 

Because of resource constraints, each year FMCSA and its state partners 

are able to conduct compliance reviews of only about 2 percent of the 

nation’s estimated 711,000 motor carriers that are subject to the federal 

safety and hazardous materials regulations.2

 FMCSA targets these reviews 

toward those carriers that its Motor Carrier Safety Status Measurement 

System (SafeStat) identifies as having the greatest potential for being 

involved in crashes and assigns these carriers to its two highest priority 

categories—SafeStat categories A and B. SafeStat’s assessments are based 

 1

Large trucks are those with a gross vehicle weight greater than 10,000 pounds. A bus is a

motor vehicle that is used to carry more than eight passengers (including the driver). 

2

According to FMCSA, this is the number of commercial motor carriers registered in its

Motor Carrier Management Information System, as of February 2007. It includes an 

unidentified number of carriers that are registered, but are no longer in business.

Furthermore, it includes only carriers classified as interstate carriers (about 696,000 

carriers) or intrastate carriers of hazardous materials (about 15,000 carriers). For the sake 

of simplicity, we refer to these carriers collectively as “interstate carriers.” 

Page 1 GAO-07-584 Motor Carrier Safety Oversight
on indicators such as crash rates and safety violations identified during 

roadside inspections of vehicles and drivers and during prior compliance 

reviews. To be given high priority for a compliance review, a carrier must 

score among the worst 25 percent of carriers3

 in at least two of SafeStat’s 

four evaluation areas (the four areas are accident, driver, vehicle, and 

safety management; the scores for the last three of these are based on a 

carrier’s violations). As a result, carriers that score poorly in a single area 

often do not necessarily receive a compliance review. 

Federal law requires FMCSA to determine whether carriers are fit to 

operate safely and to place those carriers that it finds unfit out of service. 

Out-of-service carriers cannot come back into service until FMCSA 

determines that they have corrected the conditions that rendered them 

unfit. FMCSA determines safety fitness by conducting compliance reviews, 

and it assigns unfit carriers a rating of “unsatisfactory.” It also requires 

follow-up compliance reviews on carriers that it rates “conditional.”4

FMCSA can assess fines against carriers for violations of the safety 

regulations, and federal law requires FMCSA to assess the maximum 

allowable fine5

 for each serious violation6 for those carriers whose 

performance demonstrates a pattern of serious violations or violations 

that are the same as or related to a previous serious violation (we call 

these “repeat” violations). 

You asked us to examine how FMCSA identifies and takes action against 

the freight and passenger commercial motor carriers that are the most 

egregious offenders of federal motor carrier safety regulations. 

Accordingly, this report focuses on 

 3

Within each safety evaluation area, this includes only those carriers for which FMCSA had 

sufficient data to calculate a value. 

4

A conditional safety rating means a motor carrier, as a result of not having adequate safety 

management controls, has had serious violations of the safety regulations. 

5

We use the term “fine” to refer to civil fines as opposed to criminal fines.

6

We use the term “serious violations” to refer to acute or critical violations. Acute 

violations are so severe that FMCSA will require immediate corrective actions by a motor 

carrier regardless of the overall safety status of the motor carrier. An example of an acute 

violation is a carrier failing to implement an alcohol or drug testing program for drivers.

Critical violations are less severe than acute violations and most often point to gaps in 

carrier management or operational controls, such as not maintaining records of driver 

medical certificates. 

Page 2 GAO-07-584 Motor Carrier Safety Oversight
• the extent to which FMCSA’s policy for prioritizing compliance reviews 

targets carriers that subsequently have high crash rates, 

• how FMCSA ensures that its compliance reviews are conducted 

thoroughly and consistently, and 

• the extent to which FMCSA follows up with carriers with serious safety 

violations. 

You also asked us to review other studies on SafeStat’s ability to identify 

motor carriers with high crash risks and the impact of data quality on 

SafeStat’s predictive ability. This report presents the findings on those 

issues from our June 2007 report. 7 (See apps. I and II.) Finally, as you 

requested, this report discusses studies on predictors of motor carrier and 

driver crash risk. (See app. III.) 

In our June 2007 report, we assessed the extent to which changes in the 

SafeStat model, by using regression modeling techniques, could improve 

FMCSA’s ability to identify commercial motor carriers that pose high crash 

risks. In contrast, this report assesses whether changes in how FMCSA 

prioritizes carriers for compliance reviews based on their scores in 

SafeStat’s four evaluation areas could target carriers with higher aggregate 

crash risks. 

To determine the extent to which FMCSA’s policy for prioritizing 

compliance reviews targets carriers that subsequently have high crash 

rates, we analyzed data from FMCSA’s Motor Carrier Management 

Information System (MCMIS) on the June 2004 SafeStat assessment of 

carriers and on the assessed carriers’ crashes in the 18 months (July 2004 

through December 2005) following the SafeStat assessment.8

 We defined

various groups of carriers for analysis, including those to which FMCSA 

gave high priority, as well as those based on alternatives to FMCSA’s 

prioritization policy. We then calculated the aggregate crash rate in the 18

months following the SafeStat assessment for each of these groups and 

 7

GAO, Motor Carrier Safety: A Statistical Approach Will Better Identify Commercial 

Carriers That Pose High Crash Risks Than Does the Current Federal Approach, 

GAO-07-585 (Washington, D.C.: June 11, 2007). Our findings are summarized in the section 

of this report dealing with FMCSA’s policy for prioritizing compliance reviews. 

8

FMCSA requires that states report crashes within 90 days. Sometimes states report crashes

late. To allow for this occurrence, we analyzed data on crashes occurring from June 2004

through December 2005, but which may have been reported as late as June 2006. 

Page 3 GAO-07-584 Motor Carrier Safety Oversight
compared crash rates among the various groups to determine whether 

there were any groups with substantially higher rates than the carriers in 

SafeStat categories A or B. We also talked to FMCSA officials about how 

FMCSA developed SafeStat, their views on other evaluations of SafeStat, 

and FMCSA’s plans to replace SafeStat with a new tool. 

To assess how FMCSA ensures that its compliance reviews are completed 

thoroughly and consistently, we identified our key internal control 

standards related to the communication of policy, documentation of 

results, and monitoring and reviewing of activities and findings.9

 In our 

view, these standards are critical to maintaining the thoroughness and 

consistency of compliance reviews. We gathered information on these key 

internal controls through discussions with FMCSA officials, reviews of 

policy documents and reports, and reviews of FMCSA information systems 

used to communicate policy, document findings, and review findings. We 

interviewed investigators who conduct compliance reviews and their 

managers in FMCSA’s headquarters office, as well as in 7 of FMCSA’s 52 

field division offices that work with states, two of its four regional service 

centers that support division offices, and three state offices that partner 

with 3 of the FMCSA division offices in which we did our work.10 The 

division offices we reviewed partner with states that received 30 percent 

of the grant funds that FMCSA awarded to all states in fiscal year 2005 (the 

latest year for which data were available) through its primary grant 

program, the Motor Carrier Safety Assistance Program. Because we chose 

the seven states judgmentally (representing the largest grantees), we 

cannot project our findings nationwide. Reviewing a larger number of 

grantees would not have been practical due to resource constraints. We 

assessed the extent to which FMCSA conducts vehicle inspections and 

covers applicable safety regulations during compliance reviews by 

analyzing FMCSA data. 

To assess the extent to which FMCSA follows up with carriers with 

serious violations, we reviewed regulations and FMCSA policies directing 

how FMCSA must follow up and track these violators, analyzed data to 

 9

GAO, Internal Control: Standards for Internal Control in the Federal Government, 

GAO/AIMD-00-21.3.1 (Washington, D.C.: November 1999). 

10We did not interview managers or investigators in three of the seven states because they

do not conduct compliance reviews of interstate carriers, and we did not interview 

managers or investigators in one state because they did not respond to our attempts to 

contact them. 

Page 4 GAO-07-584 Motor Carrier Safety Oversight
determine if FMCSA had met these requirements, and held discussions 

with FMCSA officials. We also used data from MCMIS to assess the 

timeliness of FMCSA’s follow-up compliance reviews. To assess FMCSA’s 

implementation of the requirement to assess the maximum fine in certain 

cases, we compared FMCSA’s policy with the language of the act, held 

discussions with FMCSA officials, estimated the number of carriers that 

could have been assessed the maximum fine based on different definitions 

of a “pattern” of violations, and reviewed the Department of 

Transportation Inspector General’s report on the implementation of the 

policy.11 In assessing these various areas, we used the most recent data

available at the time we conducted our fieldwork. The period of analysis 

varies depending on the time permitted by law, policy, or our judgment for 

FMCSA’s follow-up. 

As part of our review, we assessed internal controls and the reliability of 

FMCSA’s data on motor carriers’ safety history and its compliance review 

and enforcement activities that were pertinent to this effort. While there 

are known problems with the quality of the crash data reported to FMCSA 

for use in SafeStat, we determined that the data were sufficiently reliable 

for our use, which was to assess whether different approaches to 

prioritizing carriers could lead to better targeting of carriers that 

subsequently have high crash rates. We conducted our work from 

February 2006 through August 2007 in accordance with generally accepted 

government auditing standards. (See app. IV for additional information on 

our scope and methodology.) 

By and large, FMCSA does a good job of identifying carriers that pose high 

crash risks for subsequent compliance reviews, ensuring the thoroughness 

and consistency of those reviews, and following up with high-risk carriers. 

FMCSA’s policy for prioritizing carriers for compliance reviews based on 

their SafeStat scores leads FMCSA to conduct compliance reviews on 

many high-risk carriers but not on other higher risk ones. Our analysis 

indicates that modifications to the policy could result in the selection of

carriers with a higher aggregate crash risk than are selected using the 

current policy. Currently, carriers must score among the worst 25 percent 

Results in Brief 

 11U.S. Department of Transportation Office of Inspector General, Significant

Improvements in Motor Carrier Safety Program Since 1999 Act but Loopholes for Repeat 

Violators Need Closing, Report MH-2006-046 (Washington, D.C.: Apr. 21, 2006). 

Page 5 GAO-07-584 Motor Carrier Safety Oversight
of carriers in at least two of SafeStat’s four evaluation areas to receive

high priority for a compliance review. Using data from FMCSA’s June 2004 

SafeStat categorization, we found that the 492 carriers that scored among 

the worst 5 percent of carriers in the accident safety evaluation area—an

area that, by itself, FMCSA gives low priority for compliance reviews—had 

an aggregate rate of subsequent crashes that was more than twice as high

as that of the 4,989 carriers to which FMCSA gave high priority.12 This 

suggests that FMCSA could target a higher risk group of carriers for 

compliance reviews by changing its prioritization policy so that high 

priority is also assigned to carriers that score among the worst 5 percent 

of carriers in the accident area. We recognize that giving such carriers high

priority for a compliance review would increase FMCSA’s and the states’ 

compliance review workloads unless FMCSA were to make another 

change to its prioritization rules that resulted in removing the same 

number of carriers from the high-priority categories A and B that had 

lower crash rates than the ones added. FMCSA officials told us that the 

agency plans to assess whether giving high priority to carriers that 

perform very poorly in the accident evaluation area alone would be an

effective use of its resources. Furthermore, as part of a reform initiative 

aimed at improving how the agency identifies and deals with unsafe 

carriers, called the Comprehensive Safety Analysis 2010, FMCSA is 

considering replacing SafeStat with a new tool by 2010. While the new tool

may use some of the same data included in SafeStat, such as carriers’ 

crash rates and driver and vehicle violations identified during compliance 

reviews and roadside inspections, it may also consider additional 

information from crash reports, such as whether driver fatigue or a lack of

driver experience was cited as a causal or contributing factor.

FMCSA’s management of its compliance reviews meets our standards for 

internal controls, thereby promoting thoroughness and consistency. 

FMCSA records its compliance review policies and procedures in an 

electronic operations manual and distributes the manual to investigators 

and managers in FMCSA’s 52 division offices and in the offices of its 56 

 12We applied the SafeStat model to retrospective data. Because of changes to the MCMIS 

crash file over the past 2 years, our number does not correspond exactly to the number of 

carriers identified by FMCSA as high risk on June 25, 2004. Had all crash data been 

reported within 90 days of when the crashes occurred, 182 of the carriers identified by 

SafeStat as highest risk would have been excluded (because other carriers had higher crash 

risks), and 481 carriers that were not originally designated as posing high crash risks would 

have scored high enough to be considered high risk, resulting in a net addition of 299

carriers. 

Page 6 GAO-07-584 Motor Carrier Safety Oversight
state and territorial partners (hereafter called state partners).13 FMCSA 

also provides training to investigators on these policies and procedures, 

including initial classroom training, on-the-job training, and ad hoc training

on new policies and procedures. Many investigators we spoke with 

generally found both the electronic manual and the training to be effective 

means of communicating policies and procedures. FMCSA and state 

investigators use an information system to document the results of the 

compliance reviews. This information system supports thoroughness and

consistency by alerting investigators if they are not following key policies 

or if data appear suspect; the system also provides managers with readily 

available data to review. Managers in the division offices, states, and 

FMCSA’s service centers use monthly activity reports to monitor 

performance at the investigator level, including the number of reviews 

completed and the number and types of violations identified. The service 

centers also conduct triennial reviews of the compliance review activities

of each division and state office. In 2002, FMCSA performed an 

agencywide review of its compliance review program and made several 

improvements based on the findings of this review. One such improvement 

was to discourage repeat visits to high-risk motor carriers that had 

received an unsatisfactory rating during their last compliance review 

within the past 12 months because the agency believed that not enough 

time had elapsed to show whether safety improvements had taken effect.

For the most part, FMCSA and state investigators cover the nine major 

applicable areas of the safety regulations (e.g., driver qualifications and 

vehicle repair and maintenance) in 95 percent or more of compliance 

reviews, demonstrating thoroughness and consistency. 

FMCSA follows up with many carriers with serious safety violations, but it 

does not assess maximum fines against all of the serious violators that we 

believe the law requires. FMCSA followed up with almost all the 1,196 

carriers that received a proposed safety rating of unsatisfactory following 

a compliance review that was completed in fiscal year 2005 to ensure that 

these carriers either made safety improvements that resulted in an 

upgraded final safety rating or were placed out of service. For example, 

FMCSA upgraded the safety ratings of 881 carriers primarily on the basis 

of safety improvements it identified during follow-up compliance reviews 

and reviews of documentary evidence of improvements submitted by 

 13FMCSA partners with each of the 50 states, the District of Columbia, and the U.S. 

territories of American Samoa, Guam, the Northern Marianas, Puerto Rico, and the Virgin 

Islands. 

Page 7 GAO-07-584 Motor Carrier Safety Oversight
carriers. FMCSA assigned a final rating of unsatisfactory to 312 of the 

remaining carriers, and placed 309 of them out of service. FMCSA 

monitors carriers to identify those that are violating out-of-service orders, 

but in fiscal years 2005 and 2006, it cited only 36 of 677 carriers that its 

monitoring showed had a roadside inspection or crash while subject to an 

out-of-service order. An FMCSA official told us that some of the 677 

carriers, such as carriers that were operating intrastate,14 may not have

been violating the out-of-service order, and that FMCSA did not have

enough resources to determine whether each of the carriers was violating 

the out-of-service order. With regard to fines against carriers, we found 

that while FMCSA assesses maximum fines against carriers that repeat a 

serious violation, it does not, as we believe federal law requires, assess 

maximum fines against carriers with a pattern of serious violations. The 

law requires FMCSA to assess maximum fines against carriers in both 

situations. The annual number of carriers that would be subject to 

maximum fines under a definition of pattern that is consistent with the law 

varies greatly depending on the definition—for the eight definitions that 

we assessed, the number of such carriers in fiscal year 2006 varied from 7 

to 3,348.15 In addition, FMCSA assesses maximum fines only for the third 

instance of a violation. We read the statute as requiring FMCSA to assess 

the maximum fine if a serious violation is repeated once—not only after it

is repeated twice. 

We are recommending that FMCSA (1) select carriers with very poor 

scores in the accident safety evaluation area for compliance reviews, 

regardless of their scores in the other areas; (2) establish reasonable time 

frames within which it conducts follow-up compliance reviews on carriers 

rated conditional; and (3) revise its implementation of the requirement to 

assess maximum fines to meet our interpretation of the applicable law. We 

provided a draft of this report to the Department of Transportation for its 

review and comment. The department did not offer overall comments on 

the draft report. It said that it would assess the efficacy of the first 

recommendation, but it did not comment on the other recommendations. 

It offered several technical comments, which we incorporated where 

appropriate.

 14Except for carriers of hazardous materials, FMCSA does not have the authority to 

prohibit motor carriers from operating intrastate. 

15These eight definitions were chosen to illustrate the effect of different potential 

definitions of pattern. 

Page 8 GAO-07-584 Motor Carrier Safety Oversight
The interstate commercial motor carrier industry, primarily the trucking 

industry, is an important part of the nation’s economy. Trucks transport 

over 11 billion tons of goods, or about 60 percent of the total domestic 

tonnage shipped.16 Buses also play an important role, transporting an 

estimated 860 million passengers in 2005. FMCSA estimates that there are 

711,000 interstate commercial motor carriers, about 9 million trucks and 

buses, and about 10 million drivers. Most motor carriers are small; about 

51 percent operate one vehicle, and another 31 percent operate two to four 

vehicles. Carrier operations vary widely in size, however, and some of the 

largest motor carriers operate upwards of 58,000 vehicles. Carriers 

continually enter and exit the industry. Since 1998, the industry has 

increased in size by an average of about 29,000 interstate carriers per year.

In the United States, commercial motor carriers account for fewer than 5 

percent of all highway crashes, but these crashes result in about 13 

percent of all highway deaths, or about 5,500 of the approximately 43,000 

highway fatalities that occur nationwide annually. In addition, on average, 

about 160,000 of the approximately 3.2 million highway injuries per year 

involve motor carriers. The fatality rate for trucks has generally decreased 

over the past 30 years but has been fairly stable since 2002. The fatality

rate for buses decreased slightly from 1975 to 2005, but it has more annual 

variability than the fatality rate for trucks due to a much smaller total 

number of vehicle miles traveled. (See fig. 1.) 

Background 

 16This figure is from 2002, the most recent year for which data are available. 

Page 9 GAO-07-584 Motor Carrier Safety Oversight
Figure 1: Commercial Motor Vehicle Fatality Rate, 1975 to 2005 

Notes: Fewer buses are involved in fatal or nonfatal accidents than large trucks, but bus accidents 

tend to involve more people. 

The latest year for which data were available was 2005. 

In an attempt to reduce the number and severity of crashes involving large 

trucks, FMCSA was established by the Motor Carrier Safety Improvement 

Act of 1999. FMCSA assumed almost all of the responsibilities and 

personnel of the Federal Highway Administration’s Office of Motor 

Carriers. The agency’s primary mission is to reduce the number and 

severity of crashes involving large trucks and buses. It carries out this 

mission by (1) issuing, administering, and enforcing federal motor carrier 

safety regulations and hazardous materials regulations; (2) providing 

education and outreach for motor carriers and drivers on the safety 

regulations and hazardous materials regulations; (3) gathering and 

analyzing data on motor carriers, drivers, and vehicles; (4) developing

information systems to improve the transfer of data; and (5) researching 

new methods and technologies to enhance motor carrier safety. 

FMCSA relies heavily on the results of compliance reviews to determine 

whether carriers are operating safely and, if not, to take enforcement 

action against them. (See fig. 2.) FMCSA conducts these on-site reviews to 

0

1

2

3

4

5

6

7

8

9

10

1975 1980 1985 1990 1995 2000 2005

Fatalities per 100 million vehicle miles traveled

Source: GAO analysis of Department of Transportation data.

Year

Buses

Trucks

Page 10 GAO-07-584 Motor Carrier Safety Oversight
determine carriers’ compliance with safety regulations that address areas 

such as testing drivers for alcohol and drugs, insurance coverage, crashes, 

driver qualifications, driver hours of service, vehicle maintenance and 

inspections, and transportation of hazardous materials. Due to resource 

constraints, FMCSA and its state partners are able to conduct compliance 

reviews on only about 2 percent of the nation’s estimated 711,000 

interstate motor carriers each year. It is FMCSA’s policy to target these 

reviews at carriers that have been assessed by SafeStat as having the 

highest risk of crashes, have been the subject of a safety-related complaint 

submitted to FMCSA, have been involved in a fatal accident, have 

requested an upgraded safety rating based on safety improvements, or 

have been assigned a safety rating of conditional following a previous 

compliance review. 

Page 11 GAO-07-584 Motor Carrier Safety Oversight
Figure 2: FMCSA’s Safety Oversight Approach

Compliance review

(selection for compliance

review based on priority)

Conditional Unsatisfactory

Safety rating

Carrier ordered to

cease operations

Fines and other

enforcement actions

Sources: GAO and FMCSA.

Data inputs to SafeStat model 

 • Crashes

 • Violations from roadside inspections

 • Violations from compliance reviews

 • Moving violations

 • Closed enforcement cases

 

Accident safety

evaluation area Vehicle safety

evaluation area

Driver safety

evaluation area

Safety management safety evaluation area

SafeStat model

SafeStat compliance review prioritization

Low priority for

compliance review

(SafeStat categories D-H)

High priority for

compliance review

(SafeStat categories A-B)

By policy

At FMCSA discretion

At carrier’s request

Satisfactory

Medium priority for

compliance review

(SafeStat category C)

Other triggers for

compliance reviews

 • Complaints

 • Fatal accidents

 • Carrier request 

Based largely on the number and severity of violations that it identifies 

during compliance reviews, FMCSA assigns carriers safety ratings that 

determine whether they are allowed to continue operating. FMCSA can 

take a range of enforcement actions against carriers with violations, 

including 

Page 12 GAO-07-584 Motor Carrier Safety Oversight
• issuing notices of violation informing carriers of identified violations and

indicating that additional enforcement action may be taken if the 

violations are not corrected; 

• issuing compliance orders directing carriers to perform certain actions 

that FMCSA considers necessary to bring the carrier into compliance with

regulations;

• assessing fines for violations of the safety regulations; fines require 

carriers to pay a specific dollar amount to FMCSA; 

• placing carriers or drivers out of service for unsatisfactory safety 

performance, failure to pay a fine, or imminently hazardous conditions or

operations; 

• revoking the operating authority of carriers for failure to carry the 

required amount of insurance coverage; 

• pursuing criminal penalties in some instances when knowing and willful 

violations can be proved; and 

• seeking injunctions from a court for violations of a final order such as an 

out-of-service order. 

FMCSA has 52 division offices that partner with the 56 recipients of its 

Motor Carrier Safety Assistance Program grants. FMCSA also funds and 

oversees enforcement activities, including compliance reviews, at the state 

level through this grant program. The program was appropriated $188 

million, or about 38 percent, of FMCSA’s $501 million appropriation for 

fiscal year 2006. In fiscal year 2006, FMCSA conducted 9,719 compliance 

reviews, and its state partners conducted 5,463 compliance reviews. 

SafeStat assesses carriers’ risks relative to all other carriers based on 

safety indicators such as their crash rates and safety violations identified 

during roadside inspections and during prior compliance reviews. A 

carrier’s score is calculated on the basis of its performance in the 

following four safety evaluation areas: 

• The accident area reflects a carrier’s crash history relative to other motor 

carriers based on data from states and MCMIS. 

• The driver area reflects a carrier’s driver-related safety performance and 

compliance relative to other motor carriers based on driver violations 

Page 13 GAO-07-584 Motor Carrier Safety Oversight
identified during roadside inspections and compliance reviews. 

• The vehicle area reflects a carrier’s vehicle-related safety performance and 

compliance relative to other motor carriers based on vehicle-related 

violations identified during roadside inspections and compliance reviews. 

• The safety management area reflects the carrier’s safety management 

performance relative to other motor carriers based on 

safety-management-related violations (such as failing to implement a drug 

or alcohol testing program) and hazardous-materials-related violations 

identified during compliance reviews and on closed enforcement cases 

resulting from compliance reviews. 

A motor carrier’s score is based on the carrier’s relative ranking, indicated 

as a value, in each of the four safety evaluation areas. This value can range 

from 0 to 100 in each area, and any value of 75 or greater is considered 

deficient. Any value of less than 75 is not considered deficient and is not 

used in calculating a SafeStat score. FMCSA assigns categories to carriers 

ranging from A to H according to their performance in each of the safety

evaluation areas. (See table 1.) Although a carrier may receive a value in 

any of the four safety evaluation areas, the carrier receives a SafeStat 

score only if it is deficient in two or more safety evaluation areas. The 

calculation used to determine a motor carrier’s SafeStat score is 

SafeStat score = 2 x accident value + 1.5 x driver value + vehicle value + 

safety management value 

As shown in the formula, the accident and driver areas have 2.0 and 1.5 

times the weight, respectively, of the vehicle and safety management 

areas. FMCSA assigned more weight to these areas because accidents and

driver violations correlate relatively better with future crash risk. In 

consultation with state transportation officials, insurance industry 

representatives, safety advocates, and the motor carrier industry, FMCSA 

used its expert judgment and professional knowledge to assign these 

weights, rather than determining them through a statistical approach, such

as regression modeling.

Page 14 GAO-07-584 Motor Carrier Safety Oversight
Table 1: SafeStat Categories

Category Condition

Priority for 

compliance review

Deficient in two or more areas

A Deficient in all four safety evaluation areas or deficient in three safety evaluation areas 

that result in a weighted SafeStat score of 350 or more 

High 

B Deficient in three safety evaluation areas that result in a weighted SafeStat score of less 

than 350 or deficient in two safety evaluation areas that result in a weighted SafeStat 

score of 225 or more 

High 

C Deficient in two safety evaluation areas that result in a weighted SafeStat score of less 

than 225 

Medium 

Deficient in one area only 

D Deficient in the accident safety evaluation area (area value between 75-100) Low 

E Deficient in the driver safety evaluation area (area value between 75-100) Low 

F Deficient in the vehicle safety evaluation area (area value between 75-100) Low 

G Deficient in the safety management safety evaluation area (area value between 75-100) Low 

Not deficient in any area 

H Not deficient in any of the safety evaluation areas Low 

Source: GAO summary of FMCSA data. 

Based on the results of a compliance review, FMCSA assigns the carrier a 

safety rating of satisfactory, conditional, or unsatisfactory. The safety 

rating, which is distinct from a carrier’s SafeStat category, reflects 

FMCSA’s determination of a carrier’s fitness to operate safely. FMCSA 

issues out-of-service orders to carriers rated unsatisfactory, and these 

carriers are not allowed to resume operating until they make 

improvements that result in an upgraded safety rating. Carriers rated 

conditional are allowed to continue operating, but FMCSA aims to conduct 

follow-up compliance reviews on these carriers. FMCSA assigns safety 

ratings based on a carrier’s performance in six areas. (See table 2.) One 

area is the carrier’s accident rate, and the other five areas involve its 

compliance with regulations. The five regulation-based areas are (1) 

minimum insurance coverage and procedures for handling and evaluating 

accidents; (2) drug and alcohol use and testing, commercial driver’s 

license standards, and driver qualifications; (3) driver hours of service; (4) 

vehicle parts and accessories necessary for safe operation; inspection, 

repair, and maintenance of vehicles; and (5) transportation of hazardous 

materials. 

Page 15 GAO-07-584 Motor Carrier Safety Oversight
Table 2: How FMCSA Determines Carrier Safety Ratings Based on Ratings in Six 

Safety Areas

A carrier receives a 

safety rating of if it receives

this number of

unsatisfactory 

safety area ratings and 

this number of

conditional safety 

area ratings

Satisfactory 0 2 or fewer 

Conditional 0 more than 2 

Conditional 1 2 or fewer 

Unsatisfactory 1 more than 2 

Unsatisfactory 2 or more 0 or more 

Source: GAO presentation of FMCSA information. 

Regardless of a carrier’s safety rating, FMCSA can assess a fine against a

carrier with violations, and it is more likely to assess higher fines when 

these violations are serious. FMCSA uses a tool to help it determine the 

dollar amounts of its fines. Federal law requires FMCSA to assess the 

maximum allowable fine against a carrier for each serious violation of 

federal motor carrier safety and commercial driver’s license laws if the 

carrier is found to have a pattern of such violations or a record of 

previously committing the same or a related serious violation. 

Page 16 GAO-07-584 Motor Carrier Safety Oversight
SafeStat identifies many carriers that pose high crash risks.17 However, 

modifications to FMCSA’s policy that carriers have to score among the 

worst 25 percent of carriers in two or more safety evaluation areas to 

receive high priority for a compliance review and focusing more on crash 

risk could result in the selection of carriers with a higher aggregate crash 

risk.18 FMCSA recognizes that SafeStat can be improved, and as part of its 

Comprehensive Safety Analysis 2010 reform initiative, which is aimed at 

improving its processes for identifying and dealing with unsafe carriers, 

the agency is considering replacing SafeStat with a new tool by 2010. 

FMCSA’s Policy for 

Prioritizing 

Compliance Reviews 

Targets Many HighRisk Carriers, but 

Changes to the Policy 

Could Target Carriers 

with Even Higher Risk 

FMCSA’s Policy for 

Prioritizing Compliance 

Reviews Leads the Agency 

to Conduct Compliance 

Reviews on Many HighRisk Carriers but Not on 

Other Higher Risk Ones 

FMCSA’s policy for prioritizing carriers for compliance reviews based on 

their SafeStat scores results in FMCSA’s conducting compliance reviews 

on carriers with a higher aggregate crash risk than carriers that are not 

selected. As a result, FMCSA’s prioritization policy has value as a method

for targeting high-risk carriers. But changes to the policy could result in 

targeting carriers with an even higher aggregate crash risk. According to 

our analysis of SafeStat’s June 2004 categorization of carriers, the 4,989

carriers that received high priority for a compliance review (SafeStat 

categories A or B) had a higher aggregate crash risk (102 crashes per 1,000

vehicles in the 18 months following the SafeStat categorization) than the

remaining 617,034 carriers (27 crashes per 1,000 vehicles). (See table 3.) 

However, the 2,464 carriers that scored among the worst 25 percent of 

carriers in the accident evaluation area alone (SafeStat category D) had a 

slightly higher aggregate crash risk (112 crashes per 1,000 vehicles) than 

did the carriers in SafeStat categories A or B. Furthermore, the 1,090 

carriers that scored among the worst 10 percent and the 492 carriers that 

scored among the worst 5 percent of carriers in the accident area (and did 

not score among the worst 25 percent of carriers in any other area) had 

even higher aggregate rates of 148 and 213 crashes per 1,000 vehicles, 

respectively.

 17We found that SafeStat is about twice as effective in identifying these high-risk carriers 

than is randomly selecting them for compliance reviews. See GAO-07-585. 

18We are defining “crash risk” as the number of crashes for the carrier per 1,000 vehicles in 

the 18 months following the SafeStat categorization. By “aggregate” crash risk, we mean 

the total number of crashes for all carriers in the group per 1,000 vehicles in the 18 months 

following the SafeStat categorization. 

Page 17 GAO-07-584 Motor Carrier Safety Oversight
Table 3: Crash Rates of Motor Carriers in Various SafeStat Categories in the 18 Months following the June 2004 SafeStat 

Categorization 

SafeStat 

category(ies) Description 

Crash 

ratea

Priority for 

compliance 

review

Number of

motor 

carriersb

A Deficient in three or four safety evaluation areas; 

SafeStat score 350 or more 

107 High 631

B Deficient in two or three safety evaluation areas; SafeStat 

score 225 or more, and less than 350 

101 High 4,358

Subtotal A+B See above 102 High 4,989

C Deficient in two safety evaluation areas; SafeStat score 

less than 225 

48 Medium 3,683

D Accident safety evaluation area value 75 or more 112 Low 2,464

Subset of D Accident safety evaluation area value 90 or more 148 Low 1,090

Subset of D Accident safety evaluation area value 95 or more 213 Low 492

All categories other than A 

and B 

27 Medium or low 617,034

Source: GAO analysis of FMCSA data. 

a

Crash rates are crashes per 1,000 vehicles in the 18 months following the June 2004 SafeStat 

categorization. As discussed in appendix IV, we used data from FMCSA’s June 2004 SafeStat 

categorization because these were the latest available data that we could use at the time of our 

analysis to obtain relatively complete data on carriers’ numbers of crashes in the 18 months following

the categorization. 

b

The table includes only those carriers listed as having one or more vehicles. 

Our analysis suggests that FMCSA’s targeting of high-risk carriers could be 

enhanced by giving high priority for a compliance review to carriers that 

score among the worst 25, 10, or 5 percent of carriers in the accident 

evaluation area alone. We recognize that giving such carriers high priority 

for a compliance review would increase FMCSA’s and the states’ 

compliance review workloads unless FMCSA were to make another 

change to its prioritization policy that resulted in removing the same 

number of carriers from the high-priority categories A and B.19 For 

example, if FMCSA had given high priority to the 492 carriers that scored 

among the worst 5 percent of carriers in the accident evaluation area in 

June 2004, it could have removed the 492 carriers in categories A or B with 

the lowest SafeStat score in order to hold its and the states’ compliance 

review workloads constant. The lowest-scoring carriers in categories A 

 19To give a sense of FMCSA’s and the states’ compliance review workload, in fiscal year 

2006, FMCSA and the states conducted 15,182 compliance reviews; about half of these 

were on carriers that were in SafeStat categories A or B. 

Page 18 GAO-07-584 Motor Carrier Safety Oversight
and B had an aggregate crash risk of 65 crashes per 1,000 vehicles, less 

than one-third the crash risk of the carriers that could have replaced them

(214 crashes per 1,000 vehicles). 

We also found that carriers that scored among the worst 25 percent, 10

percent, or 5 percent of carriers in either the driver, vehicle, or safety 

management areas (and did not score among the worst 25 percent of 

carriers in any other area) had a lower aggregate crash risk than carriers in 

SafeStat categories A or B. Of these various groups of carriers with poor 

performance in a single area, the carriers that scored among the worst 10 

percent of carriers in the driver area had the highest aggregate crash risk 

(70 crashes per 1,000 vehicles). 

A Regression Model

Performs Better Than 

Current SafeStat Model 

and the Prioritization 

Approach We Developed 

In our June 2007 report, we estimated that FMCSA could improve 

SafeStat’s performance by about 9 percent by using a statistical regression 

model approach to weight the accident, driver, vehicle, and safety 

management evaluation areas instead of its current approach, which is 

based on expert judgment.20 Employing this approach would have allowed 

FMCSA to identify carriers with almost twice as many crashes in the 

following 18 months as those carriers identified under its current 

approach. We found that although the driver, vehicle, and safety 

management evaluation area scores are correlated with the future crash 

risk of a carrier, the accident evaluation area correlates the most with 

future crash risk and should be weighted more heavily than the current 

SafeStat formula weights this area. These results corroborate studies 

performed by the Volpe National Transportation Systems Center and Oak 

Ridge National Laboratory, the latter of which also employed statistical 

approaches. (See app. I for a discussion of these studies.) 

We believe that our regression model approach from our June 2007 report 

is preferable to the prioritization approach we developed in this report 

because it provides for a systematic assessment of the relative

contributions of accidents and driver, vehicle, and safety management 

violations. That is, by its very nature, the regression model approach looks 

for the “best fit” in identifying the degree to which prior accidents and 

driver, vehicle, and safety management violations identify the likelihood of

carriers having crashes in the future, compared with the current SafeStat

approach and the prioritization approach we developed for this report, 

 20GAO-07-585. 

Page 19 GAO-07-584 Motor Carrier Safety Oversight
both of which use expert judgment to establish the relationship among the 

four evaluation areas. In addition, because the regression model could be

run monthly—as is the current SafeStat model—any change in the degree

to which accidents and driver, vehicle, and safety management violations 

better identify future crashes will be automatically considered as different 

weights are assigned to the four evaluation areas. This is not the case with

the current SafeStat model, in which the evaluation area weights generally 

remain constant over time.21 Thus, the systematic assessment and the 

automatic updating of evaluation area weights using a regression model 

approach better ensure the targeting of carriers that pose high crash 

risks—both currently and in the future. 

We compared the performance of our regression model approach to the 

current SafeStat model and to two alternative approaches that employ the 

current SafeStat model approach (with the current weighting of evaluation

areas) but give higher priority to some carriers in category D (carriers that 

scored among the worst 25 percent of carriers in only the accident 

evaluation area). The two alternatives were substituting carriers in the 

worst 5 percent of the accident evaluation area for carriers in SafeStat 

categories A and B with (1) the lowest accident area scores and (2) the 

lowest overall SafeStat numerical scores.22 The regression model approach 

performed better than the current SafeStat approach and at least as well as 

the alternatives discussed in this report, in terms of identifying carriers 

that experienced a higher aggregate crash rate or a greater number of 

crashes. (See table 4.) For example, the regression model approach 

identified carriers with an average of 111 crashes per 1,000 vehicles over 

an 18-month period compared with the current SafeStat approach that 

identified carriers for compliance reviews with an average of 102 crashes 

per 1,000 vehicles. The regression model approach also performed at least 

as well as the alternatives discussed in this report in terms of identifying 

carriers with the highest aggregate crash rate and much better than the 

alternatives in identifying carriers with the greatest number of crashes. 

Finally, the alternatives discussed in this report were superior to the 

results of FMCSA’s current prioritization policy in terms of identifying 

 21The weights on the safety evaluation areas have remained unchanged since September

1999, when the weight on the driver area was increased from 1.0 to 1.5.

22These alternatives are for use as examples only. FMCSA could choose other cut points, 

such as carriers in the worst 10, 15, or 20 percent of the accident evaluation area. Our 

analyses show that these other alternatives provided superior results to the current 

SafeStat approach. 

Page 20 GAO-07-584 Motor Carrier Safety Oversight
carriers with both a higher aggregate crash rate and a greater number of 

crashes. 

Table 4: Regression Model Approach Compared with Refined Prioritization

Approach and with Current SafeStat Approach

Approach Crash ratea

Number of 

crashes in 18

months

Regression model approach 111.4 19,580

Refined prioritization approach alternative 1:

substitute SafeStat category D (accident) carriers for 

category A and B carriers with the lowest overall 

SafeStat scores 111.0 10,682

Refined prioritization approach alternative 2:

substitute SafeStat category D (accident) carriers for 

category A and B carriers with the lowest accident 

area scores 107.8 10,887

Current SafeStat approach 102.2 10,076

Source: GAO analysis of FMCSA data. 

Note: The relationship between the number of crashes and the crash rate is not linear because the 

different analyses identified carriers with different fleet sizes as posing a high crash risk. 

a

Crash rates are crashes per 1,000 vehicles in the 18 months following the June 2004 SafeStat 

categorization. 

FMCSA officials told us that the agency plans to assess whether the 

approach developed in this report—giving high priority to carriers that 

perform very poorly in only the accident evaluation area (such as those 

that scored among the worst 5 percent)—would be an effective use of its

resources. However, FMCSA officials expressed concern that adopting our 

regression model approach would reduce the effectiveness of FMCSA’s 

compliance review program by targeting many compliance reviews at 

carriers that, despite high crash rates, have good compliance records. 

FMCSA believes that compliance reviews of such carriers, compared with 

compliance reviews of carriers in SafeStat categories A or B (carriers that, 

by definition, have a history of noncompliance), have less potential to 

reduce accidents. FMCSA said that this is because compliance reviews are 

designed to reduce crashes by identifying safety violations that some 

carriers then correct, and compliance reviews of carriers with good 

compliance records but high crash rates have historically identified fewer 

serious violations than compliance reviews of carriers in SafeStat 

categories A and B. FMCSA officials told us that, as part of its 

Comprehensive Safety Analysis 2010 reform initiative, the agency is 

evaluating the potential for new ways to address motor carriers that are 

having crashes, but that it believes are not good candidates for the 

Page 21 GAO-07-584 Motor Carrier Safety Oversight
compliance review tool. (See the discussion on FMCSA’s Comprehensive 

Safety Analysis 2010 reform initiative in a subsequent section.)

We agree with FMCSA that the use of our model could tilt enforcement 

heavily toward carriers with high crash rates and away from carriers with 

compliance problems. We believe that use of the model would enhance 

motor carrier safety, even if it resulted in FMCSA reviewing carriers with 

good compliance records. FMCSA’s mission—and the ultimate purpose of

compliance reviews—is to reduce the number and severity of truck and 

bus crashes. As previously discussed, we found that while driver, vehicle, 

and safety management evaluation area scores are correlated with the 

future crash risk of a carrier, high crash rates are a stronger predictor of 

future crashes than is poor compliance with safety regulations. These facts 

suggest that FMCSA would improve motor carrier safety more by targeting 

carriers with high crash rates, even if they have better compliance records, 

than by targeting carriers in SafeStat categories A and B with significantly 

lower crash rates but with worse compliance records. The missing piece in 

the puzzle is that FMCSA does not have a good understanding of why 

some carriers, despite good compliance records, have high crash rates; 

how compliance reviews affect their crash rates; and what other 

approaches may be effective in reducing their crash rates. We believe that 

developing this understanding would be a natural outgrowth of 

implementing our regression model approach. 

FMCSA officials also said that placing more emphasis on the accident 

evaluation area would increase emphasis on the least reliable type of data

used by SafeStat—crash data—and in so doing, it would increase the 

sensitivity of the results to crash data quality issues. However, our June 

2007 report found that FMCSA has made a considerable effort to improve 

the reliability of crash data. That report also concluded that as FMCSA 

continues its efforts to have states improve crash data, any sensitivity of 

results from our regression model approach to crash data quality issues 

should diminish. 

FMCSA officials were also concerned that our issuing two reports on 

SafeStat within several months of each other could be interpreted as an 

indictment of SafeStat and of FMCSA’s responsiveness to our June 2007 

report on this issue. This is not the case. SafeStat does a good job of 

identifying carriers that pose high crash risks. As we reported in June 

2007, we found that SafeStat is nearly twice as effective (83 percent better

than) as random selection in identifying carriers that pose high crash risks 

and, therefore, has value for improving safety. Nonetheless, we found that 

FMCSA’s policy for prioritizing compliance reviews could be improved by 

Page 22 GAO-07-584 Motor Carrier Safety Oversight
applying either our regression model approach or one of the prioritization 

approaches we developed in this report. While we believe that the 

regression model approach provides somewhat better safety results, we 

understand, as discussed in our June 2007 report, that it could require 

FMCSA to re-educate the motor carrier industry and others, such as safety 

advocates, insurers, and the public, about the new approach. We would 

prefer that FMCSA implement our recommendation that it use our 

regression model approach but adopting either our regression model 

approach or one of the prioritization approaches we developed in this 

report would, in our opinion, improve FMCSA’s targeting of high-risk 

carriers. The recommendation that we make in this report reflects this 

conclusion. Finally, FMCSA has been very helpful and responsive during 

both our—largely concurrent—reviews. 

FMCSA Has Acted to 

Address Data Quality 

Problems That Potentially 

Hinder SafeStat’s Ability to 

Identify High-Risk Carriers 

For our June 2007 report, we assessed the quality of the data used by 

SafeStat and the degree to which the quality of the data affects SafeStat’s 

identification of high-risk carriers, and we identified actions FMCSA has 

taken to improve the quality of the data used by SafeStat. We found that 

crash data reported by the states from December 2001 through June 2004 

have problems in terms of timeliness, accuracy, and completeness that 

potentially hinder FMCSA’s ability to identify high-risk carriers. Regarding 

timeliness, we found that including late-reported data had a small impact 

on SafeStat—had all crash data been reported within 90 days of when the 

crashes occurred, 182 of the carriers identified by SafeStat as highest risk 

would have been excluded (because other carriers had higher crash risks), 

and 481 carriers that were not originally designated as posing high crash 

risks would have scored high enough to be considered high risk, resulting 

in a net addition of 299 carriers (or 6 percent) to the original 4,989 carriers 

that the SafeStat model ranked as highest risk in June 2004. We were not 

able to quantify the effect of incomplete or inaccurate data on SafeStat’s 

ability to identify carriers that pose high crash risks, because doing so 

would have required us to gather crash records at the state level—an effort 

that was impractical. FMCSA has acted to improve the quality of SafeStat’s 

data by completing a comprehensive plan for data quality improvement, 

implementing an approach to correct inaccurate data, and providing 

grants to states for improving data quality, among other things. We could 

not quantify the effects of FMCSA’s efforts to improve the completeness or 

accuracy of the data for the same reason as just mentioned. (See app. II for 

a more detailed discussion of the quality of the data used by SafeStat.) 

Page 23 GAO-07-584 Motor Carrier Safety Oversight
As part of its Comprehensive Safety Analysis 2010, a reform initiative 

aimed at improving its processes for identifying and dealing with unsafe 

carriers and drivers, FMCSA is considering replacing SafeStat with a new 

tool by 2010. The new tool could take on greater importance in FMCSA’s 

safety oversight framework because the agency is considering using the 

tool’s assessments of carriers’ safety to determine whether carriers are fit 

to continue operating.23 In contrast, SafeStat’s primary use now is in 

prioritizing carriers for compliance reviews, and determinations of 

operational fitness are made only after the compliance reviews are 

completed. 

FMCSA Is Considering 

Replacing SafeStat with a 

New Tool by 2010 

While the new tool may use some of the same data included in SafeStat,

such as carriers’ crash rates and driver and vehicle violations identified 

during compliance reviews and roadside inspections, it may also consider 

a broader range of behavioral data related to crashes than does SafeStat. 

For example, the new tool may consider information from crash reports, 

such as whether driver fatigue, a lack of driver experience, a medical 

reason, a mechanical failure, shifting loads, or spilled or dropped cargo, 

were cited as causal or contributing factors. An FMCSA official told us 

that the agency is analyzing the relationship between these factors and 

crash rates to help it determine how the factors should be assessed and 

the relative weights to place on the factors. We believe that, compared 

with the expert-judgment-based approach that FMCSA used to select the

weights for SafeStat’s evaluation areas, this analytical approach has the

potential to better identify high-risk carriers. 

 23Based on results from its 2006 study of the causes of large truck crashes, which indicated 

that driver behavior rather than vehicle condition was the primary reason for most crashes,

FMCSA also plans to develop a tool to assess the safety status of individual drivers, along

with tools for dealing with unsafe drivers. 

Page 24 GAO-07-584 Motor Carrier Safety Oversight
FMCSA manages its compliance reviews in a fashion that meets our 

standards for internal control, thereby promoting thoroughness and 

consistency in the reviews.24 For example, it records its policies and 

procedures related to compliance reviews in an operations manual. 

FMCSA also provides investigators with classroom and on-the-job training 

on how to plan for and conduct compliance reviews. In addition, it 

employs an information system that documents the results of compliance 

reviews and allows FMCSA and state managers to review the compliance 

reviews for thoroughness, accuracy, and consistency. FMCSA uses several

approaches to monitor its compliance review program, including an 

agencywide review in 2002 that led to several changes in the program. 

FMCSA’s Management 

of Its Compliance 

Reviews Promotes 

Thoroughness and 

Consistency 

FMCSA Communicates Its 

Compliance Review 

Policies and Procedures 

through an Electronic 

Manual and Training 

FMCSA’s communication of its policies and procedures related to 

conducting compliance reviews meets our standards for internal control.

These standards state that an organization’s policies and procedures 

should be recorded and communicated to management and others within 

the entity who need it and in a form (e.g., clearly written and provided as a 

paper or electronic manual) and within a time frame that enables them to 

carry out their responsibilities. FMCSA records and communicates its 

policies and procedures electronically through its “Field Operations 

Training Manual” (hereafter called the operations manual), which it 

provides to all federal and state investigators and their managers. The 

operations manual includes guidance on how to prepare for a compliance 

review. For example, it tells investigators that they must download and 

review a report that includes information on the carrier’s accidents, 

drivers, and inspections, and it explains how this information can help the 

investigator focus the compliance review. It also specifies the minimum 

number of driver and vehicle maintenance records to be examined and the 

minimum number of vehicle inspections to be conducted during a 

compliance review. FMCSA aims to update its operations manual twice a 

year. It posts updates to the operations manual that automatically 

download to investigators and managers when they connect to the 

Internet. In between these updates, FMCSA communicates policy changes 

by e-mail. 

 24See GAO/AIMD-00-21.3.1. In assessing the extent to which FMCSA’s management of its

compliance reviews is consistent with our internal controls, we were not able to verify the 

statements made by FMCSA and state officials and investigators about their performance 

and management of compliance reviews because doing so was not practicable given our 

time and resource constraints. 

Page 25 GAO-07-584 Motor Carrier Safety Oversight
In addition to the operations manual, FMCSA provides training to 

investigators on its policies and procedures related to compliance reviews. 

FMCSA policy requires that investigators successfully complete classroom 

training and examinations before they conduct a compliance review. The 

training covers the safety and hazardous materials regulations and 

software tools used during compliance reviews. According to FMCSA 

officials, investigators then receive on-the-job training, which allows them 

to accompany an experienced investigator during compliance reviews. 

This training lasts until managers decide that the trainees are ready to 

complete a compliance review on their own, typically after 3 to 6 months 

on the job. Investigators can also take additional classroom training on 

specialized topics throughout their careers. Furthermore, according to 

FMCSA officials, FMCSA’s division offices hold periodic and ad hoc 

meetings to train investigators about policy changes related to compliance 

reviews. In addition, in commenting on a draft of this report, FMCSA noted

that it has an annual safety investigator certification process to ensure that 

only qualified personnel conduct compliance reviews. 

FMCSA Investigators Use 

an Information System to 

Document the Results of 

Compliance Reviews 

FMCSA’s documentation of compliance reviews meets our standards for 

internal control. These standards state that all transactions and other 

significant events should be clearly and promptly documented, and the 

documentation should be readily available for examination. This applies to

the entire process or life cycle of a transaction or event from the initiation 

and authorization through its final classification in summary records. The 

standards also state that control activities, including reviews of

information and system edit checks, should help to ensure that all 

transactions are completely and accurately recorded. FMCSA and state 

investigators use an information system to document the results of their 

compliance reviews, including information on crashes and any violations

of the safety regulations that they identify. This documentation is readily 

available to FMCSA managers, who told us that they review it to help 

ensure completeness and accuracy. FMCSA officials told us that the 

information system also helps ensure thoroughness and consistency by 

prompting investigators to follow FMCSA’s policies and procedures, such 

as requirements to meet a minimum sample size. The information system 

also includes checks for consistency and reasonableness and prompts 

investigators when the information they enter appears to be inaccurate. An

FMCSA manager told us that managers typically assess an investigator’s 

thoroughness by comparing the investigator’s rate of violations identified 

over the course of several compliance reviews with the average rate for 

investigators in their division office; a rate that is substantially below the 

average suggests insufficient thoroughness. Generally, FMCSA and state

Page 26 GAO-07-584 Motor Carrier Safety Oversight
investigators and managers said they found the information system to be 

useful. 

FMCSA Monitors the 

Performance of Its 

Compliance Reviews and 

Has Taken Actions to 

Address Identified Issues 

FMCSA’s performance measurement and monitoring of compliance review 

activities meet our standards for internal control. These standards state 

that managers should compare actual performance to planned or expected 

results and analyze significant differences. Monitoring of internal controls

should include policies and procedures for ensuring that the findings of 

audits and other reviews are promptly resolved. According to FMCSA and 

state managers and investigators, the managers review all compliance 

reviews in each division office and state to ensure thoroughness and 

consistency across investigators and across compliance reviews. The 

investigators we spoke with generally found these reviews to be helpful,

and several investigators said that the reviews helped them learn policies 

and procedures and ultimately perform better compliance reviews. 

FMCSA and state managers told us that they also use monthly reports to 

track the performance of investigators using measures such as the 

numbers of reviews completed and the rates of violations found. Managers 

generally found that these reports provide useful information on 

investigators’ performance, and several managers said that they use the

reports to help identify specific areas where an investigator needs 

additional coaching or training. However, several state managers said that 

monitoring of their investigators’ performance would be enhanced if they 

had access to FMCSA’s monthly report on their investigators; currently, 

states rely on their own custom reports. FMCSA told us that it plans to 

make its monthly report on state investigators available to state managers 

by October 2007. 

In addition to assessing the performance of individual investigators, 

FMCSA periodically assesses the performance of FMCSA division offices 

and state agencies, and it conducted an agencywide review of its 

compliance review program in 2002. According to officials at one of 

FMCSA’s service centers, the service centers lead triennial reviews of the 

compliance review and enforcement activities of each division office and 

its state partner. These reviews assess whether the division offices and 

state partners are following FMCSA policies and procedures, and they 

include an assessment of performance data for items such as number of 

compliance reviews conducted, rate of violations identified, and number 

of enforcement actions taken. The officials said that some reviews identify 

instances of deviations by division offices from FMCSA’s compliance 

review policies, but that only minor adjustments by the division offices are 

needed. The officials also said that the service centers compile best 

practices identified during the reviews and share these among the division 

Page 27 GAO-07-584 Motor Carrier Safety Oversight
offices and state partners. To ensure that concerns identified during the 

reviews are addressed, the officials said that the service centers monitor 

the quality of individual compliance reviews that lead to enforcement 

cases and the monthly reports on division office and state activities. The 

officials said that the service centers also check on responses to 

previously identified concerns during the triennial reviews. 

FMCSA’s agencywide review indicated that inconsistencies and 

bottlenecks in the compliance review process were reducing its efficiency

and effectiveness, and FMCSA made several changes in 2003 aimed at 

improving compliance review policies, procedures, training, software, and 

supporting motor carrier data. Examples of problems identified and 

actions taken are as follows: 

• FMCSA discouraged repeat visits to high-risk motor carriers that had 

received unsatisfactory ratings during their last compliance review within 

the past 12 months because the agency believed that not enough time had 

elapsed to show whether safety improvements had taken effect. 

• FMCSA discouraged safety investigators from their earlier practice of 

favoring violations of drug and alcohol regulations over violations of 

hours-of-service regulations when they choose which violations to 

document for enforcement because crash data and FMCSA’s survey of its 

field staff suggest that compliance with hours-of-service regulations is 

more important for safety. 

• FMCSA revised its operations manual to encourage FMCSA’s division 

offices to document the maximum number of areas of the regulations 

where major safety violations are discovered, rather than penalizing motor 

carriers for a few violations in a particular area at the expense of other 

areas. 

FMCSA’s review also concluded that most investigators were not 

following FMCSA’s policy requiring them to perform vehicle inspections as 

part of a compliance review if the carrier has not already received the 

required number of roadside vehicle inspections.

25 FMCSA has since 

changed its policy so that inspecting a minimum number of vehicles is no

longer a strict requirement—if an investigator is unable to inspect the 

minimum number of vehicles, he or she must explain why in the 

 25The required number of inspections was based on the number of vehicles operated by the 

carrier. 

Page 28 GAO-07-584 Motor Carrier Safety Oversight
compliance review report.26 FMCSA told us that, as part of their review of

individual compliance reviews, division office managers ensure that when

compliance reviews have fewer than the minimum number of vehicle

inspections, investigators provide adequate justification in their reports. 

We did not verify this statement because we did not have enough time or 

resources. We did, however, assess the extent to which compliance 

reviews included the minimum number of vehicle inspections. In fiscal 

year 2005, FMCSA and its state partners conducted 7,436 compliance 

reviews on carriers that had not already received the minimum number of 

vehicle inspections; of these, only 254 compliance reviews (3 percent) 

included the minimum number of vehicle inspections. 

FMCSA’s review also found that investigators considered inspections to be 

the one aspect of compliance reviews, other than licensing and insurance 

verification, that had the smallest effect on carriers’ safety performance. 

FMCSA’s review team recommended that FMCSA establish new criteria 

for conducting vehicle inspections during compliance reviews, and 

suggested that inspections could be made optional. In contrast, in 2002, 

the National Transportation Safety Board (the Safety Board) 

recommended that FMCSA require that all compliance reviews include 

vehicle inspections. The Safety Board based its recommendation on its 

belief that the vehicles that receive roadside inspections may be less likely 

to have violations than the vehicles that could be inspected during a 

compliance review. In July 2006, FMCSA responded that implementing this 

recommendation would be imprudent because it would divert attention 

from driver and other safety factors, and FMCSA’s recent study of the 

causes of large truck crashes indicates the importance of driver factors, 

such as driving too fast for conditions and driver fatigue. FMCSA has not 

changed its policy, but an FMCSA official told us that under the 

operational model that FMCSA has proposed for its Comprehensive Safety

Analysis 2010 reform initiative, vehicle inspections during compliance 

reviews would be optional. FMCSA also told us that it is developing a 

policy that would allow investigators conducting compliance reviews to 

inspect vehicles that operate in intrastate commerce. FMCSA believes that

this policy will increase the number of compliance reviews with the 

minimum number of vehicle inspections. 

 26An inspector would not be able to inspect the minimum number of vehicles if, for

example, fewer than the minimum number of vehicles were available on-site for inspection. 

Page 29 GAO-07-584 Motor Carrier Safety Oversight
Finally, FMCSA’s review found that although investigators generally 

sampled the number of carrier records required by FMCSA’s policies, the 

number of undersized samples of drivers’ work hour logs was a cause for 

concern. The review said that a lack of clarity in FMCSA’s requirements 

for how carriers must document drivers’ hours was likely resulting in 

some carriers having too few records to sample. FMCSA is working to 

clarify its documentation requirements, but it has not set a date for 

completing this task. 

From fiscal year 2001 through fiscal year 2006, each of the nine major 

applicable areas of the safety regulations was covered by most of the 

approximately 76,000 compliance reviews conducted by FMCSA and the 

states. (See table 5.) 

Table 5: Percentages of Compliance Reviews for Fiscal Years 2001 through 2006 

That Covered Each of the Major Applicable Areas of the Safety Regulations

Each of the Major 

Applicable Areas of the 

Safety Regulations Is 

Covered by Most 

Compliance Reviews 

Regulatory area Percentage

Procedures for handling and evaluating accidents 97%

Drivers’ qualifications 96

Drivers’ hours of service 96

Inspection, repair, and maintenance of vehicles 96

Drug and alcohol use and testing 95

Commercial driver’s license standards 95

Driving of motor vehicles 94

Minimum insurance coverage 90

Vehicle parts and accessories necessary for safe operation 80

Source: GAO analysis of FMCSA data. 

An FMCSA official told us that not every compliance review is required to

cover all nine areas and cited the following reasons: 

• Follow-up compliance reviews of carriers rated unsatisfactory or 

conditional are sometimes streamlined to cover only the area or areas of

the regulations in which the carrier had violations. 

• Commercial driver’s license standards and drug and alcohol use and 

testing regulations apply primarily to those carriers that operate one or 

more vehicles weighing over 26,000 pounds (gross vehicle weight rating),

that haul hazardous material, or that transport more than 15 passengers. 

Page 30 GAO-07-584 Motor Carrier Safety Oversight
• Minimum insurance coverage regulations apply only to for-hire carriers 

and private carriers of hazardous materials; they do not apply to private 

passenger and nonhazardous materials carriers. 

However, according to an FMCSA official, the area of these regulations 

that had the lowest rate of coverage—vehicle parts and accessories 

necessary for safe operation—is required for all compliance reviews 

except streamlined reviews that exclude this area. Vehicle inspections are 

supposed to be a key investigative technique for assessing compliance 

with this area, and the FMCSA official said that the lower rate of coverage

for this area likely reflects the small number of vehicle inspections that 

FMCSA and the states conduct during compliance reviews. 

In addition to the safety regulations, compliance reviews of hazardous 

materials carriers, shippers, and cargo tank facilities must cover 

hazardous materials regulations. In fiscal years 2005 and 2006, FMCSA 

conducted about 6,000 compliance reviews of hazardous materials 

operators. Collectively, these compliance reviews covered between 40 

percent and 80 percent of the various individual areas of these regulations.

However, none of these compliance reviews was required to cover all 

areas of the hazardous materials regulations; the required areas vary with

the type of operator. Because the categories that MCMIS uses to classify 

hazardous materials operators are different from the categories used to 

determine which areas of the regulations must be covered, we could not 

determine, for the different types of operators, the extent to which 

FMCSA’s compliance reviews covered the required areas. 

FMCSA placed many carriers rated unsatisfactory in fiscal year 2005 out of 

service and followed up with nearly all of the rest to determine whether 

they had improved. In addition, FMCSA monitors carriers to identify those 

that are violating out-of-service orders. However, it does not take 

additional action against many of the violators of out-of-service orders that 

it identifies. Furthermore, FMCSA does not assess the maximum fines 

against all of the serious violators that we believe the law requires, partly 

because FMCSA does not distinguish between carriers with a pattern of 

serious safety violations and those that repeat a serious violation. 

FMCSA Follows Up 

with Many Carriers 

with Serious Safety 

Violations but Does 

Not Assess Maximum 

Fines against All of 

the Serious Violators 

Required by Law 

Page 31 GAO-07-584 Motor Carrier Safety Oversight
FMCSA followed up with 1,193 of 1,196 carriers (99.7 percent) that 

received a proposed safety rating of unsatisfactory following a compliance 

review that was completed in fiscal year 2005. FMCSA’s follow-up 

generally ensured that these carriers either made safety improvements 

that resulted in an upgraded final safety rating or—as required for carriers 

that also receive a final safety rating of unsatisfactory—were placed out of

service. More specifically, FMCSA used the following approaches to follow 

up with these carriers: 

FMCSA Followed Up with 

Almost All Carriers That 

Received a Proposed 

Safety Rating of 

Unsatisfactory 

• Follow-up compliance review. Based on such reviews, FMCSA upgraded 

the final safety ratings of 663 carriers (329 to satisfactory, and 334 to

conditional). 

• Assignment of a final rating of unsatisfactory and issuance of an outof-service order. FMCSA assigned a final rating of unsatisfactory to 312

carriers and issued an out-of-service order to 309 (99 percent) of them. An 

FMCSA official told us that it did not issue an out-of-service order to 2 

carriers because it could not locate them, and it did not issue an out-ofservice order to another carrier because the carrier was still subject to an 

out-of-service order that FMCSA issued several years prior to the 2005 

compliance review. 

• Review of evidence of corrective action. Carriers can request an upgraded

safety rating by submitting evidence of corrective action to FMCSA. Based 

on reviews of such evidence, FMCSA upgraded the final safety ratings of 

217 carriers (23 to satisfactory, and 194 to conditional). 

• Administrative review. Carriers that believe FMCSA made an error in 

assigning their proposed safety rating may request the agency to conduct

an administrative review. Based on the administrative review, FMCSA 

upgraded the final safety rating of 1 carrier to conditional. 

FMCSA did not assign final safety ratings to the remaining 3 carriers. For 1 

of these carriers, MCMIS indicates that the compliance review that 

resulted in the proposed rating of unsatisfactory did not identify any 

violations, even though carriers without violations are not supposed to 

receive a proposed unsatisfactory rating. For another of the carriers, 

MCMIS shows crashes, inspections, and a compliance review while also 

indicating that the carrier is inactive. FMCSA has been unable to locate the

final carrier, and MCMIS indicates that the carrier is inactive.

Unless FMCSA upgrades a proposed unsatisfactory safety rating or grants 

a carrier an extension, the agency is required under its policy to assign the 

carrier a final rating of unsatisfactory and to issue it an out-of-service 

Page 32 GAO-07-584 Motor Carrier Safety Oversight
order on the 46th day after the date of FMCSA’s notice of a proposed 

unsatisfactory rating for carriers of hazardous materials or passengers and 

on the 61st day for other types of carriers.27 Of the 309 out-of-service 

orders that FMCSA issued to carriers rated unsatisfactory following 

compliance reviews conducted in fiscal year 2005, 276 (89 percent) were 

issued on time, 28 (9 percent) were issued between 1 and 10 days late, and 

5 (2 percent) were issued more than 10 days late. FMCSA also assigned 

final upgraded safety ratings within these time frames in 837 (95 percent)

of the 881 cases in which it upgraded these ratings. FMCSA assigned 20

upgrades (2 percent) between 1 and 10 days late, and it assigned another 

20 (2 percent) more than 10 days late. MCMIS did not have information on 

the timing of the other 4 upgrades. An FMCSA official told us that when an 

out-of-service order was issued more than 1 week late, the primary reason 

for the delay was that the responsible FMCSA division office had difficulty 

scheduling a follow-up compliance review and thus waited to issue the 

orders. The official said that other delays were caused by clerical errors; 

extended periods during which certain division offices operated without a 

person serving in the position with primary responsibility for ensuring that 

out-of-service orders are issued on time; a lack of complete compatibility 

between MCMIS and FMCSA’s enforcement database; and, in one service 

center whose policy is to personally serve out-of-service orders to carriers, 

insufficient advance notification by the service center to its division 

offices that an order was to be served. The official noted that the last two 

issues have been addressed and said that FMCSA plans to more closely 

monitor the timeliness of the issuance of out-of-service orders in all of 

FMCSA’s division offices. 

 27FMCSA may allow a carrier with a proposed rating of unsatisfactory (unless the carrier is 

transporting passengers or hazardous materials) to continue to operate in interstate 

commerce for up to 60 days beyond the 60 days specified in the proposed rating if FMCSA

determines that the carrier is making a good faith effort to improve its safety. For carriers 

of passengers or hazardous materials, FMCSA may extend by up to 10 days the 45-day 

period before which the proposed safety rating becomes final, but it may not extend the 45-

day period before which these carriers are to be placed out of service. 

Page 33 GAO-07-584 Motor Carrier Safety Oversight
FMCSA uses two primary means to try to ensure that carriers that have

been placed out of service do not continue to operate. First, FMCSA 

partners with states to help them suspend, revoke, or deny vehicle 

registration to carriers that have been placed out of service. FMCSA refers 

to these partnerships as the Performance and Registration Information 

Systems Management program (PRISM). PRISM links FMCSA databases 

with state motor vehicle registration systems and roadside inspection 

personnel to help identify vehicles operated by carriers that have been 

issued out-of-service orders. As of January 2007, 45 states had been 

awarded PRISM grants, and 27 states were operating with PRISM 

capabilities. FMCSA officials told us that some states have not applied for

PRISM grants because they do not want to bear the costs that are not 

covered by the grants or they have not made the legislative changes 

required to implement PRISM. According to an FMCSA official, FMCSA 

has also begun working with PRISM states to enable them to receive

automated notifications of carriers that have been placed out of service. 

PRISM can also identify carriers that attempt to register vehicles under a 

different carrier name, and FMCSA provided us with information on two 

out-of-service carriers that Connecticut, using PRISM, had caught trying to

register vehicles by using a new company name. In addition, in

commenting on a draft of this report, FMCSA said that during the first 6 

months of fiscal year 2007, states that reported data to FMCSA indicated

that at least 104 motor carriers had their state vehicle registrations 

suspended, revoked, or denied based on an FMCSA order to cease 

interstate operations. 

FMCSA and its state partners also monitor carriers for indicators—such as 

roadside inspections, moving violations, and crashes—that the carriers 

may be violating an out-of-service order. First, FMCSA recently began to 

require the state partners that receive Motor Carrier Safety Assistance 

Program grants to check during roadside inspections whether carriers are 

operating under revoked authority and to take enforcement action against 

any that are. Second, FMCSA visits some suspect carriers that it identifies

by monitoring crash and inspection data to examine their records to 

determine whether they did indeed violate the order. FMCSA told us it is 

difficult for it to verify that such carriers were operating in violation of 

out-of-service orders because its resources do not allow it to visit each 

carrier or conduct roadside inspections on all vehicles, and we agree. In 

fiscal years 2005 and 2006, 677 of 1,741 carriers (39 percent) that were 

subject to an out-of-service order had a roadside inspection or crash; 

FMCSA cited only 36 of these 677 carriers for violating the out-of-service 

order. An FMCSA official told us that some of these carriers, such as 

carriers that were operating intrastate or leasing vehicles to other carriers, 

FMCSA Monitors Carriers 

to Identify Those That Are 

Violating Out-of-Service 

Orders, but It Does Not 

Take Additional Action 

against Many of the 

Violators It Identifies 

Page 34 GAO-07-584 Motor Carrier Safety Oversight
may not have been violating the out-of-service order. The official said that 

the agency did not have enough resources to determine whether each of 

the carriers was violating the out-of-service order. He also said that 

FMCSA recently completed a pilot program in which the agency cited 

obvious violators such as carriers that have a roadside inspection outside 

their home state. In commenting on a draft of this report, FMCSA said that 

it is developing new policies and procedures intended to establish a 

uniform national approach for follow-up, as well as additional 

enforcement action against motor carriers that have violated an out-ofservice order. 

In 2006, the Safety Board assessed FMCSA’s approach to ensuring that 

carriers whose operating authority has been revoked do not operate and 

concluded that it was inadequate.28 The Safety Board recommended that

FMCSA establish a program to address this issue. In response to this 

recommendation, FMCSA noted that, because the numbers of carriers that 

have been placed out of service or have had their operating authority 

revoked has significantly increased in recent years, it is difficult to ensure

that these carriers do not continue to operate. An FMCSA official 

attributed this difficulty to FMCSA’s lack of resources to visit each carrier 

or conduct roadside inspections on all vehicles—the same reason FMCSA 

cites for not following up on all carriers that may be violating an out-ofservice order. Despite this difficulty, FMCSA responded that it (1) is 

linking its licensing and insurance database to its primary carrier database 

to improve the ability of roadside inspection personnel in all states and 

registration offices in PRISM states to identify carriers that have had their 

operating authority revoked and (2) has directed division office managers 

to assess fines when data accessed during roadside inspections indicate 

that carriers were operating under revoked authority. In March 2007, the 

Safety Board said that FMCSA was making acceptable progress on the 

recommendation, but expressed concern that some states will choose not 

to implement PRISM and that, based on the program’s rate of 

implementation thus far, it will take too long to become fully operational 

in many other states. The Safety Board, therefore, encouraged FMCSA to 

The Safety Board Recently 

Concluded That FMCSA Is 

Making Adequate Progress 

in Ensuring That Carriers 

Do Not Operate under 

Revoked Authority 

 28FMCSA’s policy calls for the agency to revoke the operating authority of any carrier that

does not have the minimum required amount of insurance coverage; the minimum amount 

depends on whether the carrier is for-hire or private, whether it transports commodities or

passengers, and what type of commodity or number of passengers is transported. 

Operating without the minimum required amount of insurance coverage is a serious

violation of the safety regulations. 

Page 35 GAO-07-584 Motor Carrier Safety Oversight
implement PRISM more rapidly in all states. An FMCSA official told us 

that the agency is already making a concerted effort to encourage the 5 

states without PRISM to adopt the program and the 18 PRISM states that 

do not yet have full PRISM capabilities to achieve them. 

FMCSA’s policy requires the agency to conduct follow-up compliance 

reviews on all carriers rated conditional and, over the last several years, 

the agency has reduced the number of such carriers needing review. After 

the Department of Transportation Inspector General reported in 1999 that 

FMCSA allowed motor carriers with less than satisfactory ratings to 

continue operations for extended periods of time, FMCSA began requiring 

follow-up compliance reviews on all carriers rated conditional. In fiscal 

years 2005 and 2006, respectively, FMCSA conducted 2,537 and 2,692 

follow-up reviews of carriers rated conditional or unsatisfactory,29

exceeding its annual goal of 2,500 follow-up reviews.30 In addition, from 

fiscal year 2000 through fiscal year 2006, the number of carriers rated 

conditional that needed a follow-up review decreased from about 40,000 to

about 30,000. 

While FMCSA has reduced the number of carriers rated conditional that 

need a follow-up review, it is difficult to assess the agency’s timeliness in 

conducting these reviews because FMCSA’s policy does not specify a time

frame for following up on carriers with conditional safety ratings. The 

policy does discourage follow-up reviews within 12 months because 

FMCSA believes that more time is needed to show the effects of safety 

improvements. Yet the policy also gives FMCSA’s division office 

administrators the discretion to determine whether a follow-up review 

should be conducted within 12 months. Almost half of all carriers that 

received a conditional rating from fiscal year 2002 through fiscal year 2004 

received a follow-up review within 12 months; however, because of the 

FMCSA Has Reduced the 

Number of Carriers Rated 

Conditional That Need 

Follow-up Compliance 

Reviews, but the 

Timeliness of These 

Reviews Is Difficult to 

Assess 

 29FMCSA also aims to conduct follow-up compliance reviews of carriers rated 

unsatisfactory (1) that request a follow-up review or (2) that received their ratings before

November 20, 2000, when FMCSA’s regulation requiring the agency to place carriers rated 

unsatisfactory out of service became effective. 

30FMCSA’s goal for follow-up reviews includes only those follow-up reviews conducted by 

FMCSA. An FMCSA official told us that the agency chose not to include reviews conducted 

by the states as part of the goal because FMCSA receives an appropriation that covers its 

follow-up reviews. However, follow-on compliance reviews conducted by states are funded 

through a separate appropriation, the Motor Carrier Safety Assistance Program. FMCSA

could choose to have states establish goals when applying for these funds. 

Page 36 GAO-07-584 Motor Carrier Safety Oversight
policy’s allowance for discretion, we could not determine how many, if 

any, of these follow-up reviews, occurred too soon. (See table 6.) In 

addition, because FMCSA does not specify a deadline for conducting 

follow-up reviews, we could not determine whether any of the reviews 

occurred too late. Our analysis of the timing of follow-up reviews shows 

that from fiscal year 2002 through fiscal year 2004, 66 percent of the 

carriers that received a conditional rating received a follow-up review 

within 24 months, while 7 percent received a follow-up review more than 

24 months after they received their conditional rating. Another 27 percent 

of the carriers still needed a review as of September 2006. 

Table 6: Time Elapsed before Carriers Rated Conditional Received Follow-up 

Compliance Reviews, Fiscal Years 2002 through 2004, as of September 2006 

2002 2003 2004 Total

Time elapsed

before follow-up 

compliance review

Number of 

follow-up

reviews

Number of 

follow-up

reviews

Number of 

follow-up

reviews

Number of 

follow-up

reviews

0 to 12 months 1,203 (51%) 1,132 (42%) 1,021 (42%) 3,356 (45%)

More than 12

months to 18 

months 311 (13) 413 (15) 398 (16) 1,122 (15)

More than 18

months to 24 

months 86 (4) 163 (6) 191 (8) 440 (6)

More than 24

months 180 (8) 274 (10) 86 (4) 540 (7)

Still need a review 568 (24) 722 (27) 723 (30) 2,013 (27)

Total 2,348 (100%) 2,704 (100%) 2,419 (100%) 7,471 (100%)

Source: GAO analysis of FMCSA data. 

In 1999, the Safety Board recommended that FMCSA lower its threshold 

for rating a carrier unsatisfactory to include carriers with an unsatisfactory 

rating in either the driver or vehicle factor of the rating scheme. The Safety 

Board has classified this recommendation as one of its “most wanted” 

safety improvements since 2000.31 Although FMCSA has not yet decided 

whether it will implement this recommendation, it is developing a new 

FMCSA Is Developing a 

New Safety Rating 

Methodology 

 31The Safety Board’s most wanted list, which is drawn up from issued safety 

recommendations, is intended to emphasize the transportation safety issues the Safety

Board deems most critical. 

Page 37 GAO-07-584 Motor Carrier Safety Oversight
rating methodology as part of its Comprehensive Safety Analysis 2010 

reform initiative, and it plans to implement the methodology in 2010. As 

mentioned previously, the new methodology would base determinations of 

whether carriers are fit to continue operating on assessments made by the 

tool that FMCSA is developing to replace SafeStat, rather than on the 

results of compliance reviews. FMCSA believes that the new approach will 

enable the agency to assess the safety fitness of a larger share of the motor 

carrier industry. 

FMCSA is also considering determining the safety fitness of drivers, and 

applying interventions to those that it deems need them. FMCSA believes 

that the increased focus that this would bring to the safety of drivers is 

important because the results of its recent study on the causes of large 

truck crashes indicate that drivers of large trucks and other vehicles 

involved in truck crashes are 10 times more likely to be the cause of the 

crash than other factors, such as weather, road conditions, and vehicle

performance. In addition, FMCSA is considering eliminating the 

conditional rating and using only two ratings—“continue to operate” and 

“unfit.” An FMCSA official told us that FMCSA may eliminate the 

conditional rating because the agency feels that the current satisfactory 

rating is being misinterpreted by some government agencies and members 

of the public that hire carriers as FMCSA’s seal of approval. The official

said that the agency believes that the “continue to operate” rating, which

would be given to all carriers that are allowed to continue to operate, is 

less likely to be viewed as a seal of approval than the satisfactory rating, 

which indicates a level of safety that is greater than the conditional rating 

that also allows carriers to continue operating. Depending on their safety 

performance, carriers or drivers allowed to continue operating could be

subject to interventions, such as Web-based education, warning letters, 

requests for submission of documents, targeted roadside inspections, 

focused on-site reviews, comprehensive on-site reviews (similar to 

compliance reviews), and enforcement actions. 

Page 38 GAO-07-584 Motor Carrier Safety Oversight
From August 2006 through February 2007, data from MCMIS indicate that 

FMCSA performed compliance reviews on 1,136 of the 2,220 (51 percent)

carriers that were covered by FMCSA’s mandatory compliance review 

policy.32 Under the Safe, Accountable, Flexible, Efficient Transportation 

Equity Act: A Legacy for Users, FMCSA is required to conduct compliance 

reviews on carriers rated in SafeStat categories A or B for 2 consecutive 

months. In response to this requirement, in June 2006, FMCSA 

implemented a policy requiring a compliance review within 6 months for 

any such carrier unless the carrier had received a compliance review 

within the previous 12 months.33 An FMCSA official told us that the agency

did not have enough resources to conduct compliance reviews on all of 

the 2,220 carriers within the first 6-month period.

In April 2007, FMCSA revised the policy because the agency believes that 

it required compliance reviews for some carriers that did not need them, 

leaving FMCSA with insufficient resources to conduct compliance reviews 

on other carriers that did need them. The carriers that did not need 

compliance reviews were those that had already had a compliance review 

and had corrected identified violations, but these violations continued to 

adversely affect their SafeStat rating because SafeStat penalizes carriers 

for violations regardless of whether they have been corrected. This 

unnecessary targeting drained resources, leaving FMCSA without the 

means to conduct compliance reviews of carriers that had never received 

such a review, but, in FMCSA’s view, should have received one because of 

current safety performance issues that led to their placement in SafeStat 

categories C, D, or E. The new policy requires compliance reviews within 6 

months for carriers that have been in SafeStat categories A or B for 2 

consecutive months and received their last compliance review 2 or more 

Policy Change Gives 

FMCSA Appropriate 

Discretion in Performing 

Statutorily Required 

Reviews of High-Risk 

Carriers 

 32An FMCSA official told us that the agency believes that using MCMIS data results in an 

overestimate of the number of carriers that were required to receive, but did not receive, a 

compliance review, primarily because the agency has indications that some carriers listed 

as active in MCMIS are actually inactive. The official said that FMCSA’s eastern service 

center examined the cases of 95 of the 162 carriers that MCMIS indicated did not receive a 

compliance review even though one was required and found that 39 of them did not require 

a compliance review, and 7 actually did receive a compliance review. 

33The first group of carriers to be affected by this policy was the 2,220 carriers in SafeStat 

categories A or B in both July and August 2006 that did not receive a compliance review in 

the previous 12 months (another 2,887 carriers that were in SafeStat categories A or B in 

both July and August 2006 did receive a compliance review in the previous 12 months). 

Page 39 GAO-07-584 Motor Carrier Safety Oversight
years ago (or have never received a compliance review).34 In addition, 

compliance reviews are recommended for carriers that have been in 

SafeStat categories A or B for 2 consecutive months and received their last 

compliance review more than 1 year ago but less than 2 years ago. FMCSA 

division offices can decide not to conduct a compliance review on such a 

carrier if (1) its SafeStat category changes to a category other than A or B 

or (2) its safety evaluation area values are based largely on prior 

compliance review violations that have been corrected or on accidents or 

inspections that occurred prior to the carrier’s last compliance review. We 

believe that these changes are consistent with the act’s requirement and 

give FMCSA appropriate discretion in allocating its compliance review 

resources. 

From October 2005 through October 2006, FMCSA reduced its backlog of 

enforcement cases that had been open for 6 months or more by about 70 

percent (from 807 to 247).

35 As the Department of Transportation Inspector 

General has noted, a large backlog of enforcement cases negatively affects

the integrity of the enforcement process for two reasons. First, because

FMCSA considers only closed enforcement cases when targeting motor 

carriers for a compliance review, high-risk motor carriers are less likely to

be selected if they have an open enforcement case. Second, because 

FMCSA assesses smaller fines against carriers with open cases than 

against those with closed cases, it may not assess appropriate fine 

amounts against carriers with multiple enforcement cases (the number of 

prior enforcement cases is one of the criteria that FMCSA uses to 

determine fine amounts). FMCSA’s 2002 review of its compliance review 

program also found that delays in closing enforcement cases were 

negatively affecting the integrity of the agency’s enforcement process. An 

FMCSA Has Substantially 

Reduced Its Backlog of 

Enforcement Cases 

 34For the carriers that have received a prior compliance review, FMCSA would be able to

extend the deadline to 12 months if it has applied an alternative intervention, such as a

consent agreement. A consent agreement is an agreement between FMCSA and a carrier 

that can lower the amount of an assessed fine in exchange for corrective action and 

additional safety improvements by the carrier.

35We defined the backlog as consisting of enforcement cases that had been open for 6

months or more to be consistent with our and the Inspector General’s earlier work on the 

backlog. See GAO, Large Truck Safety: Federal Enforcement Efforts Have Been Stronger 

Since 2000, but Oversight of State Grants Needs Improvement, GAO-06-156 (Washington,

D.C.: Dec.15, 2005) and U.S. Department of Transportation Office of Inspector General, 

Motor Carrier Safety Program, Federal Highway Administration, Report TR-1999-091 

(Washington, D.C.: Apr. 26, 1999).We did not compare how FMCSA closed the cases that 

were and were not backlogged because doing so would have required too many resources.

Page 40 GAO-07-584 Motor Carrier Safety Oversight
FMCSA official told us that in response to this review, the agency assigned 

a second attorney to work on enforcement cases. In 2005, we 

recommended that FMCSA establish a goal specifying how much it would 

like to reduce the enforcement backlog and by what date. In March 2007,

FMCSA implemented this recommendation by establishing goals to (1) 

close, by the end of 2007, its backlog of 63 enforcement cases in its 

division offices that had been open for 270 days or more and (2) close, by

August 31, 2007, its backlog of 14 cases pending before its Assistant 

Administrator for Enforcement for more than 18 months, without adding

other cases to this backlog. 

FMCSA does not assess maximum fines against all of the serious violators 

that we believe the law requires. The law requires FMCSA to assess the 

maximum allowable fine for each serious violation by a carrier that is 

found (1) to have a pattern of committing such violations (pattern 

requirement) or (2) to have previously committed the same or a related

serious violation (repeat requirement).36 The legislative history of this 

provision provides evidence that FMCSA must assess maximum fines in 

these two distinct situations.37 However, FMCSA’s policy on maximum 

fines does not fully meet these requirements. FMCSA enforces both 

requirements using what is known as the “three strikes rule,” applying the 

maximum allowable fine when it finds that a motor carrier has violated the 

same regulation three times within 6 years. FMCSA officials said they 

interpret both parts of the act’s requirements to refer to repeat violations, 

FMCSA Does Not Assess 

Maximum Fines Against 

All of the Serious Violators 

That the Law Requires 

 36Motor Carrier Safety Improvement Act of 1999, Pub. L. No. 106-159, § 222(b)(2), 113 Stat. 

1748, 1769 (49 U.S.C.A. § 521 Note). 

37See statement of Congressman Oberstar, then ranking member of the Committee on 

Transportation and Infrastructure, explaining, along with then-Chairman Shuster, the 

Motor Carrier Safety Improvement Act of 1999, 145 Cong. Rec. H12868-12870 (Daily ed. 

Nov. 9, 1999). After observing that prior federal efforts at motor carrier oversight had 

proved to have major deficiencies, he stated:

“The bill makes numerous programmatic changes to improve safety by keeping dangerous 

drivers off the roads and enhancing oversight.... 

“Violators of safety laws and regulations will face penalties high enough to promote future

compliance. Maximum fines will be assessed for repeat offenders as well as a pattern of 

violations of our safety laws and regulations.” (Emphasis added.) 

While the congressional committees did not submit reports on this legislation, the

Chairman introduced materials to serve as the joint statement of managers for the 

legislation. Those materials and other floor statements also referred to repeat offenders or 

a pattern of violations. Id. at H.12874. 

Page 41 GAO-07-584 Motor Carrier Safety Oversight
and because they believe that having two distinct policies on repeat 

violations would confuse motor carriers, FMCSA has chosen to address 

both requirements with its single three strikes policy. According to FMCSA 

officials, FMCSA developed the three strikes policy in response to a 

provision in the Motor Carrier Safety Act of 1984,38 which permitted 

FMCSA’s predecessor to assess a fine of up to $1,000 per offense (capped 

at $10,000) if the agency determined that “a serious pattern of safety 

violations” existed or had occurred. FMCSA officials told us that when 

Congress in 1999 enacted the current “pattern of violations” language in 

the Motor Carrier Safety Improvement Act, the agency interpreted it to be 

similar to the previous language and to mean three strikes.39

FMCSA’s interpretation does not carry out the statutory mandate to 

impose maximum fines in two different cases. In contrast to FMCSA, we 

read the statute’s use of the distinct terms “a pattern of violations” and 

“previously committed the same or a related violation” as requiring 

FMCSA to implement two distinct policies. A basic principle of statutory 

interpretation is that distinct terms should be read as having distinct 

meanings. In this case, the statute not only uses different language to refer 

to the violations for which maximum fines must be imposed, but it also 

sets them out separately and makes either type of violation subject to the 

maximum penalties. Therefore, one carrier may commit a variety of 

serious violations and another carrier may commit a serious violation that 

is the same as, or substantially similar to, a previous serious violation; the 

language on its face requires FMCSA to assess the maximum allowable 

fine in both situations—for a pattern of violations, as well as a repeat 

offense. 

 38Pub. L. No. 98-554, title II, 98 Stat. 2832, 2842 (1984). 

39In making its argument, FMCSA is referring to the Office of Motor Carriers, which was an 

office within the Federal Highway Administration until 1999, the year when FMCSA was 

created with the adoption of the Motor Carrier Safety Improvement Act. That act 

strengthened and transferred to FMCSA the functions previously assigned to the Office of

Motor Carriers. Furthermore, section 222(b)(2) not only used different language in the

requirements for the imposition of fines; it also made the imposition of the maximum fines

mandatory and specifically included repeat, as well as patterns of violations of critical or 

acute regulations. In this context, we do not agree that section 222(b)(2) was just a 

continuation of earlier, less specific, discretionary authority. Section 222(b)(2), along with 

other changes, was part of a congressional design to remedy what Congress viewed as

serious shortcomings in the Office of Motor Carriers. Congress denied funding to that

office under section 338 of the Department of Transportation and Related Agencies 

Appropriations Act, 2000, Pub. L. No. 106-69, 113 Stat. 986 (1999), with responsibility for 

trucking safety being temporarily transferred to the Office of the Secretary. Only thereafter 

was FMCSA created as a separate administration within the Department of Transportation. 

Page 42 GAO-07-584 Motor Carrier Safety Oversight
FMCSA could define a pattern of serious violations in numerous ways that 

are consistent with the act’s pattern requirement. Our application of eight 

potential definitions shows that the number of carriers that would be 

subject to maximum fines depends greatly on the definition. (See table 7.)

For example, a definition calling for two or more serious violations in each

of at least four different regulatory areas during a compliance review 

would have made 38 carriers subject to maximum fines in fiscal year 2006. 

In contrast, a definition calling for one or more serious violations in each 

of at least three different regulatory areas would have made 1,529 carriers 

subject to maximum fines during that time.40

Table 7: Number of Motor Carriers That Would Have Been Subject to Maximum Fines under Various Definitions of a Pattern of

Serious Violations, Fiscal Years 2004 through 2006 

Number of carriers in 2004 

with 

Number of carriers in 2005

 with 

Number of carriers in 2006 

with 

Number of 

regulatory 

areas with 

serious

violations

1 or more 

serious

violations per 

area 

2 or more 

serious

violations per 

area

1 or more 

serious

violations per 

area

2 or more 

serious 

violations per 

 area 

1 or more 

serious

violations per 

area

2 or more 

serious

violations

per area

2 or more 2,935 177 3,004 158 3,348 225

3 or more 1,372 64 1,430 58 1,529 114

4 or more 494 16 557 25 530 38

5 or more 83 2 115 9 115 7

Source: GAO analysis of FMCSA data. 

We also interpret the statutory language for the repeat requirement as 

calling for a “two strikes” rule as opposed to FMCSA’s three strikes rule. 

FMCSA’s interpretation imposes the maximum fine only after a carrier has 

twice previously committed a serious violation. The language of the 

statute does not allow FMCSA’s interpretation; rather it requires FMCSA 

to assess the maximum allowable fine for each serious violation against a

carrier that has previously committed the same serious violation.41 In 

 40Our definitions are for analysis purposes only. We are neither suggesting which, if any, of

these pattern definitions FMCSA should adopt as its policy, nor is our exclusive focus on 

patterns involving only violations identified during a single compliance review meant to 

suggest that the pattern definitions could not require that serious violations occur over 

multiple compliance reviews. 

41The statute (section 222(c)) does allow the Secretary to determine and document that 

extraordinary circumstances merit a lower-than-maximum fine in a particular case if, for

example, a carrier can establish that repetition was not a result of its failure to take 

appropriate remedial action. 

Page 43 GAO-07-584 Motor Carrier Safety Oversight
addition, in 2006, the Department of Transportation Inspector General 

found that FMCSA’s implementation of its three strikes rule had allowed 

many third strike violators to escape maximum fines.42 Specifically, of the 

533 third strike violators of the hours of service or the drug and alcohol 

regulations between September 2000 and October 2004, 33 (6 percent) 

third strike violators were assessed the maximum fine. The Inspector 

General found that FMCSA did not consider many of these violators to be

third strike violators because the agency, in keeping with its policy, did 

not count the carriers’ violations as strikes unless a violation resulted in 

the assessment of a fine. FMCSA does not always notify carriers of serious 

violations without fines and, therefore, FMCSA believes that counting such 

violations as strikes would violate the due process rights of carriers. The 

Inspector General agreed and recommended that FMCSA assess a nodollar-amount fine or use another appropriate mechanism to legally notify 

a motor carrier of the violation and the policy that future violations will 

result in the maximum fine amount. An FMCSA official said that the 

agency is developing a policy designed to address this recommendation 

and plans to consider the related recommendation in this report as it 

develops the policy. FMCSA plans to implement the policy by June 2008. 

In fiscal years 2004 through 2006, there were more than four times as many 

carriers with a serious violation that constituted a second strike than there 

were carriers with a third strike. (See table 8.) For example, in fiscal year 

2006, 1,320 carriers had a serious violation that constituted a second 

strike, whereas 280 carriers had a third strike.43

Table 8: Number of Motor Carriers That Would Have Been Subject to Maximum 

Fines under Two Strikes and Three Strikes Repeat Violator Policies, Fiscal Years

2004 through 2006

Policy 2004 2005 2006 Total

Two strikes 1,251 1,292 1,320 3,863

Three strikesa269 284 280 833

Source: GAO analysis of FMCSA data. 

a

FMCSA’s policy currently assesses the maximum fine for three violations in the same regulatory 

area. 

 42Office of Inspector General, Report MH-2006-046. 

43These figures count all serious violations as strikes, regardless of whether they resulted in

a fine. This is consistent with the policy that FMCSA is developing in response to the

Inspector General’s recommendation. 

Page 44 GAO-07-584 Motor Carrier Safety Oversight
Carriers with a pattern of violations may also commit a second strike 

violation. For example, three of the seven carriers that had two or more 

serious violations in each of at least five different regulatory areas also had

a second strike in fiscal year 2006. Were FMCSA to make policy changes 

along the lines discussed here, we believe that the new policies should 

address how to deal with carriers with serious violations that both are part

of a pattern and repeat the same or similar previous violations. 

FMCSA’s policy for prioritizing carriers for compliance reviews based on 

their SafeStat scores furthers motor carrier safety because it targets many 

carriers that pose high crash risks and thus has value for reducing both the 

number and severity of motor carrier crashes. However, the policy does 

not always target the carriers that have the highest crash risks. 

Modifications to the policy that we identified could improve FMCSA’s 

targeting of high-risk carriers, thereby leading to compliance reviews that 

would have a greater potential to avoid crashes and their associated 

injuries and fatalities. Our June 2007 report found that a regression model 

approach would better identify carriers that pose high crash risks than 

does SafeStat, enabling FMCSA to better target its resources. We 

recommended in that report that FMCSA implement such an approach. 

However, if FMCSA does not implement this recommendation, the 

analysis presented in this report suggests an alternative approach that 

would also better target carriers that pose high crash risks. This approach 

would give high priority for compliance reviews to carriers with very poor

scores (such as the worst 5 percent) in the accident safety evaluation area.

Conclusions 

While FMCSA follows up with most carriers with serious safety violations, 

it has not established a time frame for carriers rated conditional to receive 

a follow-up compliance review. As a result, many carriers with conditional 

ratings can continue to operate for 2 years or more without a follow-up 

compliance review, posing safety risks to themselves and the public. 

Finally, we found that FMCSA assesses maximum fines against carriers 

that twice repeat a serious violation. However, because of FMCSA’s 

interpretation of the statutory requirement to assess maximum fines 

against serious violators, many carriers that continue to accrue serious 

violations do not have the maximum fine assessed against them. 

Therefore, neither the statutory requirement nor FMCSA’s enforcement is 

as effective as possible in deterring unsafe practices and, as a result, 

additional accidents could occur. 

Page 45 GAO-07-584 Motor Carrier Safety Oversight
In our June 2007 report on the effectiveness of SafeStat, we recommended 

that FMCSA use a regression model approach to identify carriers that pose 

high crash risks rather than its expert judgment approach. Should the 

Secretary of Transportation decide not to implement that 

recommendation, we recommend that the Secretary of Transportation 

direct the FMCSA Administrator to take the following action: 

• to improve FMCSA’s targeting of carriers that pose high crash risks, 

modify FMCSA’s policy for prioritizing compliance reviews so that carriers 

with very poor scores (such as the worst 5 percent) in the accident safety

evaluation area will be selected for compliance reviews, regardless of their 

scores in the other areas.

We also recommend that the Secretary of Transportation direct the 

FMCSA Administrator to take the following two actions: 

• to help ensure that carriers rated conditional make safety improvements in 

a timely manner, establish a reasonable time frame within which FMCSA 

should conduct follow-up compliance reviews on such carriers and 

• to meet the Motor Carrier Safety Improvement Act’s requirement to assess 

maximum fines and improve the deterrent effect of these fines, revise 

FMCSA’s related policy to include (1) a definition for a pattern of 

violations that is distinct from the repetition of the same or related 

violations and (2) a two strikes rule rather than a three strikes rule. 

We provided a draft of this report to the Department of Transportation for 

its review and comment. The department did not offer overall comments 

on the draft report. It said that it would assess the efficacy of the first 

recommendation, but it did not comment on the other recommendations. 

It offered several technical comments, which we incorporated where 

appropriate.

As agreed with your office, unless you publicly announce the contents of

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies of this report to 

congressional committees and subcommittees with responsibilities for 

commercial motor vehicle safety issues; the Secretary of Transportation; 

the Administrator, FMCSA; and the Director, Office of Management and 

Budget. We also will make copies available to others upon request. In 

Recommendations for 

Executive Action 

Agency Comments 

Page 46 GAO-07-584 Motor Carrier Safety Oversight
addition, the report will be available at no charge on the GAO Web site at 

http://www.gao.gov. 

If you 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. Staff who made key contributions to this report are listed in

appendix V.

Sincerely yours, 

Susan A. Fleming 

Director, Physical Infrastructure Issues 

Page 47 GAO-07-584 Motor Carrier Safety Oversight
Appendix I: 

A

Other Assessments of SafeStat’s 

bility to Identify High-Risk Motor Carriers 

Page 48 GAO-07-584

Appendix I: Other Assessments of SafeStat’s 

Ability to Identify High-Risk Motor Carriers 

Several studies by the Volpe National Transportation Systems Center 

(Volpe), the Department of Transportation Office of Inspector General, the 

Oak Ridge National Laboratory (Oak Ridge), and others have assessed the 

predictive capability of the Motor Carrier Safety Status Measurement 

System (SafeStat) model and the data used by that model. In general, 

studies that assessed the predictive power of SafeStat offered suggestions 

to increase that power, and studies that assessed data quality found 

weaknesses in the data that the Federal Motor Carrier Safety 

Administration (FMCSA) relies upon.

The studies we reviewed compared SafeStat with random selection to 

determine which does a better job of selecting carriers that pose high 

crash risks and assessed whether statistical approaches could improve 

that selection and whether carrier financial positions or driver convictions 

are associated with crash risk. 

In its 2004 and 1998 studies of the SafeStat model,

1

 Volpe analyzed 

retrospective data to determine how many crashes carriers in SafeStat 

categories A and B experienced over the following 18 months. The 2004 

study used the carrier rankings from an application of the SafeStat model 

on March 21, 2001. Volpe then compared the SafeStat carrier safety ratings 

with state-reported data on crashes that occurred between March 22, 2001, 

and September 21, 2002, to assess the model’s performance. For each 

carrier, Volpe calculated a total number of crashes, weighted for time and 

severity, and then estimated a rate per 1,000 vehicles for comparing 

carriers in SafeStat categories A and B with the carriers in other SafeStat 

categories. The 1998 Volpe study used a similar methodology. Each study 

used a constrained subset of carriers rather than the full list contained in 

the Motor Carrier Management Information System (MCMIS).2

 Both 

studies found that the crash rate for the carriers in SafeStat categories A 

and B was substantially higher than for the other carriers during the 18 

Assessments of SafeStat’s

Predictive Capability 

Predictive Capability of 

SafeStat Compared with 

Random Selection 

 1

David Madsen and Donald Wright, Volpe National Transportation Systems Center, An 

Effectiveness Analysis of SafeStat (Motor Carrier Safety Status Measurement System),

Paper No. 990448, November 1998 and John A. Volpe National Transportation Systems 

Center, Motor Carrier Safety Assessment Division, SafeStat Effectiveness Study Update, 

March 2004. 

2

Volpe included only carriers which met one or more of the following conditions: two or

more reported crashes; three or more roadside inspections during the preceding 30 

months; an enforcement action within the past 6 years; or a compliance review within the 

previous 18 months. This is consistent with the SafeStat minimum event requirements. 

Motor Carrier Safety Oversight
Appendix I: Other Assessments of SafeStat’s 

Ability to Identify High-Risk Motor Carriers 

months after the particular SafeStat run. On the basis of this finding, Volpe 

concluded that the SafeStat model worked. 

In response to a recommendation by the Department of Transportation 

Office of Inspector General,3

 FMCSA contracted with Oak Ridge to 

independently review the SafeStat model. Oak Ridge assessed the SafeStat 

model’s performance and used the same data set (for March 21, 2001) 

provided by Volpe, which Volpe had used in its 2004 evaluation. Perhaps 

not surprisingly, Oak Ridge obtained a similar result for the weighted 

crash rate of carriers in SafeStat categories A and B over the 18-month 

follow-up period. Like the Volpe studies, the Oak Ridge study was 

constrained because it was based on a limited data set rather than the 

entire MCMIS data set. 

While SafeStat does better than simple random selection in identifying 

carriers that pose high crash risks, other methods can also be used. Oak 

Ridge extended Volpe’s analysis by applying regression models to identify

carriers that pose high crash risks. Specifically, Oak Ridge applied a 

Poisson regression model and a negative binomial model using the safety 

evaluation area scores as independent variables to a weighted count of 

crashes that occurred in the 30 months before March 21, 2001.

4

In addition, Oak Ridge applied the empirical Bayes method to the negative 

binomial regression model and assessed the variability of carrier crash 

counts by estimating confidence intervals.5

 Oak Ridge found that the 

negative binomial model worked well at identifying carriers that pose high

crash risks. However, the data set Oak Ridge had to use did not include 

any carriers with one reported crash in the 30 months before March 21, 

Application of Regression 

Models to Safety Data 

 3

U.S. Department of Transportation Office of Inspector General, Improvements Needed in

the Motor Carrier Safety Status Measurement System, Report MH-2004-034 (Washington,

D.C.: Feb. 13, 2004). 

4

Both the Poisson model and the negative binomial model are statistically appropriate for

use when modeling counts are positive and integer valued. The two models differ in their 

assumptions about the mean and variance. Whereas the Poisson model assumes that the 

mean and the variance are equal, the negative binomial model assumes that the mean is not

equal to the variance. 

5

The empirical Bayes method takes a weighted average of the rate of crashes for a carrier

from a prior period of time and the predicted mean number of crashes from the negative 

binomial regression. This method optimizes the identification of carriers with the highest 

number of future crashes.

Page 49 GAO-07-584 Motor Carrier Safety Oversight
Appendix I: Other Assessments of SafeStat’s 

Ability to Identify High-Risk Motor Carriers 

2001. Because the data included only carriers with zero or two or more 

reported crashes, the distribution of crashes was truncated. 

Since the Oak Ridge regression model analysis did not cover carriers with 

safety evaluation area data and one reported crash, the findings from the 

study are limited in their generalizeability. However, other modeling 

analyses of crashes at intersections and on road segments have also found

that the negative binomial regression model works well.6

 In addition, our 

analysis, using a more recent and more comprehensive data set, supports 

the finding that the negative binomial regression model performs better 

than the SafeStat model. 

The studies carried out by other authors advocate the use of the empirical 

Bayes method in conjunction with a negative binomial regression model to 

estimate crash risk. Oak Ridge also applied this model to identify motor 

carriers that pose high crash risks. We applied this method to the 2004 

SafeStat data and found that the empirical Bayes method best identified 

the carriers with the largest number of crashes in the 18 months after June 

25, 2004. However, the crash rate per 1,000 vehicles was much lower than 

that for carriers in SafeStat categories A and B. We analyzed this result 

further and found that although the empirical Bayes method best identifies

future crashes, it is not as effective as the SafeStat model or the negative 

binomial regression model in identifying carriers with the highest future 

crash rates. The carriers identified with the empirical Bayes method were 

invariably the largest carriers. This result is not especially useful from a 

regulatory perspective. Companies operating a large number of vehicles 

often have more crashes over a period of time than smaller companies. 

However, this does not mean that the larger company is necessarily 

violating more safety regulations or is less safe than the smaller company.

For this reason, we do not advocate the use of the empirical Bayes method 

in conjunction with the negative binomial regression model as long as the

method used to calculate the safety evaluation area values remains 

unchanged. If changes are made in how carriers are rated for safety, this 

method may in the future offer more promise than the negative binomial 

regression model alone. 

 6

Ezra Hauer, Douglas Harwood, and Michael Griffith, The Empirical Bayes Method for

Estimating Safety: A Tutorial, Transportation Research Record 1784, National Academies 

Press, 2002, 126-131. 

Page 50 GAO-07-584 Motor Carrier Safety Oversight
Appen

Compare Meth

Carri

dix II: FMCSA’s Crash Data Used to 

ods for Identifying High-Risk 

ers 

Page 51 GAO-07-584

Appendix II: FMCSA’s Crash Data Used to 

Compare Methods for Identifying High-Risk 

Carriers 

The quality of crash data is a long-standing problem that hinders FMCSA’s 

ability to accurately identify carriers that pose high crash risks.1

 Despite 

the problems of late-reported crashes and incomplete and inaccurate data

on crashes, the data were of sufficient quality for our use, which was to 

assess whether different approaches to categorizing carriers could lead to

better identification of carriers that subsequently have high crash rates. 

Our reasoning is based on our use of the same data set to compare the 

crash risk of carriers in SafeStat categories A or B and of carriers that 

score among the worst 25, 10, or 5 percent in an individual safety 

evaluation area. Limitations in the data would apply equally to both 

results. FMCSA has undertaken a number of efforts to improve crash data

quality. 

FMCSA’s guidance requires states to report all crashes to MCMIS within 90 

days of their occurrence. Late reporting can cause SafeStat to miss some 

of the carriers that should have received a SafeStat score. Moreover, since 

SafeStat scoring involves a relative ranking of carriers, a carrier may 

receive a SafeStat score and have to undergo a compliance review because 

crash data for a higher risk carrier were reported late and not included in

the calculation. 

Late reporting affected SafeStat’s ability to identify all high-risk carriers to 

a small degree—missing about 6 percent-—for the period that we studied. 

Late reporting of crashes by states also affected the safety rankings of 

more than 600 carriers, both positively and negatively. When SafeStat 

analyzed the 2004 data, which did not include the late-reported crashes, it

identified 4,989 motor carriers as highest risk, meaning they received a 

category A or B ranking. With the addition of late-reported crashes, 481 

carriers moved into the highest risk category, and 182 carriers dropped out 

of the highest risk category, resulting in a net increase of 299 carriers (6 

percent) in the highest risk category. After the late-reported crashes were 

added, 481 carriers that originally received a category C, D, E, F, or G 

SafeStat rating received an A or B rating. These carriers would not 

originally have been given a high priority for a compliance review because

the SafeStat calculation did not take into account all of their crashes. On 

the other hand, a number of carriers would have fared better if the lateLate Reporting Had a 

Small Effect on SafeStat’s

Ability to Identify High-risk 

Carriers 

 1

For another assessment of data quality, see U.S. Department of Transportation Office of 

Inspector General, Improvements Needed in the Motor Carrier Safety Status 

Measurement System, Report MH-2004-034 (Washington, D.C.: Feb. 13, 2004). 

Motor Carrier Safety Oversight
Appendix II: FMCSA’s Crash Data Used to 

Compare Methods for Identifying High-Risk 

Carriers 

reported crashes had been included in their score. Specifically, 182 

carriers—or fewer than 4 percent of those ranked—fell from the A or B 

category into the C, D, E, F, or G category once the late-reported crashes 

were included.2

 These carriers would have avoided a compliance review if 

all crashes had been reported on time. Overall, however, the vast majority 

of carriers (96 percent) were not negatively affected by late reporting. 

The timeliness of crash reporting seems to be improving. The median 

number of days it took states to report crashes to MCMIS dropped from 

225 days in calendar year 2001 to 57 days in 2005 (the latest data available

at the time of our analysis).3

 In addition, the percentage of crashes 

reported by states within 90 days of occurrence has jumped from 32 

percent in fiscal year 2000 to 89 percent in fiscal year 2006. (See fig. 3.) 

Figure 3: Percentage of Crashes Submitted to MCMIS within 90 Days of Occurrence, 

Fiscal Years 2000 through 2006 

0

10

20

30

40

50

60

70

80

90

100

2000 2001 2002 2003 2004 2005 2006

Percentage

Source: GAO analysis of FMCSA data.

Fiscal year

 2

These 182 carriers were no longer in the worst 25 percent for the accident safety 

evaluation area after the addition of the late-reported crashes. 

3

One reason for the improvement in the timeliness of reporting for the most recent year is

that an unknown number of crashes that occurred in 2005 had still not been reported, as of 

June 2006, the date we obtained these data. 

Page 52 GAO-07-584 Motor Carrier Safety Oversight
Appendix II: FMCSA’s Crash Data Used to 

Compare Methods for Identifying High-Risk 

Carriers 

FMCSA uses a motor carrier identification number, which is unique to 

each carrier, as the primary means of linking inspections, crashes, and 

compliance reviews to motor carriers. Approximately 184,000 (75 percent) 

of the 244,000 crashes reported to MCMIS between December 2001 and 

June 2004 involved interstate carriers. Of these 184,000 crashes, nearly 

24,000 (13 percent) were missing this identification number. As a result, 

FMCSA could not match these crashes to motor carriers or use data from 

them in SafeStat. In addition, the carrier identification number could not 

be matched to one listed in MCMIS for 15,000 (8 percent) other crashes 

that involved interstate carriers. Missing data or data that cannot be 

matched to carriers for nearly one quarter of the crashes for the period of

our review potentially have a large impact on a motor carrier’s SafeStat 

score because SafeStat treats crashes as the most important source of 

information for assessing motor carrier crash risk. Theoretically, 

information exists to match crash records to motor carriers by other 

means, but such matching would require too much manual work to be 

practicable.

We were not able to quantify the actual effect of the missing data and the

data that could not be matched for MCMIS overall. To do so, we would 

have had to gather crash records at the state level—an effort that was 

impractical. For the same reason, we cannot quantify the effects of 

FMCSA’s efforts to improve the completeness of the data (discussed 

later). However, the University of Michigan Transportation Research 

Institute issued a series of reports analyzing the completeness of the data

submitted to MCMIS by the states.4

 One of the goals of the research was to 

determine the states’ crash reporting rates. Reporting rates varied greatly 

among the 14 states studied, ranging from 9 percent in New Mexico in 2003

to 83 percent in Missouri in 2005. It is not possible to draw wide-scale 

conclusions about whether states’ reporting rates are improving over time

because only 2 of the states—Missouri and Ohio—were studied in multiple 

years. However, the reporting rates of these 2 states did improve. Missouri 

experienced a large improvement in its reporting rate, with 61 percent of 

eligible crashes reported in 2001, and 83 percent reported in 2005. Ohio’s 

Incomplete Data from 

States Limit SafeStat’s

Identification of All

Carriers That Pose High 

Crash Risks 

 4

The University of Michigan Transportation Research Institute’s reports on state crash 

reporting can be found at http://www.umtri.umich.edu/publicationList.php? 

divID=4&t=8uFEHJI&plc=63|9||5|CHRON||||. State reports issued by the University of 

Michigan Transportation Research Institute cover California, Florida, Illinois, Iowa, 

Louisiana, Maryland, Michigan, Missouri, New Jersey, New Mexico, North Carolina, Ohio,

Washington, and Nebraska. We included all of these reports in our review. 

Page 53 GAO-07-584 Motor Carrier Safety Oversight
Appendix II: FMCSA’s Crash Data Used to 

Compare Methods for Identifying High-Risk 

Carriers 

improvement was more modest, increasing from 39 percent in 2000 to 43

percent in 2005. 

The University of Michigan Transportation Research Institute’s reports 

also identified a number of factors that may affect states’ reporting rates. 

One of the main factors affecting reporting rates is the reporting officer’s 

understanding of crash reporting requirements. The studies note that 

reporting rates are generally lower for less serious crashes and for crashes 

involving smaller vehicles, which may indicate that there is some 

confusion about which crashes are reportable. Some states, such as 

Missouri, aid the officer by explicitly listing reporting criteria on the police 

accident reporting form, while other states, such as Washington, leave it 

up to the officer to complete certain sections of the form if the crash is 

reportable, but the form includes no guidance on reportable crashes. 

Other states, such as North Carolina and Illinois, have taken this task out 

of officers’ hands and include all reporting elements on the police accident

reporting form. Reportable crashes are then selected centrally by the state, 

and the required data are transmitted to MCMIS. 

Inaccurate data, such as information on nonqualifying crashes reported to 

FMCSA, potentially have a large impact on a motor carrier’s SafeStat score 

because SafeStat treats crashes as the most important source of 

information for assessing motor carrier crash risk. The University of 

Michigan Transportation Research Institute’s reports on state crash 

reporting show that, among the 14 states studied, incorrect reporting of 

crash data is widespread. This inaccuracy limits SafeStat’s ability to 

identify carriers that pose high crash risks. In the most recent reports, the 

researchers found that, in 2005, Ohio incorrectly reported 1,094 (22 

percent) of the 5,037 cases it reported, and Louisiana incorrectly reported 

137 (5 percent) of the 2,699 cases it reported. In Ohio, most of the 

incorrectly reported crashes did not qualify because they did not meet the

crash severity threshold. In contrast, most of the incorrectly reported 

crashes in Louisiana did not qualify because they did not involve vehicles 

eligible for reporting. Other states studied by the institute had similar 

problems with reporting crashes that did not meet the criteria for 

reporting to MCMIS. The addition of these nonqualifying crashes could 

cause some carriers to exceed the minimum number of crashes required to

receive a SafeStat rating and result in SafeStat’s mistakenly identifying 

carriers as posing high crash risks. Because each report focuses on 

reporting in one state in a particular year, it is not possible to identify the 

number of cases that have been incorrectly reported nationwide and, 

Inaccurate Data 

Potentially Limit SafeStat’s

Ability to Identify Carriers 

That Pose High Crash 

Risks 

Page 54 GAO-07-584 Motor Carrier Safety Oversight
Appendix II: FMCSA’s Crash Data Used to 

Compare Methods for Identifying High-Risk 

Carriers 

therefore, it is not possible to determine the impact of inaccurate reporting

on SafeStat’s calculations. 

We also found examples of crashes that are reported to MCMIS but cannot 

be used by SafeStat because of data errors. Specifically, we found that the 

carrier’s identification number cannot be matched to an identification 

number in MCMIS in 8 percent of reported crashes. FMCSA cannot link 

these crashes to specific carriers without an accurate identification 

number and, therefore, cannot use these crashes in the SafeStat model to 

identify carriers that pose high crash risks. 

As noted in the University of Michigan Transportation Research Institute’s 

reports, states may be unintentionally submitting incorrect data to MCMIS

because of difficulties in determining whether a crash meets the reporting 

criteria. For example, in Missouri, pickups are systematically excluded

from MCMIS crash reporting, which may cause the state to miss some 

reportable crashes. This may occur because, in recent years, a number of 

pickups have been equipped with rear axles that may increase their weight 

above the reporting threshold and make crashes involving them eligible 

for reporting. There is no way for the state to determine which crashes 

involving pickups qualify for reporting without examining the 

characteristics of each vehicle. In this case, the number of omissions is 

likely to be relatively small, but this example demonstrates the difficulty

states may face when identifying reportable crashes. 

In addition, in some states, the information contained in the police 

accident report may not be sufficient for the state to determine if a crash 

meets the accident severity threshold. It is generally straightforward to 

determine whether a fatality occurred as a result of a crash, but it may be 

difficult to determine whether an injured person was transported for 

medical attention or a vehicle was towed because of disabling damage. In

some states, such as Illinois and New Jersey, an officer can indicate on the 

form if a vehicle was towed by checking a box, but there is no way to 

identify whether the reason for towing was disabling damage. It is likely 

that such uncertainty results in overreporting because some vehicles may 

be towed for other reasons. 

Page 55 GAO-07-584 Motor Carrier Safety Oversight
Appendix II: FMCSA’s Crash Data Used to 

Compare Methods for Identifying High-Risk 

Carriers 

FMCSA has taken steps to try and improve the quality of crash data 

reporting. As we noted in November 2005, FMCSA has undertaken two 

major efforts to help states improve the quality of crash data.5

 One 

program, the Safety Data Improvement Program, has provided funding to

states to implement or expand activities designed to improve the 

completeness, timeliness, accuracy, and consistency of their data. FMCSA 

has also used a data quality rating system to rate and display ratings for 

the quality of states’ crash and inspection data. Because these ratings are 

public, this system creates an incentive for states to improve their data 

quality. 

To further improve these programs, FMCSA has awarded additional grants 

to several states and implemented our recommendations to (1) establish 

specific guidelines for assessing states’ requests for funding to support 

data improvement in order to better assess and prioritize the requests and

(2) increase the usefulness of its state data quality map as a tool for 

monitoring and measuring commercial motor vehicle crash data by 

ensuring that the map adequately reflects the condition of the states’ 

commercial motor vehicle crash data.

In February 2004, FMCSA implemented Data Q’s, an online system that 

allows for challenging and correcting erroneous crash or inspection data. 

Users of this system include motor carriers, the general public, state 

officials, and FMCSA. In addition, in response to a recent recommendation 

by the Department of Transportation Inspector General, FMCSA is 

planning to conduct a number of evaluations of the effectiveness of a 

training course on crash data collection that it will be providing to states 

by September 2008. 

While the quality of crash data is sufficient for use in assessing whether 

different approaches to categorizing carriers could lead to better 

identification of carriers that subsequently have high crash rates and has

started to improve, commercial motor vehicle crash data continue to have

some problems with timeliness, completeness, and accuracy. These 

problems have been well-documented in several studies, and FMCSA is 

taking steps to address the problems through studies of each state’s crash 

reporting system and grants to states to fund improvements. As a result, 

we are not making any recommendations in this area. 

FMCSA Has Undertaken 

Efforts to Improve Crash 

Data Quality 

 5

GAO, Highway Safety: Further Opportunities Exist to Improve Data on Crashes 

Involving Commercial Motor Vehicles, GAO-06-102 (Washington, D.C.: Nov. 18, 2005). 

Page 56 GAO-07-584 Motor Carrier Safety Oversight
Appendix III: Rev

of Motor Carrier and Driver Crash Risk 

iew of Studies on Predictors 

Page 57 GAO-07-584

Appendix III: Review of Studies on Predictors 

of Motor Carrier and Driver Crash Risk 

Several studies have identified relationships between certain

characteristics of motor carriers and drivers and their crash risks. Theses 

characteristics include carrier financial performance, carrier size, driver 

pay, and driver age. 

The studies we reviewed assessed whether financial performance or other 

characteristics of carriers, such as size, are associated with crash risk. 

Our 1991 study developed a model that linked changes in economic 

conditions to declining safety performance in the trucking industry.1

 The 

study hypothesized that a decline in economic performance among motor 

carriers leads to a decline in safety performance in one or more of the 

following ways: (1) a lowering of the average quality of driver

performance; (2) downward wage pressures encouraging driver 

noncompliance with safety regulations; (3) less management emphasis on 

safety practices; (4) deferred truck maintenance and replacement; and/or 

(5) the introduction of larger, heavier, multitrailer trucks. Using data on

537 carriers drawn from the Department of Transportation and the 

Interstate Commerce Commission, we found that seven financial ratios 

show promise as predictors of truck firms’ safety. For five of the seven 

financial variables we examined, firms in the weakest financial position 

had the highest subsequent accident rates. For example, weakness in any 

of three measures of profitability—return on equity, operating ratio, and 

net profit margin—was associated with subsequent safety problems as 

measured by accident rates. 

On behalf of FMCSA, a study carried out by Corsi, Barnard, and Gibney in

2002 examined how data on carriers’ financial performance correlate with 

a carrier’s safety rating following a compliance review.2

 The authors 

selected motor carriers from MCMIS in December 2000 with complete data 

for the accident, driver, vehicle, and safety management safety evaluation 

areas. Using these data, the authors then matched a total of 700 carriers to 

Relationship of Motor 

Carrier Characteristics and 

Crash Risk 

Carrier Financial Performance 

 1

GAO, Freight Trucking: Promising Approach for Identifying Carriers’ Safety Risks, 

GAO/PEMD-91-13 (Washington, D.C.: Apr. 4, 1991). 

2

T. Corsi, R. Barnard, and J. Gibney, “Motor Carrier Industry Profile: Linkages Between 

Financial and Safety Performance Among Carriers in Major Industry Segments,” Robert H.

Smith School of Business at the University of Maryland, October 2002. 

Motor Carrier Safety Oversight
Appendix III: Review of Studies on Predictors 

of Motor Carrier and Driver Crash Risk 

company financial statements in the annual report database of the 

American Trucking Associations.3

 The authors found that carriers that 

received satisfactory ratings following a compliance review performed 

better on two financial measures—operating ratio and return on assets—

than carriers that received lower ratings. 

Two practical considerations limit the applicability of the findings from 

these two studies to SafeStat. First, the studies’ samples of 537 and 700 

carriers, respectively, are not representative of the motor carriers that 

FMCSA oversees. For example, our sample included only the largest forhire interstate carriers because these were the only carriers that were 

required to report financial information to the federal government. The 

carriers selected for the Corsi and others’ study were also not 

representative because a very small percentage of the carriers evaluated 

by the SafeStat model in June 2004 had scores for all four safety evaluation 

areas. About 2 percent had a score for the the safety management safety 

evaluation area, and of these, not all had complete data for the other three 

safety evaluation areas. Second, FMCSA does not receive annual financial 

statements from carriers and, according to an FMCSA official, it is unlikely 

that the agency could obtain the authority it would need to require 

financial statements from all carriers. In addition, because the 

relationships identified by our study are based on data and economic 

conditions that are almost 20 years old, the relationships would need to be

reanalyzed within current conditions to determine whether they still exist. 

As part of its Comprehensive Safety Analysis 2010 reform initiative, 

discussed earlier in this report, FMCSA decided not to use financial data to

help assess the safety risk of firms because of the limited availability of 

these data. 

A 1994 study by Moses and Savage found that crash rates decline as firm 

size increases; the largest 10 percent of firms have an accident rate that is 

one-third the rate of the smallest 10 percent of firms.4

 Our 1991 study 

found that the smallest carriers, as a group, had an accident rate that 

exceeded the rate for all firms by 20 percent. The study by Moses and 

Savage also found that (1) private fleets that serve the needs of their 

parent companies, such as manufacturers and retailers, have accident 

Other Carrier Characteristics 

 3

The American Trucking Associations is an association of trucking associations. Its mission

is to serve and represent the interests of the trucking industry. 

4

L.N. Moses and I. Savage, “The Effect of Firm Characteristics on Truck Accidents,” 

Accident Analysis and Prevention 26, no. 2 (1994). 

Page 58 GAO-07-584 Motor Carrier Safety Oversight
Appendix III: Review of Studies on Predictors 

of Motor Carrier and Driver Crash Risk 

rates that are about 20 percent lower than the rates of carriers that offer 

for-hire trucking; (2) carriers of hazardous materials have accident rates 

that are 22 percent higher than the rates of carriers that do not transport 

these goods; and (3) general freight carriers have accident rates that are 10 

percent higher than the rates of other freight carriers. We believe that 

Moses and Savage’s findings are reasonable given their study’s design, 

data, and methodology, but because the findings are based on data and 

economic conditions that are about 15 to 20 years old, current data would

need to be reanalyzed within current conditions to determine whether the 

findings are still valid. As mentioned above, our study shares this 

limitation and is further limited by an unrepresentative sample of motor 

carriers. An FMCSA official told us that the agency would not want to rely 

directly on data on the size of the carrier to assess safety risk because the 

agency believes that its data on indicators of carrier size, such as revenue, 

number of drivers, and number of power units, are not of sufficient quality.

Similarly, the agency would not want to distinguish between private and

for-hire carriers or between carriers that carry different types of freight 

because it does not believe that its data are sufficiently reliable. 

The studies we reviewed assessed whether driver characteristics—

including convictions for traffic violations, age and experience, pay, or 

frequency of job changes—are associated with crash risk. 

A series of studies by Lantz and others examined the effect of

incorporating conviction data from the state-run commercial driver license

data system into the calculation of carriers’ safety management safety 

evaluation area scores.5

 The studies found that the resulting driver 

conviction measure is weakly correlated with the crash-per-vehicle rate.

6

However, the studies did not calculate new safety management safety 

evaluation area scores with the proposed driver conviction measure and 

then use the updated measure to estimate new SafeStat scores for carriers. 

FMCSA uses data on driver convictions to help target its roadside 

inspections, and it is considering using such data in the tool it is 

Relationship of Driver 

Characteristics and Crash 

Risk 

Driver Convictions for Traffic 

Violations 

 5

B. Lantz and D. Goettee, An Analysis of Commercial Vehicle Driver Traffic Conviction

Data to Identify Higher Safety Risk Motor Carriers, Upper Great Plains Transportation 

Institute and FMCSA, March 2004. B. Lantz, Development and Implementation of a Driver

Safety History Indicator into the Roadside Inspection Selection System, FMCSA, April 

2006. 

6

Correlation = 0.085. (FMCSA, Development and Implementation of a Driver Safety 

History Indicator into the Roadside Inspection Selection System, April 2006, 14). 

Page 59 GAO-07-584 Motor Carrier Safety Oversight
Appendix III: Review of Studies on Predictors 

of Motor Carrier and Driver Crash Risk 

developing to replace SafeStat as part of its Comprehensive Safety 

Analysis 2010 reform initiative. 

Campbell’s 1991 study found that the risk of a fatal crash is significantly 

higher for younger truck drivers than for older drivers.7

 Campbell used 

data from surveys of fatal crashes and large truck travel to calculate fatal 

involvement rates per mile driven by driver age. Overall, fatal involvement 

rates remained high through age 26. The fatal crash rates for drivers under 

19 years of age were four times higher than the rate for all drivers, and the 

rates for drivers aged 19 to 20 years were six times higher. Our 1991 study 

found that younger, less experienced drivers posed greater-than-average 

accident risks. In particular, compared with drivers 40 to 49 years of age,

drivers 21 to 39 years of age have 28 percent greater odds of accident 

involvement. Compared with those for drivers over 50 years of age, the 

odds of the youngest group of drivers having an accident are about 60 

percent greater. The differences in accident risks between drivers with 0 

to 13 years of experience, 14 to 20 years of experience, and 21 or more 

years of experience followed a very similar pattern. Although Campbell’s 

study provides only limited information about the quality of the data it

used, we believe that its findings are reasonable given the study’s design 

and methodology, which relied on multiple kinds of analyses to 

substantiate a higher risk for younger drivers of large trucks. We believe 

that our 1991 findings are reasonable given our study’s design, data, and 

methodology. An FMCSA official told us that, at this time, the agency 

would not be able to use driver age in SafeStat or in a similar model 

because the agency does not have access to data on all drivers. FMCSA 

said that it is exploring the possibility of gaining broader access to data on 

drivers, which are maintained by the states, so that the agency can use the 

data to help assess the safety of drivers as part of its Comprehensive 

Safety Analysis 2010 reform initiative. 

Belzer and others’ 2002 study found that drivers with lower pay had higher 

crash rates.8

 Because economic theory predicts that low pay levels are 

associated with poorer performing workers, the study hypothesized that 

low pay levels for drivers are associated with unsafe driving. The study 

found that for every 10 percent more in average driver compensation 

Driver Age and Experience 

Driver Pay

 7

K. L. Campbell, “Fatal Accident Rates by Driver Age for Large Trucks,” Accident Analysis

and Prevention 23, no. 4 (1991). 

8

M. H. Belzer, D. Rodriguez, and S.A. Sedo, “Paying for Safety: An Economic Analysis of the 

Effect of Compensation on Truck Driver Safety,” prepared for FMCSA, September 2002. 

Page 60 GAO-07-584 Motor Carrier Safety Oversight
Appendix III: Review of Studies on Predictors 

of Motor Carrier and Driver Crash Risk 

(mileage rate, unpaid time, anticipated annual raise, safety bonus, health

insurance, and life insurance), the carriers experienced 9.2 percent fewer 

crashes. We believe that this finding is reasonable given the study’s design, 

data, and methodology. An FMCSA official told us that the agency could 

not use data on driver pay in SafeStat or in a similar model because such 

data are available only from studies or surveys that do not cover the full 

population of drivers. 

Staplin and others’ 2003 study for FMCSA found that drivers that average 

three or more jobs with different carriers each year have crash rates that 

are more than twice as high as drivers that average fewer job changes.9

Although the study authors acknowledge several limitations in the data 

used in study, we believe that the data and the analysis approach were 

sufficiently reliable to support the study’s finding of a relationship 

between the number of jobs and the number of crashes. An FMCSA official 

told us that, as for data on driver pay, the agency could not use data on the 

frequency of job changes in SafeStat or in a similar model because such 

data are available only from studies or surveys that do not cover the full 

population of drivers. 

Frequency of Job Changes 

 9

L. Staplin, K. Gish, L. Decina, and R. Brewster, “Commercial Motor Vehicle Driver 

Retention and Safety,” FMCSA-RT-03-004 (Washington, D.C.: March 2003). 

Page 61 GAO-07-584 Motor Carrier Safety Oversight
Appendix IV: Scope and Methodology Appendix IV: Scope and Methodology 

To determine the extent to which FMCSA’s policy for prioritizing 

compliance reviews targets carriers that subsequently have high crash 

rates, we analyzed data from FMCSA’s MCMIS on the June 2004 SafeStat 

assessment of carriers and on the assessed carriers’ crashes in the 18

months following the SafeStat assessment. We selected June 2004 because 

this date enabled us to examine MCMIS data on actual crashes that 

occurred in the 18-month period from July 2004 through December 2005.1

We defined various groups of carriers for analysis, such as those in each 

SafeStat category, those to which FMCSA gave high priority (i.e., those in

categories A or B), and those in the worst 5 or 10 percent of carriers in a 

particular safety evaluation area without being in the worst 25 percent of 

carriers in any other area. We then calculated the aggregate crash rate in

the 18 months following the SafeStat assessment for each of these groups 

by dividing the total crashes experienced by all the carriers in a group 

during that time period by the total number of vehicles operated by those 

carriers, as reported on their motor carrier census form. We then 

compared crash rates among the various groups to determine whether 

there were any groups with substantially higher aggregate crash rates than 

the carriers in SafeStat categories A or B. We also talked to FMCSA 

officials about how FMCSA developed SafeStat, their views on other 

evaluations of SafeStat, and FMCSA’s plans to replace SafeStat with a new 

tool. 

In assessing how FMCSA ensures that its compliance reviews are 

completed thoroughly and consistently, we reviewed our report on 

internal control standards for the federal government. We identified key 

standards in the areas that we believe are critical to maintaining the 

thoroughness and consistency of compliance reviews, namely the 

recording and communication of policy to management and others, the 

clear documentation of processes, and the monitoring and reviewing of 

activities and findings. We assessed the extent to which FMCSA’s 

management of its compliance reviews is consistent with these internal 

control standards by interviewing FMCSA and state managers and 

investigators. We interviewed investigators who conduct compliance 

reviews and their managers in FMCSA’s headquarters office, as well as in 7 

of FMCSA’s 52 field division offices that work with states, two of its four 

regional service centers that support division offices, and three state 

 1

We obtained crash data for this period that were reported to FMCSA through June 2006.

This allowed us to obtain data on late-reported crashes for the July 2004 through December

2005 period. 

Page 62 GAO-07-584 Motor Carrier Safety Oversight
Appendix IV: Scope and Methodology 

offices that partner with 3 of the FMCSA division offices in which we did 

our work.2

 We also interviewed two safety investigators in each of the 

same 7 division offices. The division offices and states that we reviewed—

California, Georgia, Illinois, New York, Ohio, Pennsylvania, and Texas—

received 30 percent of all the of the grant funds that FMCSA awarded to 

the states in fiscal year 2005 (the latest year for which data were available)

through its primary grant program, the Motor Carrier Safety Assistance 

Program. Because we chose the seven states judgmentally (representing 

the largest grantees), we cannot project our findings nationwide.3 

Reviewing a larger number of grantees would not have been practical 

because of resource constraints. 

We gathered information on the recording and communication of policy 

from discussions with FMCSA officials, documents, and system software,

including the electronic operations manual. We obtained information 

about how FMCSA documents the findings of compliance reviews through 

discussions with FMCSA officials and reviews of FMCSA documents. We 

obtained information on how FMCSA monitors and reviews the 

performance of its compliance reviews through discussions with FMCSA 

officials and reviews of FMCSA documents, including the 2002 report of 

FMCSA’s Compliance Review Work Group. The data assessments of the 

number of vehicles inspected during compliance reviews and the 

percentage of applicable areas of the regulations covered by compliance 

reviews since 2001 were provided to us by FMCSA. 

In assessing the extent to which FMCSA follows up with carriers with 

serious violations, we reviewed regulations directing how FMCSA should 

follow up and track these violators and analyzed data to determine if 

FMCSA had met these policies. Particularly, we examined FMCSA policies 

and discussed with FMCSA officials the agency’s policy to perform a 

follow-up compliance review on carriers in SafeStat categories A and B, its 

policy to place carriers rated unsatisfactory out of service, its policy to 

perform a follow-up compliance review on carriers with a conditional 

rating, and its reduction of its enforcement backlog. Additional analysis 

 2

We did not interview managers or investigators in three of the seven states because they

do not conduct compliance reviews of interstate carriers, and we did not interview 

managers or investigators in one state because they did not respond to our attempts to 

contact them. 

3

Results from nonprobability samples cannot be used to make inferences about a

population, because in a nonprobability sample some elements of the population being

studied have no chance or an unknown chance of being selected as part of the sample. 

Page 63 GAO-07-584 Motor Carrier Safety Oversight
Appendix IV: Scope and Methodology 

was performed—as of the end of each fiscal year from 2001 through 

2006—using data from FMCSA’s MCMIS to determine the total number of 

carriers with a conditional rating that had not received a follow-up 

compliance review. We also used MCMIS to determine how many carriers 

with a conditional rating received a follow-up compliance review and how 

soon after the original compliance review the second review occurred. 

To assess FMCSA’s implementation of the statutory requirement to assess 

the maximum fine against any carrier with either a pattern of violations or 

previously committed violations, we compared FMCSA’s policy with the 

language of the act and held discussions with FMCSA officials. In addition, 

we assessed the number of carriers that would have been assessed the 

maximum fine under differing definitions of a pattern of violations. We 

also reviewed the report of the Department of Transportation Inspector 

General on the implementation of the policy and documents pertaining to

FMCSA’s response to the Inspector General’s report. 

In determining the reliability of FMCSA’s data on compliance reviews, 

violations, and enforcement cases, we performed electronic testing for 

obvious errors in accuracy and completeness. As part of a recent 

evaluation of FMCSA’s enforcement programs, we interviewed officials 

from FMCSA’s data analysis office who are knowledgeable about the same 

data sources. We determined that the data were sufficiently reliable for the 

types of analysis we present in this report. 

To assess the extent to which the timeliness, completeness, and accuracy

of MCMIS and state-reported crash data affect SafeStat’s performance, we 

carried out a series of analyses with the MCMIS master crash file, and the 

MCMIS census file, as well as surveying the literature to assess other 

studies’ findings on the quality of MCMIS data. To assess timeliness, we 

first measured how many days on average it was taking each state to 

report crashes to FMCSA by year for calendar years 2000 through 2005. We 

also recalculated SafeStat scores from June 25, 2004, to include crashes 

that had occurred more than 90 days previously but had not yet been 

reported to FMCSA by that date. We compared the number and rankings 

of carriers from the original SafeStat results with those obtained with the 

addition of late-reported crashes. In addition, we reviewed the University 

of Michigan Transportation Research Institute’s studies of state crash 

reporting to MCMIS to identify the impact of late reporting in individual 

states on MCMIS data quality. 

To assess completeness, we attempted to match all crash records in the 

MCMIS master crash file for crashes occurring between December 2001 

Page 64 GAO-07-584 Motor Carrier Safety Oversight
Appendix IV: Scope and Methodology 

and June 2004 to the list of motor carriers in the MCMIS census file. We 

used a variety of matching techniques to try and match the crash records 

without a carrier Department of Transportation number to carriers listed 

in the MCMIS census file. In addition, we reviewed the University of 

Michigan Transportation Research Institute’s studies of state crash 

reporting to MCMIS to identify the impact of incomplete crash reporting in

individual states on MCMIS data quality. 

To assess accuracy, we reviewed an audit by the Inspector General that 

tested the accuracy of electronic data by comparing records selected in 

the sample to source paper documents. In addition, we reviewed the 

University of Michigan Transportation Research Institute’s studies of state 

crash reporting to MCMIS to identify the impact of incorrectly reported 

crashes in individual states on MCMIS data quality. 

We determined that the data reported to FMCSA for use in SafeStat—

while not as timely, complete, or accurate as they could be—were of 

sufficient quality for our use. Through our analyses, we found that the data

identify many carriers that pose high crash risks and are, therefore, useful 

for the purposes of this report. 

To understand what other researchers have found about how well SafeStat 

identifies motor carriers that pose high crash risks, we identified studies 

through a general literature review and by asking stakeholders and study 

authors to identify high-quality studies. The studies included in our review 

were (1) the 2004 study of SafeStat done by Oak Ridge National 

Laboratory, (2) the SafeStat effectiveness studies done by the Department 

of Transportation Inspector General and Volpe Institute, (3) the University 

of Michigan Transportation Research Institute’s studies of state crash 

reporting to FMCSA, and (4) the 2006 audit by the Department of 

Transportation Inspector General of data for new entrant carriers.4

 We 

 4

Campbell, Schmoyer, and Hwang, Review of the Motor Carrier Safety Status 

Measurement System (SAFESTAT), 2004; U.S. Department of Transportation Office of

Inspector General, Improvements Needed in the Motor Carrier Safety Status 

Measurement System, Report MH-2004-034 (Washington, D.C.: Feb. 13, 2004); Madsen and

Wright, Volpe National Transportation Systems Center, An Effectiveness Analysis of 

SafeStat, November 1998; Volpe National Transportation Systems Center, SafeStat 

Effectiveness Study Update, March 2004; University of Michigan Transportation Research 

Institute MCMIS State Reports; U.S. Department of Transportation Office of Inspector 

General, Significant Improvements in Motor Carrier Safety Program Since 1999 Act but 

Loopholes for Repeat Violators Need Closing, Report MH-2006-046 (Washington, D.C.: Apr. 

21, 2006). 

Page 65 GAO-07-584 Motor Carrier Safety Oversight
Appendix IV: Scope and Methodology 

assessed the methodology used in each study and identified which 

findings are supported by rigorous analysis. We accomplished this analysis 

by relying on information presented in the studies and, where possible, 

discussing the studies with the authors. When the studies’ methodologies 

and analyses appeared reasonable, we used the findings from those 

studies in our analysis of SafeStat. We discussed with FMCSA and industry 

and safety stakeholders the SafeStat methodology issues and data quality 

issues raised by these studies. We also discussed the aptness of the 

respective methodological approaches with FMCSA. Finally, we reviewed 

FMCSA documentation on how SafeStat is constructed and assessments of 

SafeStat conducted by FMCSA. 

To identify studies on predictors of motor carrier and driver crash risk, we 

conducted a general literature review. We shared this preliminary list of 

studies with the members of the Transportation Research Board’s 

Committee on Truck and Bus Safety and requested them to identify 

additional relevant studies.5

 We selected those studies that assessed a 

relationship between one or more motor carrier or driver characteristics 

and crash risk. Based on information presented in the selected studies, we 

assessed the methodology used in each study and report only those 

findings that were based on sound methodology and analysis. 

 5

The Transportation Research Board is a unit of the National Research Council, a private, 

nonprofit institution that is the principal operating agency of the National Academy of

Sciences and the National Academy of Engineering. The board’s mission is to promote 

innovation and progress in transportation by motivating and conducting research, 

facilitating the dissemination of information, and encouraging the implementation of

research results. 

Page 66 GAO-07-584 Motor Carrier Safety Oversight
Appendix V: 

A

GAO Contact and Staff 

cknowledgments 

Page 67 GAO-07-584

Appendix V: GAO Contact and Staff 

Acknowledgments 

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

In addition to the individual named above, James Ratzenberger, Assistant 

Director; Carl Barden; Elizabeth Eisenstadt; David Goldstein; Ryan 

Gottschall; Laurie Hamilton; Eric Hudson; Bert Japikse; and Gregory 

Wilmoth made key contributions to this report. 

GAO Contact 

Staff 

Acknowledgments 

(541024) Motor Carrier Safety Oversight
GAO’s Mission The Government Accountability Office, the audit, evaluation and 

investigative arm of Congress, exists to support Congress in meeting its 

constitutional responsibilities and to help improve the performance and 

accountability of the federal government for the American people. GAO 

examines the use of public funds; evaluates federal programs and policies; 

and provides analyses, recommendations, and other assistance to help

Congress make informed oversight, policy, and funding decisions. GAO’s 

commitment to good government is reflected in its core values of 

accountability, integrity, and reliability. 

The fastest and easiest way to obtain copies of GAO documents at no cost

is through GAO’s Web site (www.gao.gov). Each weekday, GAO posts 

newly released reports, testimony, and correspondence on its Web site. To

have GAO e-mail you a list of newly posted products every afternoon, go 

to www.gao.gov and select “Subscribe to Updates.” 

The first copy of each printed report is free. Additional copies are $2 each. 

A check or money order should be made out to the Superintendent of 

Documents. GAO also accepts VISA and Mastercard. Orders for 100 or 

more copies mailed to a single address are discounted 25 percent. Orders 

should be sent to: 

U.S. Government Accountability Office 

441 G Street NW, Room LM 

Washington, D.C. 20548 

To order by Phone: Voice: (202) 512-6000 

TDD: (202) 512-2537 

Fax: (202) 512-6061 

Contact: 

Web site: www.gao.gov/fraudnet/fraudnet.htm

E-mail: fraudnet@gao.gov

Automated answering system: (800) 424-5454 or (202) 512-7470 

Gloria Jarmon, Managing Director, JarmonG@gao.gov (202) 512-4400 

U.S. Government Accountability Office, 441 G Street NW, Room 7125 

Washington, D.C. 20548 

Susan Becker, Acting Manager, BeckerS@gao.gov (202) 512-4800 

U.S. Government Accountability Office, 441 G Street NW, Room 7149 

Washington, D.C. 20548 

Obtaining Copies of 

GAO Reports and 

Testimony

Order by Mail or Phone 

To Report Fraud,

Waste, and Abuse in 

Federal Programs 

Congressional 

Relations 

Public Affairs 

PRINTED ON RECYCLED PAPER