Agricultural Commodity and Utility Carriers 

Hours of Service Exemption Analysis 

May 2010
FOREWORD 

The purpose of this study was to assess the safety performance of agricultural commodity and 

utility service carriers that are exempt from the Federal Motor Carrier Safety Regulations 

regarding hours of service or record-of-duty-status requirements in comparison to those that are 

not exempt. The purpose of this report was to document the method, results, and conclusions 

from this study. 

NOTICE 

This document is disseminated under the sponsorship of the U.S. Department of Transportation 

in the interest of information exchange. The United States Government assumes no liability for 

its contents or the use thereof. 

The contents of this Report reflect the views of the contractor, who is responsible for the 

accuracy of the data presented herein. The contents do not necessarily reflect the official policy 

of the U.S. Department of Transportation. 

This Report does not constitute a standard, specification, or regulation. 

The United States Government does not endorse products or manufacturers named herein. Trade 

or manufacturers’ names appear herein solely because they are considered essential to the object 

of this report. 
Technical Report Documentation Page—Form DOT F 1700.7 (8-72) 

1. Report No. 

FMCSA-RRA-10-048 

2. Government Accession No. 3. Recipient's Catalog No. 

5. Report Date 

May 2010 

4. Title and Subtitle 

AGRICULTURAL COMMODITY AND UTILITY CARRIERS 

HOURS OF SERVICE EXEMPTION ANALYSIS 6. Performing Organization Code 

7. Author(s) 

Phase 1: Annalynn Lacombe, Dennis Piccolo, Volpe Center 

Phase 2: Mokbul Khan, FMCSA Analysis Division 

Consolidated Report: William Bannister, FMCSA Analysis Division 

8. Performing Organization Report No. 

9. Performing Organization Name and Address 10. Work Unit No. (TRAIS) 

Phase 1: 

John A. Volpe National Transportation Systems Center 

55 Broadway / Cambridge, MA 02142 

Phase 2: 

U.S. Department of Transportation 

Federal Motor Carrier Safety Administration 

Office of Analysis, Research and Technology, Analysis Division 

1200 New Jersey Ave. SE / Washington, DC 20590

11. Contract or Grant No. 

13. Type of Report and Period Covered 

Final Report, 

January 2005–February 2010 

12. Sponsoring Agency Name and Address 

U.S. Department of Transportation 

Federal Motor Carrier Safety Administration 

Office of Analysis, Research and Technology 

1200 New Jersey Ave. SE 

Washington, DC 20590 

14. Sponsoring Agency Code 

15. Supplementary Notes 

16. Abstract 

The study was conducted in two phases. Phase 1 compares the safety performance of agricultural and nonagricultural carriers for the period 2005 through 2008, and also examines two additional industries: livestock and 

utility carriers, whose operations were not exempt from Hours Of Service (HOS) regulations prior to the 2005 

passage of SAFETEA-LU. The Phase 1 analysis used carrier registration, inspection, and crash data from the 

Motor Carrier Management Information System (MCMIS). Key findings were that, nationally, agricultural 

carriers operating within a 100-air-mile radius had lower crash rates per 100 power units than those operating 

beyond this radius, except for 2008, when there was no difference in the crash rates. Also, agricultural carriers 

exempt from HOS had higher out of service (OOS) and/or violation rates than non-exempt carriers for regulations 

pertaining to driver qualifications, vehicle maintenance, and improper loading and securement. For the Phase 2 

analysis, inspection data of agricultural commodity and utility carriers was collected during an FMCSA special 

study of a sample of States. These data included only those inspections occurring during the States’ planting and 

harvesting seasons. Key finding were that agricultural carriers in the survey operating beyond a 100-air-mile 

radius had a statistically higher driver OOS rate than those driving within a 100-air-mile radius, but those 

operating within a 100-air-mile radius had a statistically higher vehicle OOS rate. Also, agricultural carriers in the 

survey that were subject to the HOS requirements had higher crash rates per 100 power units than agricultural 

carriers that were exempt from the HOS requirements. Both Phase 1 and Phase 2 analyses have data limitations. 

17. Key Words 

agricultural commodity carrier, HOS, hours of service, OOS, out of 

service, utility service carrier 

18. Distribution Statement 

No restrictions 

19. Security Classif. (of this report) 

Unclassified 

20. Security Classif. (of this page) 

Unclassified 

21. No. of Pages 

46 

22. Price 

Form DOT F 1700.7 (8-72) Reproduction of completed page authorized. 
SI* (MODERN METRIC) CONVERSION FACTORS 

Table of APPROXIMATE CONVERSIONS TO SI UNITS 

Symbol When You Know Multiply By To Find Symbol 

LENGTH 

In inches 25.4 millimeters mm 

Ft feet 0.305 meters m 

Yd yards 0.914 meters m 

Mi miles 1.61 kilometers km 

AREA 

in2 square inches 645.2 square millimeters mm2 

ft2 square feet 0.093 square meters m2 

yd2 square yards 0.836 square meters m2 

Ac acres 0.405 hectares ha 

mi2 square miles 2.59 square kilometers km2 

VOLUME Note: Volumes greater than 

1000 L shall be shown in m3 

fl oz fluid ounces 29.57 milliliters mL 

Gal gallons 3.785 liters L 

ft3 cubic feet 0.028 cubic meters m3 

yd3 cubic yards 0.765 cubic meters m3 

MASS 

Oz ounces 28.35 grams g 

Lb pounds 0.454 kilograms kg 

T short tons (2000 lb) 0.907 megagrams (or “metric ton”) Mg (or “t”) 

TEMPERATURE temperature is in exact degrees 

°F Fahrenheit 5 × (F-32) ÷ 9 

or (F-32) ÷ 1.8 

Celsius °C 

ILLUMINATION 

Fc foot-candles 10.76 lux lx 

Fl foot-Lamberts 3.426 candela/m2 cd/m2 

Force and Pressure or Stress 

Lbf poundforce 4.45 Newtons N 

lbf/in2 poundforce per square inch 6.89 kilopascals kPa 

Table of APPROXIMATE CONVERSIONS FROM SI UNITS 

Symbol When You Know Multiply By To Find Symbol 

LENGTH 

Mm millimeters 0.039 inches in 

M meters 3.28 feet ft 

M meters 1.09 yards yd 

Km kilometers 0.621 miles mi 

AREA 

mm2 square millimeters 0.0016 square inches in2 

m2 square meters 10.764 square feet ft2 

m2 square meters 1.195 square yards yd2 

Ha hectares 2.47 acres ac 

km2 square kilometers 0.386 square miles mi2 

VOLUME 

mL milliliters 0.034 fluid ounces fl oz 

L liters 0.264 gallons gal 

m3 cubic meters 35.314 cubic feet ft3 

m3 cubic meters 1.307 cubic yards yd3 

MASS 

G grams 0.035 ounces oz 

Kg kilograms 2.202 pounds lb 

Mg (or “t”) megagrams (or “metric ton”) 1.103 short tons (2000 lb) T 

TEMPERATURE temperature is in exact degrees 

°C Celsius 1.8C + 32 Fahrenheit °F 

ILLUMINATION 

Lx lux 0.0929 foot-candles fc 

cd/m2 candela/m2 0.2919 foot-Lamberts fl 

Force & Pressure or Stress 

N Newtons 0.225 poundforce lbf 

kPa Kilopascals 0.145 poundforce per square inch lbf/in2 

* SI is the symbol for the International System of Units. Appropriate rounding should be made to comply with Section 4 of ASTM E380. 

(Revised March 2003, Section 508-accessible version September 2009) 

ii 
TABLE OF CONTENTS 

LIST OF ACRONYMS .............................................................................................................. VI

EXECUTIVE SUMMARY .......................................................................................................VII

1. BACKGROUND ...................................................................................................................1

2. PHASE 1 METHODOLOGY..............................................................................................3

2.1 CARRIER COMMODITY GROUPS ...........................................................................3

2.2 CRASH, OOS, AND VIOLATION DATA ..................................................................4

2.3

.......................................................................................................................5

BEHAVIOR ANALYSIS AND SAFETY IMPROVEMENT CATEGORIES 

(BASICS)

3. PHASE 1 FINDINGS............................................................................................................7

3.1 CRASH RATES ............................................................................................................7

3.1.1

................................................................................................................... 7

Agricultural Carriers with All Drivers Operating Within or Beyond a 100-AirMile Radius

3.1.2 “Before and After” Crash Rates for Utility and Livestock Carriers................. 9

3.2 OOS AND VIOLATION RATES ...............................................................................11

3.2.1 Agricultural and Non-Agricultural Carriers.................................................... 11

3.2.2

................................................................................................................. 14

Agricultural Carriers with All Drivers Operating Within or Beyond a 100-AirMile Radius

4. PHASE 1 CONCLUSIONS................................................................................................17

5. PHASE 2 METHODOLOGY............................................................................................19

5.1 CARRIER ROADSIDE INSPECTION DATA...........................................................19

5.2 OOS VIOLATION ANALYSIS..................................................................................22

5.3 CRASH ANALYSIS ...................................................................................................22

6. PHASE 2 FINDINGS..........................................................................................................25

6.1 OOS RATES................................................................................................................25

6.1.1 Agricultural Carriers....................................................................................... 25

6.1.2 Utility Carriers................................................................................................ 26

6.1.3

 27

Agricultural and Utility Carriers Operating Within or Beyond 100-Air-Mile 

Radius

6.2 CRASH RATES ..........................................................................................................28

6.2.1 Agricultural Carriers Operating Within or Beyond 100-Air-Mile Radius...... 28

7. PHASE 2 CONCLUSIONS................................................................................................31

iii 
LIST OF APPENDICES 

APPENDIX A: FMCSA FORM MCS-150, MOTOR CARRIER IDENTIFICATION 

REPORT..............................................................................................................................33

iv 
v 

LIST OF TABLES 

Table 1. Carrier Commodity Groups...............................................................................................3

Table 2. Agricultural Carrier Subgroups .........................................................................................4

Table 3. Crash Rates: Agricultural Carriers with 100 Percent of Drivers Operating Within a 100-

Air-Mile Radius and Agricultural Carriers with 100 Percent of Drivers Operating 

Beyond a 100-Air-Mile Radius........................................................................................8

Table 4. Crash Rates: Agricultural Carriers with 100 Percent of Drivers Operating Within a 100-

Air-Mile Radius and Agricultural Carriers with 100 Percent of Drivers Operating 

Beyond a 100-Air-Mile Radius Domiciled in PRISM States with MCS-150 Updating..8

Table 5. Before (August 2002–July 2005) and After (August 2005–July 2008) Crash Rates: 

Utility/Livestock Carriers and Non-Agricultural Carriers.............................................10

Table 6. Before (August 2002–July 2005) and After (August 2005–July 2008) Crash Rates: 

Utility/Livestock Carriers and Non-Agricultural Carriers Domiciled in PRISM States 

with MCS-150 Updating ................................................................................................10

Table 7. 2005–2008 Violation Rates: Agricultural and Non-Agricultural Carriers ......................12

Table 8. 2005–2008 OOS Rates: Agricultural and Non-Agricultural Carriers .............................13

Table 9. 2005–2008 OOS Rates: Agricultural Carriers with All Drivers Operating Within a 100-

air-mile Radius and Agricultural Carriers with All Drivers Operating Beyond a 100--

air-mile Radius...............................................................................................................15

Table 10. 2005–2008 Violation Rates: Agricultural Carriers with All Drivers Operating Within a 

100-Air-Mile Radius and Agricultural Carriers with All Drivers Operating Beyond a 

100-Air-Mile Radius......................................................................................................16

Table 11. Target Number of Inspections of Agricultural Commodity and Utility Service Carriers, 

Phase 2 Study .................................................................................................................21

Table 12. Driver Inspections (Levels 1, 2, and 3) and Vehicle Inspections (Levels 1, 2, and 5) 

with Driver/Vehicle OOS Rate of Agricultural Commodity Carriers in Four Survey 

States ..............................................................................................................................25

Table 13. Driver Inspections (Levels 1, 2, and 3) and Vehicle Inspections (Levels 1, 2, and 5) 

with Driver/Vehicle OOS Rate of Utility Service Carriers in Four Survey States........26

Table 14. Driver/Vehicle OOS Rates by Agricultural and Utility Carriers Driving Beyond and 

Within 100-Air-Mile Radius in the Four Survey States Combined ...............................27

Table 15. Driver OOS Rates of Agricultural Commodity & Utility Carriers Driving Beyond or 

Within a 100-Air-Mile Radius (HOS violations removed from Beyond 100-Air-Mile 

Group) in the Four Survey States Combined .................................................................28

Table 16. Crash Rates by Time Period for Agricultural Commodity Carriers in the Phase 2 

Survey and by Driving Distance (Exclusively Within a 100 Air-Mile Radius).............29

Table 17. Crash Rates by Time Period for Agricultural Commodity Carriers in the Phase 2 

Survey and by Driving Distance (Exclusively Beyond a 100 Air-Mile Radius) ...........29
LIST OF ACRONYMS 

Acronym Definition 

BASIC Behavior Analysis Safety Improvement Category 

CDL commercial driver’s license 

CMV commercial motor vehicle 

CSA 2010 Comprehensive Safety Analysis 2010 

CVSA Commercial Vehicle Safety Alliance 

FMCSA Federal Motor Carrier Safety Administration 

FMCSRs Federal Motor Carrier Safety Regulations 

HOS hours of service 

MCMIS Motor Carrier Management Information System 

MCS-50 Motor Carrier Identification Report 

OOS out of service 

PRISM Performance and Registration Information Systems Management 

SAFETEA-LU Safe, Accountable, Flexible, Efficient Transportation Equity Act: 

A Legacy for Users 

vi 
EXECUTIVE SUMMARY 

PURPOSE 

In recognition of the relatively local and seasonal nature of their operations, certain agricultural 

commodity carriers are exempt from the Federal Motor Carrier Safety Regulations (FMCSRs) 

regarding hours of service (HOS) or record-of-duty-status requirements when transporting 

agricultural commodities and farm supplies during the planting and harvesting seasons as defined 

by each State. The agriculture exemption, defined in section 4130(a) of the Safe, Accountable, 

Flexible, Efficient Transportation Equity Act: A Legacy for Users (SAFETEA-LU), limits such 

transportation “to an area within a 100 air mile radius from the source of the commodities or the 

distribution point for the farm supplies.” Similarly, utility service vehicle drivers who operate 

primarily within the service area of a utility’s subscribers or consumers are also exempt from 

HOS or record-of-duty-status requirements, as defined by section 4132 of SAFETEA-LU. This 

analysis provides an examination of the safety impact of these HOS exemptions. 

The study was conducted in two phases. Phase 1 compares the safety performance of agricultural 

and non-agricultural carriers for the period 2005 through 2008, and also examines two additional 

industries: livestock and utility carriers, whose operations were not exempt from HOS 

regulations prior to the 2005 passage of SAFETEA-LU. The Phase 1 analysis used carrier 

registration, inspection, and crash data from the Motor Carrier Management Information System 

(MCMIS). Cargo classification information on the Motor Carrier Identification Report (FMCSA 

Form MCS-150) in MCMIS was used to identify the carrier’s industry group (agricultural, 

livestock, or utility carrier), and MCS-150 information was used to identify carriers operating 

within and beyond a 100-air-mile radius (Appendix A). The operating radius information was 

used to create two agricultural carrier subgroups: agricultural carriers with 100 percent of drivers 

operating within a 100-air-mile radius, and agricultural carriers with 100 percent of drivers 

operating beyond a 100-air-mile radius. The analysis used the first subgroup as representative of 

agricultural carriers exempt from the HOS requirements, and the second subgroup as 

representative of agricultural carriers not exempt from the HOS requirements. 

For the Phase 2 analysis, inspection data of agricultural commodity and utility carriers were 

collected during an FMCSA special study of a sample of States. These data include only those 

inspections occurring during the States’ planting and harvesting seasons and indicate both the 

commodity being transported and whether the driver was operating within or beyond the 100-airmile radius exempt from HOS regulations. The Phase 2 analysis assessed the safety performance 

of the HOS-exempt agricultural commodity and utility service carriers identified in the survey in 

comparison with non-HOS-exempt carriers based on their out-of-service (OOS) violation rates 

and crash rates. 

The Phase 1 analysis findings are as follows: 

 Nationally, agricultural carriers operating during 2005–2008 within a 100-air-mile radius 

had lower crash rates per 100 power units than those operating beyond this radius, except 

for 2008, when there was no difference in the crash rates. 

vii 
 Data from the 23 Performance and Registration Information Systems Management 

(PRISM) States that enforce MCS-150 updating, however, show that agricultural carriers 

operating within a 100-air-mile radius had more varied results, with crash rates in 2008 

higher than carriers operating beyond a 100-air-mile radius, lower in 2006 and 2007, and 

nearly the same in 2005. 

 Agricultural carriers overall had higher OOS and/or violation rates than non-agricultural 

carriers for FMCSRs addressing the safe operation of commercial motor vehicles 

(CMVs), driver qualifications, vehicle maintenance, and cargo loading and securement. 

 Agricultural carriers exempt from HOS had higher OOS and/or violation rates than nonexempt agricultural carriers for regulations pertaining to driver qualifications, vehicle 

maintenance, and improper loading and securement. 

 Nationally, utility carriers had higher crash rates after being granted the HOS exemption 

in SAFETEA-LU. Within the PRISM States, however, both utility and livestock carriers 

had higher crash rates in the “after” period. 

The Phase 2 analysis findings are as follows: 

 In the four States participating in the survey (Idaho, Kansas, Maryland, and Michigan), 

both driver and vehicle OOS rates for agricultural carriers were statistically no different 

from the corresponding OOS rates for all carriers in the respective States, with the 

exception of Idaho and Maryland where the agricultural carriers’ vehicle OOS rates were 

higher than average for all carriers in those States. 

 When data from the four States were combined, the overall agricultural carrier driver 

OOS rate was statistically higher than the national driver OOS rate, but the vehicle OOS 

rate was not. 

 None of the surveyed States had utility carrier driver or vehicle OOS rates that 

statistically differed from their respective State average OOS rates. When the data were 

aggregated, the utility carrier driver and vehicle OOS rates were not statistically different 

from the national averages. 

 Agricultural carriers in the survey operating beyond a 100-air-mile radius had a 

statistically higher driver OOS rate than those driving within a 100-air-mile radius, but 

those operating within a 100-air-mile radius had a statistically higher vehicle OOS rate. 

 After removing the HOS-related OOS violations (which the “within 100-air-mile group” 

were exempted from) from the “beyond 100-air-mile group,” there was no longer a 

statistical difference between the two groups in terms of driver OOS rates. 

 Agricultural carriers in the survey that were subject to the HOS requirements had higher 

crash rates per 100 power units than agricultural carriers that were exempt from the HOS 

requirements. 

 Utility carriers operating within a 100-air-mile radius showed no statistical difference in 

driver and vehicle OOS rates when compared to those operating beyond a 100-air-mile 

radius. 

viii 
ix 

Both Phase 1 and Phase 2 have limitations in their analyses of the safety impacts of HOS 

exemptions. In Phase 1, carrier reported cargo information was used to identify agricultural 

carriers. Because carriers may select multiple cargo classifications, or no cargo classification, the 

analysis eliminated such carriers from consideration, resulting in exclusion of more than 25 

percent of the carriers in MCMIS. Some of those excluded carriers might have transported 

agricultural commodities at least occasionally. Additionally, the MCMIS inspection and crash 

data do not account for whether a carrier’s operations occurred during a State’s official planting 

and harvesting season. Therefore, Phase 2 was initiated to analyze the inspection data on 

agricultural commodity and utility service carriers collected during an FMCSA special study of a 

sample of States. While the results would not be nationally representative, they were expected to 

supplement the Phase 1 findings and provide a clearer picture of any potential safety issues. 

Unfortunately, the number of participating States and the amount of data collected were less than 

what was called for in the Phase 2 study design, so the statistical analysis of safety impacts was 

affected. Given the small sample sizes (and large sampling errors associated with such sample 

sizes), many of the differences between the various groups examined were not found to be 

statistically significant. 
[this page intentionally left blank] 
1. BACKGROUND 

In recognition of the relatively local and seasonal nature of their operations, farmers and others 

in agriculture-related industries are exempt from the Federal Motor Carrier Safety Regulations 

(FMCSRs) regarding hours of service (HOS) and record-of-duty-status requirements when 

transporting agricultural commodities and farm supplies within a 100-air-mile radius from the 

source of the commodities or distribution point for the supplies during the planting and 

harvesting season determined by each State (see section 395.1(k) of Title 49 of the Code of 

Federal Regulations). Similarly, utility service vehicle drivers who operate commercial motor 

vehicles (CMVs) necessary for the delivery of public utility services, including the furnishing of 

electric, gas, water, sanitary, telephone, and television cable or community antenna service, 

primarily within the service area of a utility’s subscribers or consumers except for any occasional 

emergency use, are also exempt from HOS and record-of-duty-status requirements (see section 

395.1(n) of Title 49 of the Code of Federal Regulations). This analysis provides an examination 

of the safety impact of these HOS exemptions. 

The study was conducted in two phases. Phase 1 compares the safety performance of agricultural 

and non-agricultural carriers for the period 2005–2008. Carriers and their type of operations were 

identified based on their registration information in the Motor Carrier Management Information 

System (MCMIS) census file. Because the HOS exemption is limited to transportation within a 

100-air-mile radius, the analysis compares the safety performance of agricultural carriers who 

reported 100 percent of their drivers operating within a 100-air-mile radius (operations are 

exempt from HOS) to those who reported 100 percent of their drivers operating beyond a 100-

air-mile radius (operations are non-exempt). Additionally, Phase 1 examines two industries—

livestock and utility carriers—whose operations were not exempt from HOS regulations prior to 

the passage of the Safe, Accountable, Flexible, Efficient Transportation Equity Act: A Legacy 

for Users (SAFETEA-LU). For these carrier groups, the analysis compares crash data for the 

periods before and after August 2005, when SAFETEA-LU was enacted. Finally, to provide 

additional validation of the crash analysis, which uses power unit data reported on the Form 

MCS-150, a separate analysis was performed using data only for carriers domiciled in states 

participating in the Performance and Registration Information Systems Management (PRISM) 

program that enforce MCS-150 updating. At the time of this report, the PRISM States that 

enforce the MCS-150 updating requirement are: Alabama, Arizona, Arkansas, Connecticut, 

Georgia, Iowa, Kentucky, Louisiana, Maine, Minnesota, Missouri, Nebraska, New Hampshire, 

New Mexico, North Carolina, Ohio, South Carolina, South Dakota, Tennessee, Utah, Vermont, 

Washington, and West Virginia. Carriers domiciled in these PRISM States are required to update 

their MCS-150 annually (Appendix A). As a result, PRISM State data are considered more 

current and reliable than non-PRISM State data where there are no direct consequences for not 

updating the data. 

A key limitation of the Phase 1 analysis is the use of MCS-150 data to classify a carrier’s 

operations as “agricultural,” “non-agricultural,” “livestock,” or “utility,” using commodity 

information. Because carriers may select multiple cargo classifications, or no cargo classification 

on the MCS-150, the analysis eliminated such carriers from consideration. This resulted in the 

exclusion of 25.97 percent of the carriers in MCMIS, some of which were likely to have carried 

agricultural commodities at least occasionally. Another limitation is the inability to determine 

whether a carrier’s operations occurred during a State’s official planting and harvesting season. 

1 
Therefore, a Phase 2 analysis was initiated to supplement the Phase 1 results by analyzing 

inspection data of agricultural commodity and utility carriers collected during a Federal Motor 

Carrier Safety Administration (FMCSA) special study of a sample of States (section 4.1). This 

data includes only those inspections occurring during the States’ planting and harvesting seasons 

and indicates both the commodity being transported and whether the driver was operating within 

or beyond the 100-air-mile radius exempt from HOS regulations. The objective of Phase 2 was to 

assess the safety performance of the HOS exempt agricultural commodity and utility service 

carriers identified in the survey in comparison with non-HOS exempt carriers based on their out 

of service (OOS) violation rates and crash rates. 

2 
2. PHASE 1 METHODOLOGY 

2.1 CARRIER COMMODITY GROUPS 

This analysis groups motor carriers based on the cargo classifications and driver information on 

their MCS-150s as of the MCMIS snapshot on June 26, 2009. 

MCS-150 Question 24 asks carriers to mark all cargo classifications that describe their 

operations. Carriers may select more than one classification. Using these cargo classifications, 

this analysis placed carriers into carrier commodity groups described below. Assumptions were 

that (1) the cargo classifications as of the date of the MCMIS snapshot accurately represented the 

carriers’ operations over the period studied (2005–2008); and (2) carriers were actually 

transporting these commodities at the time of a crash or inspection. The carrier commodity 

groups used in this analysis are shown in Table 1 and are defined as follows: 

 Agricultural Carriers. The carrier selected at least one of the following agricultural cargo 

classifications and did not select any other cargo classifications: Logs, Poles, Beams, 

Lumber; Fresh Produce; Grain, Feed, Hay; Farm Supplies. 

 Livestock Carriers. The carrier selected the Livestock cargo classification and did not 

select any other cargo classifications. 

 Utility Carriers. The carrier selected the Utility cargo classification and did not select any 

other cargo classifications. 

 Non-Agricultural Carriers. The carrier did not select any of the four agricultural 

commodity cargo classifications, the livestock cargo classification, or the utility 

classification. 

Table 1. Carrier Commodity Groups

Carrier Group Number of 

Carriers Share 

Agricultural (Only) 44,685 6.06% 

Livestock (Only) 6,384 0.87% 

Utility (Only) 694 0.09% 

Non-Agricultural, Non-Livestock, Non-Utility (Only) 493,717 67.00% 

Multiple Cargo Commodities* 172,979 23.47% 

No Cargo Commodities* 18,429 2.50% 

All Carriers 736,888 100.00% 

*Not used in this analysis. 

In addition, Question 27 on the MCS-150 asks carriers to identify the number of drivers 

operating within, and beyond, a 100-air-mile radius. The analysis used this information to 

partition agricultural carriers in an attempt to further isolate the population of interest (i.e., 

agricultural carriers with operations that are exempt from HOS regulations because they are 

within a 100-air-mile radius). Shown in Table 2, the following two agricultural carrier subgroups 

were used: 

3 
 Agricultural carriers with 100 percent of drivers operating within a 100-air-mile radius. 

The carrier indicated that all drivers operate within a 100-air-mile radius. 

 Agricultural carriers with 100 percent of drivers operating beyond a 100-air-mile radius. 

The carrier indicated that all drivers operate beyond a 100-air-mile radius. 

Table 2. Agricultural Carrier Subgroups 

Carrier Subgroup Number of 

Carriers Share 

Agricultural carriers with 100 percent of drivers operating within a 

100-air-mile radius 18,625 41.68% 

Agricultural carriers with 100 percent of drivers operating beyond a 

100-air-mile radius 21,071 47.15% 

Agricultural carriers with drivers operating both within and beyond a 

100-air-mile radius* 4,989 11.16% 

All agricultural (only) carriers 44,685 100.00% 

*Not used in this analysis. 

2.2 CRASH, OOS, AND VIOLATION DATA 

The crash, OOS, and violation analysis used crash and inspection data contained in the MCMIS 

data snapshot for June 26, 2009. For the “before and after” crash comparison, the analysis 

aggregated the MCMIS data for the 3 years prior to August 2005, when the Safe, Accountable, 

Flexible, Efficient Transportation Equity Act: A Legacy for Users (SAFETEA-LU) of 2005 was 

enacted (August 2002–July 2005) and the 3 years after (August 2005–July 2008). 

The crash rate analysis included only those carriers reporting a reasonable number of power 

units. Specifically, the analysis included only those carriers with at least one power unit, and 

applied filters to compare driver counts and power unit counts. Carriers were removed if the 

number of power units > 10 ×(number of drivers + 1) or the number of drivers > 10 × (number 

of power units + 1). In addition, after discovering one carrier with suspect power unit data, the 

data were examined for additional carriers with unusually high or low driver-to-power unit 

ratios, unusually high or low crash rates, or unusually large year-to-year changes in power units. 

No carriers identified from this additional examination had any significant impact on the crash 

results. (The MCS-150 for the carrier with suspect data showed 17,000 power units and 1,000 

drivers. This carrier had no crashes or inspections in MCMIS. Removing this carrier from the 

analysis resulted in a change in the crash rates for agricultural carriers with 100 percent of 

drivers operating beyond a 100-mile radius (see section 3 for details on the crash rate results). 

Crash rates were calculated using crash data from the MCMIS snapshot and power unit data 

from SafeStat result files at the end of each calendar year; however, the “before and after” crash 

rate analysis used power unit data for the end of July 2005 and the end of July 2008. 

This analysis calculated the OOS and violation rates by summing up the number of inspections 

that resulted in the driver or vehicle being placed OOS (or where at least one regulation from the 

violation category was violated) and dividing by the total number of inspections. The analysis 

4 
5 

used data for Inspection Levels 1, 2, 3, and 5. To test for statistical significance of differences in 

OOS and violation rates, the analysis used a Z-test for comparing proportions. 

2.3 BEHAVIOR ANALYSIS AND SAFETY IMPROVEMENT CATEGORIES 

(BASICS) 

In comparing OOS and violation rates, the analysis used Behavior Analysis and Safety 

Improvement Categories (BASICs) employed by the measurement system developed under the 

Comprehensive Safety Analysis (CSA) 2010 initiative. This Safety Measurement System uses 

crash and inspection data to quantify the on-road safety performance of motor carriers and 

drivers. These categories group violations of the regulations into specific behavioral areas, such 

as vehicle maintenance, enabling the targeted identification of safety problems. This analysis 

includes OOS and violation data for the following four BASICs: 

 Unsafe Driving. Dangerous or careless operation of a CMV. Example violations for this 

BASIC include speeding, reckless driving, improper lane change, and inattention. 

 Driver Fitness. Operation of a CMV by a driver who is unfit to operate due to lack of 

training, experience, or medical qualifications. Violations include failure to have a valid 

and appropriate commercial driver’s license (CDL), and failure to have proper medical 

documentation. 

 Vehicle Maintenance. CMV failure due to improper or inadequate maintenance. 

Violations include brakes, lights, and other mechanical defects, and failure to make 

required repairs. 

 Improper Loading/Cargo Securement. Shifting loads, spilled or dropped cargo, and 

unsafe handling of hazardous materials. Example violations include improper load 

securement, cargo retention, and hazardous materials handling. 

This analysis did not include the CSA 2010 Fatigued Driving BASIC, since this category 

includes HOS-related violations, or the Controlled Substances/Alcohol BASIC, due to the 

limited number of inspections citing these violations. 
[this page intentionally left blank] 
3. PHASE 1 FINDINGS 

3.1 CRASH RATES 

3.1.1 Agricultural Carriers with All Drivers Operating Within or Beyond a 100-AirMile Radius 

As shown in Table 3, in 2005 through 2007, agricultural carriers with 100 percent of drivers 

operating within a 100-air-mile radius had lower crash rates than agricultural carriers with all 

drivers operating beyond this radius. In 2008, both carrier groups had similar crash rates. 

However, the results for the PRISM States that enforce MCS-150 updating show that agricultural 

carriers with all drivers operating within a 100-air-mile radius had a higher crash rate than those 

carriers with all drivers operating beyond this radius in 2008, a lower crash rate in 2006 and 

2007, and nearly the same crash rate in 2005 (Table 4) Because of the requirement for carriers in

PRISM States to update their MCS-150 information annually, the data from the PRISM States 

are considered more current and reliable than the MCS-150 data from non-PRISM States. 

7 
Table 3. Crash Rates: Agricultural Carriers with 100 Percent of Drivers Operating Within a 100-Air-Mile Radius and 

with 100 Percent of Drivers Operating Beyond a 100-Air-Mile Radius 

Year 

Number of 

Carriers 

Within 100-

Air-Mile 

Radius 

Number of 

Power Units 

Within 100-

Air-Mile 

Radius 

Vehicles 

Involved in a 

Crash Within 

100-Air-Mile 

Radius 

Crash 

Rate 

Within 

100-AirMile 

Radius 

Number of 

Carriers

Beyond 

100-Air-Mile 

Radius 

Number of 

Power Units 

Beyond 100-

Air-Mile 

Radius 

Vehicles 

Involved in a 

Crash 

Beyond 100-

Air-Mile 

Radius 

Cras

Be

100

M

Ra

2005 13,327 28,042 506 1.80 16,597 31,782 608 12006 14,337 30,218 488 1.62 17,393 33,411 612 12007 15,881 33,355 538 1.61 18,790 35,908 724 22008 17,569 36,443 569 1.56 19,963 37,970 592 1Source: MCMIS Data Snapshot for June 26, 2009. Crash rate is the number of crashes per 100 power units. 

Table 4. Crash Rates: Agricultural Carriers with 100 Percent of Drivers Operating Within a 100-Air-Mile Radius and 

with 100 Percent of Drivers Operating Beyond a 100-Air-Mile Radius Domiciled in PRISM States with MCS

Year 

Number of 

Carriers 

Within 100-

Air-Mile 

Radius 

Number of 

Power Units 

Within 100-

Air-Mile 

Radius 

Vehicles 

Involved in a 

Crash 

Within 100-

Air-Mile 

Radius 

Crash 

Rate 

Within 

100-AirMile 

Radius 

Number of 

Carriers 

Beyond 100-

Air-Mile 

Radius 

Number of 

Power Units 

Beyond 100-

Air-Mile 

Radius 

Vehicles 

Involved in a 

Crash 

Beyond 100-

Air-Mile 

Radius 

Cras

Be

100-A

Ra

2005 6,919 13,692 310 2.26 7,948 14,291 320 22006 7,426 14,833 272 1.83 8,288 15,031 321 22007 8,195 16,226 306 1.89 8,908 16,128 374 22008 8,833 17,615 319 1.81 9,443 16,990 273 1Source: MCMIS Data Snapshot for June 26, 2009. Crash rate is the number of crashes per 100 power units. 

8 
3.1.2 “Before and After” Crash Rates for Utility and Livestock Carriers 

To assess the impact of the exemption granted to utility and livestock carriers by SAFETEA-LU 

in August 2005, crash rates for these particular groups were evaluated both prior to and after 

enactment of the legislation. The “before and after” crash analysis indicates that utility carriers 

had higher crash rates after being granted the HOS exemption compared to the period prior to the 

exemption. Livestock carriers had no change in their crash rate in the “after” period, while nonagricultural carriers had a slight decrease in their crash rate (Table 5). However, the crash data 

for PRISM States that enforce MCS-150 updating show higher crash rates for both utility and 

livestock carriers in the “after” period (Table 6). In contrast, non-agricultural carriers in these 

States (which had no change to their HOS requirements during the same period) showed a 

decrease in their crash rate. 

9 
Table 5. Before (August 2002–July 2005) and After (August 2005–July 2008) Crash Rates: 

Utility/Livestock Carriers and Non-Agricultural Carriers 

Carrier 

Group 

“Before” 

Period: 

Number of 

Carriers 

“Before” 

Period: 

Number of 

Power Units 

(July 2005) 

“Before” 

Period: 

Vehicles 

Involved in 

a Crash 

“Before” 

Period: 

Crash 

Rate 

“After” 

Period: 

Number of 

Carriers 

“After” 

Period: 

Number of 

Power Units 

(July 2008) 

“After” 

Period: 

Vehicles 

Involved in 

a Crash 

“A

Pe

C

R

Utility 410 7,871 61 0.26 583 10,400 130 0Livestock 4,336 7,224 532 2.46 5,714 9,151 672 2Non-Ag 334,260 2,356,517 138,094 1.95 426,299 2,965,444 171,576 1Source: MCMIS Data Snapshot for June 26, 2009. Crash rates were obtained by aggregating crash data for the 3 years prior to August 2005 and the 3 years after August 2005; power units were multip3 years of crashes. 

Table 6. Before (August 2002–July 2005) and After (August 2005–July 2008) Crash Rates: 

Utility/Livestock Carriers and Non-Agricultural Carriers Domiciled in PRISM States with MCS-150 U

Carrier 

Group 

“Before” 

Period: 

Number of 

Carriers 

“Before” 

Period: 

Number of 

Power Units 

(July 2005) 

“Before” 

Period: 

Vehicles 

Involved in 

a Crash 

“Before” 

Period: 

Crash 

Rate 

“After” 

Period: 

Number of 

Carriers 

“After” 

Period: 

Number of 

Power Units 

(July 2008) 

“After” 

Period: 

Vehicles 

Involved in 

a Crash 

“A

Pe

C

R

Utility 195 2,832 18 0.21 270 4,764 47 0Livestock 2,028 3,243 262 2.69 2,671 4,081 362 2Non-Ag 126,127 939,118 55,001 1.95 157,481 1,187,733 67,889 1

Source: MCMIS Data Snapshot for June 26, 2009. Crash rates were obtained by aggregating crash data for the 3 years prior to August 2005 and the 3 years after August 2005; power units were multip3 years of crashes. 

10 
3.2 OOS AND VIOLATION RATES 

3.2.1 Agricultural and Non-Agricultural Carriers 

In the four BASICs considered in this analysis (Unsafe Driving, Driver Fitness, Vehicle 

Maintenance, and Improper Loading/Cargo Securement—violation categories as defined in 

section 2), agricultural carriers had higher violation rates that were statistically significant when 

compared to non-agricultural carriers during the period covered by this analysis (Table 7). For 

OOS rates, the agricultural carriers also had higher violation rates that were statistically 

significant when compared to non-agricultural carriers for the Vehicle Maintenance and 

Improper Loading/Cargo Securement BASICs. The differences in OOS rates for the Unsafe 

Driving and Driver Fitness BASICs were not statistically significant (Table 8). 

11 
Table 7. 2005–2008 Violation Rates: Agricultural and Non-Agricultural Carriers 

Violation Category 

Ag 

Inspections 

Non-Ag 

Inspections 

Ag Inspections 

with a Violation 

Non-Ag 

Inspections with a 

Violation 

Ag Violation 

Rate 

V

2005 Unsafe Driving 37,072 1,336,266 4,320 138,715 11.65% 2006 Unsafe Driving 40,051 1,519,387 4,984 162,338 12.44% 2007 Unsafe Driving 42,736 1,618,573 5,149 165,714 12.05% 2008 Unsafe Driving 45,941 1,732,273 4,988 164,445 10.86% 2005 Driver Fitness 37,072 1,336,266 3,580 79,169 9.66% 2006 Driver Fitness 40,051 1,519,387 4,022 87,281 10.04% 2007 Driver Fitness 42,736 1,618,573 4,106 102,388 9.61% 2008 Driver Fitness 45,941 1,732,273 4,470 136,144 9.73% 2005 Vehicle Maintenance 37,072 1,336,266 19,159 576,062 51.68% 2006 Vehicle Maintenance 40,051 1,519,387 21,216 673,636 52.97% 2007 Vehicle Maintenance 42,736 1,618,573 21,841 687,465 51.11% 2008 Vehicle Maintenance 45,941 1,732,273 23,140 727,835 50.37% 2005 Improper Loading 37,072 1,336,266 8,541 150,433 23.04% 2006 Improper Loading 40,051 1,519,387 8,988 160,437 22.44% 2007 Improper Loading 42,736 1,618,573 9,390 170,531 21.97% 2008 Improper Loading 45,941 1,732,273 10,114 174,081 22.02% Source: MCMIS Data Snapshot for June 26, 2009. *For two-tail test, a z-value > 1.96 or a z-value < -1.96 indicates significance at a level of α=0.05. 

12 
13 

Table 8. 2005–2008 OOS Rates: Agricultural and Non-Agricultural Carriers 

OOS Category 

Ag 

Inspections 

Non-Ag 

Inspections 

Ag OOS 

Inspections 

Non-Ag OOS 

Inspections Ag OOS Rate 

2005 Unsafe Driving 37,072 1,336,266 2 105 0.005% 2006 Unsafe Driving 40,051 1,519,387 2 93 0.005% 2007 Unsafe Driving 42,736 1,618,573 3 115 0.007% 2008 Unsafe Driving 45,941 1,732,273 0 88 0.000% 2005 Driver Fitness 37,072 1,336,266 555 16,930 1.50% 2006 Driver Fitness 40,051 1,519,387 654 19,597 1.63% 2007 Driver Fitness 42,736 1,618,573 725 22,132 1.70% 2008 Driver Fitness 45,941 1,732,273 789 24,463 1.72% 2005 Vehicle Maintenance 37,072 1,336,266 6,659 166,359 17.96% 2006 Vehicle Maintenance 40,051 1,519,387 7,242 187,362 18.08% 2007 Vehicle Maintenance 42,736 1,618,573 7,327 190,739 17.14% 2008 Vehicle Maintenance 45,941 1,732,273 7,762 201,393 16.90% 2005 Improper Loading 37,072 1,336,266 1,943 46,956 5.24% 2006 Improper Loading 40,051 1,519,387 2,138 50,463 5.34% 2007 Improper Loading 42,736 1,618,573 2,224 52,532 5.20% 2008 Improper Loading 45,941 1,732,273 2,298 54,500 5.00% Source: MCMIS Data Snapshot for June 26, 2009. *For two-tail test, a z-value > 1.96 or a z-value < -1.96 indicates significance at a level of α=0.05. 
3.2.2 Agricultural Carriers with All Drivers Operating Within or Beyond a 100-AirMile Radius 

Agricultural carriers operating within a 100-air-mile radius had higher OOS and/or violation 

rates that were statistically significant when compared with those operating beyond a 100-airmile radius in some BASICs. As shown in Table 9 and Table 10, these rates are higher for the 

following violation categories: 

 Driver Fitness. Violation rate; statistically significant for 2007 and 2008. 

 Vehicle Maintenance. OOS and violation rate; statistically significant for all years. 

 Improper Loading/Cargo Securement. Violation rate; statistically significant for all years. 

14 
Table 9. 2005–2008 OOS Rates: Agricultural Carriers with All Drivers Operating Within a 100-air-mile Radius and 

with All Drivers Operating Beyond a 100--air-mile Radius 

OOS Category 

Ag < 100-

Air-Mile 

Radius 

Inspections 

Ag >100-

Air-Mile 

Radius 

Inspections 

Ag < 100-

Air-Mile 

Radius OOS 

Inspections 

Ag >100-AirMile Radius 

OOS 

Inspections 

Ag < 100-AirMile Radius 

OOS Rate 

Ag > 100

Radius O

2005 Unsafe Driving 13,444 18,320 0 1 0.000% 02006 Unsafe Driving 15,101 19,472 1 1 0.007% 02007 Unsafe Driving 15,989 20,928 2 0 0.013% 02008 Unsafe Driving 17,220 22,502 0 0 0.000% 02005 Driver Fitness 13,444 18,320 183 273 1.36% 12006 Driver Fitness 15,101 19,472 235 309 1.56% 12007 Driver Fitness 15,989 20,928 259 348 1.62% 12008 Driver Fitness 17,220 22,502 271 399 1.57% 12005 Vehicle Maintenance 13,444 18,320 2,765 3,078 20.57% 162006 Vehicle Maintenance 15,101 19,472 3,149 3,273 20.85% 162007 Vehicle Maintenance 15,989 20,928 3,121 3,364 19.52% 162008 Vehicle Maintenance 17,220 22,502 3,303 3,635 19.18% 162005 Improper Loading 13,444 18,320 758 931 5.64% 52006 Improper Loading 15,101 19,472 939 966 6.22% 42007 Improper Loading 15,989 20,928 973 957 6.09% 42008 Improper Loading 17,220 22,502 1,033 1,022 6.00% 4Source: MCMIS Data Snapshot for June 26, 2009. *For two-tail test, a z-value > 1.96 or a z-value < -1.96 indicates significance at a level of α=0.05. 

15 
16 

Table 10. 2005–2008 Violation Rates: Agricultural Carriers with All Drivers Operating Within a 100-Air-Mile Radi

Carriers with All Drivers Operating Beyond a 100-Air-Mile Radius 

Violation Category 

Ag < 100-

Air-Mile 

Radius 

Inspections 

Ag >100-AirMile Radius 

Inspections 

Ag < 100-AirMile Radius 

Inspections 

with a Violation 

Ag > 100-AirMile Radius 

Inspections with 

a Violation 

Ag < 100-AirMile Radius 

Violation Rate 

A

M

2005 Unsafe Driving 13,444 18,320 1,435 2,232 10.67% 2006 Unsafe Driving 15,101 19,472 1,750 2,505 11.59% 2007 Unsafe Driving 15,989 20,928 1,771 2,538 11.08% 2008 Unsafe Driving 17,220 22,502 1,679 2,525 9.75% 2005 Driver Fitness 13,444 18,320 1,445 1,652 10.75% 2006 Driver Fitness 15,101 19,472 1,647 1,833 10.91% 2007 Driver Fitness 15,989 20,928 1,746 1,814 10.92% 2008 Driver Fitness 17,220 22,502 1,977 1,937 11.48% 2005 Vehicle Maintenance 13,444 18,320 7,504 9,158 55.82% 2006 Vehicle Maintenance 15,101 19,472 8,587 9,987 56.86% 2007 Vehicle Maintenance 15,989 20,928 8,848 10,373 55.34% 2008 Vehicle Maintenance 17,220 22,502 9,483 10,875 55.07% 2005 Improper Loading 13,444 18,320 3,662 3,987 27.24% 2006 Improper Loading 15,101 19,472 4,111 3,981 27.22% 2007 Improper Loading 15,989 20,928 4,264 4,103 26.67% 2008 Improper Loading 17,220 22,502 4,612 4,471 26.78% Source: MCMIS Data Snapshot for June 26, 2009. * For two-tail test, a z-value > 1.96 or a z-value < -1.96 indicates significance at a level of α=0.05 
4. PHASE 1 CONCLUSIONS 

The Phase 1 analysis of the safety of agricultural and utility carriers and the impact of the HOS 

exemption yields the following conclusions: 

 Nationally, agricultural carriers with 100 percent of drivers operating within a 

100-air-mile radius had lower crash rates than those with all drivers operating beyond this 

radius, except for 2008, when there was no difference in the crash rates. However, data 

for PRISM States that enforce MCS-150 updating show that agricultural carriers with all 

drivers operating within a 100-air-mile radius had more varied results, with crash rates 

higher than carriers with all drivers operating beyond a 100-air-mile radius in 2008, lower 

in 2006 and 2007, and nearly the same in 2005. 

 Nationally, utility carriers had higher crash rates after being granted the HOS exemption 

in SAFETEA-LU. Within the PRISM States, however, both utility and livestock carriers 

had higher crash rates in the “after” period. 

 Agricultural carriers overall had higher OOS and/or violation rates than 

non-agricultural carriers for FMCSA regulations addressing the safe operation of CMVs, 

driver qualifications, vehicle maintenance, and cargo loading and securement. 

 Agricultural carriers exempt from HOS (those with all drivers operating within a 

100-air-mile radius) had higher OOS and/or violation rates than non-exempt agricultural 

carriers (those with all drivers operating beyond a 100-air-mile radius) for regulations 

addressing driver qualifications, vehicle maintenance, and improper loading and 

securement. 

17 
[this page intentionally left blank] 
5. PHASE 2 METHODOLOGY 

5.1 CARRIER ROADSIDE INSPECTION DATA 

FMCSA, with the assistance of the Commercial Vehicle Safety Alliance (CVSA), arranged to 

capture information during roadside inspections from July through November 2008 in several 

States that expressed interest in participating in a special survey. The usual inspection data 

collected at the roadside were supplemented with additional information that was entered in the 

Special Study fields in the Aspen data reporting system for transmittal to MCMIS. The following 

questions were asked during the roadside inspections: 

Question 1: (to be entered into Aspen Special Study Field #1): At the time of inspection, please 

specify the type of operation in which the driver/vehicle are involved: 

 Private operation, intRAstate commerce = 1. 

 Private operation, intERstate commerce = 2. 

 For-hire operation, intRAstate commerce = 3. 

 For-hire operation, intERstate commerce = 4. 

 Unknown = 9. 

Question 2: (to be entered into Aspen Special Study Field #2): Please specify the type of 

commodity being transported at the time of the inspection: 

 Logs = 1. 

 Fresh Produce = 2. 

 Grain, Feed, or Hay = 3. 

 Farm Supplies = 4. 

 Livestock = 5. 

 Other commodity = 6. 

 No commodity (i.e., empty load or bobtail) = 7. 

 Utility Service Vehicle = 8. 

 Unknown = 9. 

19 
Question 3: (to be entered into Aspen Special Study Field #3): If the vehicle being inspected is a 

Utility Service Vehicle (Response = 8 in Question 2), please specify the type of utility service 

industry this vehicle was operated by: 

 Electrical & Gas Utility = 1. 

 Cable Television Utility = 2. 

 Telecommunications Utility = 3. 

 Other Utility = 4. 

 Unknown = 9. 

 Not Applicable = 0. 

Question 4: (to be entered into Aspen Special Study Field #4): If the response to Question 2 is 

“No Commodity (i.e., empty load or bobtail) = 7”, please specify which of the following was the 

last commodity carried by this vehicle: 

 Logs = 1. 

 Fresh Produce = 2. 

 Grain, Feed, Hay = 3. 

 Farm Supplies = 4. 

 Livestock = 5. 

 Other commodity = 6. 

 Utility Service Vehicle = 8. 

 Unknown = 9. 

 Not Applicable = 0. 

Question 5: (to be entered into Aspen Special Study Field #5): Is the intended or actual distance 

of the current trip more than 100-air-miles from the point of origin? 

 Yes = 1. 

 No = 2. 

 Unknown = 9. 

perating agricultural and utility carriers could be specifically identified 

s 

gh the 

pt 

As a result, currently o

during the Phase 2 data analysis. Also, based on the response to Question 5, agricultural carrier

reporting a current trip distance of 100-air-miles or less from the point of origin were considered 

representative in terms of performance of agricultural carrier exempt from the HOS 

requirements; those reporting a distance greater than 100-air-miles were considered 

representative of agricultural carriers not exempt from the HOS requirements. Althou

FMCSRs do not specify a radius of operations for utility service carriers to differentiate exem

from non-exempt status, they do exempt only those utility carriers operating primarily within the

20 
service area of a utility’s subscribers or consumers except for any occasional emergency use. 

Therefore, the 100-air-mile radius was used to estimate the number of utility carriers operating 

within their service area from those operating outside their service area. 

The survey data collected included information from four States (Idaho, Kansas, Maryland, and 

Michigan). These four were among the six States (Arizona, Idaho, Kansas, Kentucky, Maryland, 

and Michigan) that had originally agreed to participate in the data collection effort during 

roadside inspections. The Phase 2 study design was a stratified random sample with each of the 

six participating States representing a stratum. The planned total sample size for the study was 

allocated proportionately to the six States based on the historical proportion of inspections 

performed in each of the six States annually. Agricultural commodity and utility service carriers 

were identified at the roadside jurisdictions for inclusion in the study. The sample of inspections 

desired for statistical analysis from the two study groups, and the achieved number of 

driver/vehicle inspections from agricultural and utility carriers, are presented in Table 11. 

Unfortunately, the number of participating States and the amount of data collected were less than 

what was called for in the Phase 2 study design (compare Target Number and Achieved columns 

in Table 11), so the statistical analysis of safety impacts was affected. Given the small sample 

sizes (and the large sampling errors associated with such sample sizes), many of the differences 

between the various groups examined were not found to be statistically significant. Additionally, 

it is apparent from Table 11 that an overwhelming percentage of the total agricultural carrier 

driver and vehicle inspections, nearly 90 percent, was recorded in Kansas. Thus, any analysis of 

combined totals from all States will be highly influenced by the data from Kansas. 

Table 11. Target Number of Inspections of Agricultural Commodity and Utility Service Carriers, 

Phase 2 Study 

Target Number of Target Number Achieved Achieved Utility 

Survey States 

Agricultural Carrier 

Inspections 

of Utility Carrier 

Inspections 

Agricultural Carrier 

Inspections 

Carrier 

Inspections 

Arizona 500 625 0 0 

Idaho 100 125 38 5 

Kansas 500 275 575 46 

Kentucky 525 575 0 0 

Maryland 450 475 64 35 

Michigan 425 425 90 8 

Total Samples 2,500 2,500 667 94 

Source: Special Study Survey

Because those carriers reporting a current trip distance of 100-air-miles or less from the point of 

origin were considered representative in terms of performance of agricultural and utility carriers 

exempt from the HOS requirements, any inspections for this group with an HOS violation were 

removed from the analysis file. 

 Data 

21 
5.2 OOS VIOLATION ANALYSIS 

The Phase 2 analysis involved a series of comparisons of driver and vehicle OOS rates for the 

surveyed carriers in each State with the calendar year 2008 OOS rates for all carriers within that 

state, and of the OOS rates for the four States combined with the national OOS rates. The 

analysis used data for Inspection Levels 1, 2, 3, and 5. Comparisons were also made between 

OOS rates for carriers operating within a 100-air-mile radius and those operating beyond a 100-

air-mile radius, first with all violations included from the inspection records of the carriers 

operating beyond a 100-air-mile radius and then with HOS violations removed. This was done to 

determine if any difference between the two groups was solely a result of the HOS requirements. 

5.3 CRASH ANALYSIS 

As was done in Phase 1, a comparison was made of crash rates in 2007 and 2008 of the 

agricultural commodity carriers in the survey that were operating within a 100-air-mile radius to 

those operating beyond a 100-air-mile radius, using MCS-150 data to classify carriers. The U.S. 

Department of Transportation Number from each inspection report was used to match the 

carriers with their respective MCMIS registration data and crash records. The registration data 

were used to identify 611 distinct agricultural carriers that had counts in the carriers’ driver count 

table. 

Each carrier was categorized according to its driving distance reported on its MCS-150 Form in 

the MCMIS census file. Two groups were created: 

 Carriers that exclusively drive within 100-air-miles and are therefore exempt from the 

HOS requirements. 

 Carriers that exclusively drive beyond 100-air-miles and are therefore subject to the HOS 

requirements. 

Carriers that have drivers driving within and beyond a 100-air-mile radius were eliminated. 

These two groups were determined by using the carrier’s driver count table, which was obtained 

from the MCMIS data file. A crash rate per 100 power units was calculated for each of these two 

groups based on crash data for the years 2007 and 2008. When calculating the crash rates, a few 

carriers were excluded because the driver to power unit ratio (or power unit to driver ratio) was 

greater than 50, too high to be considered reasonable. Also, any carrier whose power unit count 

was found to be greater than 500, and therefore too large to be considered accurate, was also 

removed. Power unit counts from the December SafeStat run for the year 2007 and 2008 were 

used as the denominator to calculate the crash rates. Crashes in 2007 and 2008, as recorded in the 

May 22, 2009, MCMIS snapshot, were used as the numerator for calculating the crash rates. 

The crash analysis was conducted to determine if there was a difference in the overall crash rates 

of the agricultural carriers in the data collection that operated within a 100-air-mile radius 

compared to the agricultural carriers that operated beyond a 100-air-mile radius. It is recognized 

that this analysis, by using all crashes in which the carriers were involved in 2007 and 2008, and 

relying on the MCMIS registration data to identify carriers that operated exclusively within or 

beyond a 100-air-mile radius, resulted in some of the same limitations as in Phase 1. This 

22 
23 

includes the analysis of crashes by agricultural carriers that occurred outside their States’ 

planting and harvesting seasons, crashes occurring beyond a 100-air-mile radius but attributed to 

a carrier in the group identified as operating within a 100-air-mile radius (and vice versa), and 

crashes involving the transport of other than agricultural commodities or farm supplies. 
[this page intentionally left blank] 
6. PHASE 2 FINDINGS 

6.1 OOS RATES 

6.1.1 Agricultural Carriers 

Because the OOS rates for all carriers in each of the four States participating in Phase 2 may 

differ significantly from similar rates calculated at the national level, the Phase 2 analysis began 

by comparing each survey State’s agricultural carrier OOS rates to the rates for all carriers in that 

State. Driver and vehicle OOS rates were calculated for each State for the agricultural 

commodity carriers identified in the survey. These rates were compared to their respective 

State’s 2008 overall driver and vehicle OOS rates to determine if the agricultural carriers’ 

inspection results differed from other carriers. As shown in Table 12, based on the Phase 2 

survey, agricultural carriers inspected in Maryland and Idaho had vehicle OOS rates that were 

statistically higher than their State average vehicle OOS rate. Kansas and Michigan had vehicle 

OOS rates that were not statistically different from their State averages. None of the States had 

agricultural carrier driver OOS rates that statistically differed from the State average driver OOS 

rate. 

Table 12. Driver Inspections (Levels 1, 2, and 3) and Vehicle Inspections (Levels 1, 2, and 5) with 

Driver/Vehicle OOS Rate of Agricultural Commodity Carriers in Four Survey States 

State 

(Driver/Vehicle OOS 

Rate for all carriers 

in state) 

Agricultural 

Carrier Driver 

Inspections 

Agricultural Carrier 

Driver OOS 

Violations (Driver 

OOS Rate) 

Agricultural 

Carrier Vehicle 

Inspections 

Agricultural Carrier 

Vehicle OOS 

Violations (Vehicle 

OOS Rate) 

Idaho 

(10.7%/29.3%) 25 1 (4.0%) 38 

18 

(47.4%)* 

Z=2.264 

Kansas 

(8.8%/17.9%) 575 49 (8.5%) 390 67 (17.2%) 

Maryland 

(7.3%/19.7%) 64 7 (10.9%) 63 

19 

(30.2%)* 

Z=1.926 

Michigan 

(6.1%/19.0%) 90 6 (6.7%) 43 10 (23.3%) 

Total 

(2008 National 

Driver/Vehicle OOS 

Rates: 6.4%/22.3%) 

754 

63 

(8.4%)* 

Z=2.150 

534 114 

(21.4%) 

Source: Special Study Survey Data and MCMIS Data Snapshot for December 18, 2009. 

Note: Asterisk denotes rate is statistically significant compared to the state or national rate using a one-tailed test at a level of 

α=0.05 

The data from the four States were then aggregated and driver and vehicle OOS rates were 

calculated. These rates were compared to the 2008 national rates for all carriers of 6.4 percent 

driver OOS rate and 22.3 percent vehicle OOS rate. The agricultural carriers in the survey had a 

vehicle OOS rate (21.4 percent) that was not statistically different from the national average. 

25 
However, the agricultural carriers had a driver OOS rate (8.4 percent) that was statistically 

higher than the national average of 6.4 percent. It should be noted that Kansas, which accounted 

for about 75 percent of both the Phase 2 survey driver and vehicle inspections, highly influenced 

the aggregated State data comparison to the national OOS rates. For example, although the 

recorded driver OOS rates for Kansas, Maryland and Michigan were all higher than the national 

rate of 6.4 percent, only Kansas had a statistically significant difference between its rate and the 

national rate. Similarly, although Idaho and Maryland had statistically significant vehicle OOS 

rates that were higher than their State rates and the national rate of 22.3 percent, and Michigan’s 

recorded rate was higher than the national rate but not statistically significant, Kansas had a 

statistically significant vehicle OOS rate that was lower than the national rate and thus resulted in 

an aggregated rate lower than the national rate that was statistically significant. 

6.1.2 Utility Carriers 

Driver and vehicle OOS rates were calculated for each State for the utility service carriers 

identified in the survey (see Table 13). These rates were compared to their respective State’s 

2008 overall driver and vehicle OOS rates to determine if the utility carriers’ inspection results 

differed from other carriers in the State. None of the States had driver or vehicle OOS rates that 

statistically from their respective State average driver and vehicle OOS rates. Also, the driver 

and vehicle OOS rates for the aggregated data of the four States were not statistically different 

from the national rates. Although some of the OOS rates in Table 13 are lower or higher than the 

national rates, the small number of utility carrier inspections affected the precision levels 

obtained for the survey estimates, resulting in statistical power limitations. 

Table 13. Driver Inspections (Levels 1, 2, and 3) and Vehicle Inspections (Levels 1, 2, and 5) with 

Driver/Vehicle OOS Rate of Utility Service Carriers in Four Survey States 

State 

(Driver/Vehicle 

OOS Rate for all 

carriers in State) 

Utility Carriers 

with Driver 

Inspections 

Utility Carriers with 

Driver OOS 

Violations 

(Driver OOS Rate) 

Utility 

Carriers with 

Vehicle 

Inspections 

Utility Carriers with 

Vehicle OOS 

Violations 

(Vehicle OOS Rate) 

Idaho 

(10.7%/29.3%) 5 0 (0.0%) 5 2 (40.0%) 

Kansas 

(8.8%/17.9%) 46 4 (8.7%) 43 9 (20.9%) 

Maryland 

(7.3%/19.7%) 35 0 (0.0%) 35 5 (14.3%) 

Michigan 

(6.1%/19.0%) 8 1 (12.5%) 3 0 (0.0%) 

Total 

(2008 National 

Driver/Vehicle OOS 

Rates: 

6.4%/22.3%) 

94 5 

(5.3%) 86 16 (18.6%) 

Source: Special Study Survey Data and MCMIS Data Snapshot for December 18, 2009. 

Note: Asterisk denotes rate is statistically significant compared to the State or national rate using a one-tailed test at a level of 

α=0.05 

26 
6.1.3 Agricultural and Utility Carriers Operating Within or Beyond 100-Air-Mile 

Radius 

The survey data for the four States were combined and driver and vehicle OOS rates were 

calculated for agricultural commodity carriers identified as operating within a 100-air-mile 

radius, representing those that are exempt from the HOS requirements. Similar rates were 

calculated for the agricultural carriers identified as operating beyond a 100-air-mile radius, 

representing those not exempt from the HOS requirements. The rates for the two groups were 

then compared to determine if there was a statistically significant difference in OOS rates. As 

shown in Table 15, the agricultural carriers operating beyond a 100-air-mile radius had a 

statistically higher driver OOS rate than the carriers operating within a 100-air-mile radius. But 

the results were just the opposite for vehicle OOS rates, with the agricultural carriers operating 

within a 100-air-mile radius having a statistically higher OOS rate than the carriers operating 

beyond a 100-air-mile radius. Given that the “within 100-air-miles” carriers are exempt from the 

HOS requirements, it is not surprising that their driver OOS rate was found to be lower than the 

“beyond 100-air-miles” carriers. The finding that their vehicle OOS rate is higher than the 

“beyond 100-air-miles” carriers is consistent with the Phase 1 analysis results. 

The same procedure was used to compare utility service carriers identified in the survey as 

operating within a 100-air-mile radius with those operating beyond a 100-air-mile radius. The 

differences in driver and vehicle OOS rates were not statistically significant between the two 

groups of utility carriers (see Table 14). It should be noted that the small number of inspections 

and OOS violations affected the statistical test. For example, even though the vehicle OOS rate 

for utility carriers operating within a 100-air-mile radius (23.3 percent) was five times greater 

than the vehicle OOS rate for those operating beyond a 100-air-mile radius (4.6 percent), because 

there were 60 vehicle inspections and 14 OOS violations for those driving within the 100-airmile radius and only 22 vehicle inspections and 1 OOS violation for those driving beyond the 

100-air-mile radius, the proportion test was determined to be statistically not significant at the 95 

percent confidence level (Z = 1.632). 

Table 14. Driver/Vehicle OOS Rates by Agricultural and Utility Carriers Driving Beyond and Within 

100-Air-Mile Radius in the Four Survey States Combined 

Type of Carrier and OOS 

Rate 

Driving Within 100 Air-Mile 

Radius 

Driving Beyond 100 Air-Mile 

Radius 

Agricultural Carriers’ 

Driver OOS Rate 

3.1% 

(n=260) 

9.0% * 

z = 2.885 

 (n=440) 

Agricultural Carriers’ 

Vehicle OOS Rate 

25.5% * 

z = 2.037 

(n=231) 

17.8% 

(n=297) 

Utility Service Carriers’ 

Driver OOS Rate 

4.8% 

(n=63) 

 0.0% 

(n=25) 

Utility Service Carriers’ 

Vehicle OOS Rate 

23.3% 

(n=60) 

4.6% 

(n=22) 

Source: Special Study Survey Data. 

Note: Asterisk denotes rate is statistically significant compared to the corresponding carrier group operating beyond 100-air-mile 

radius using a one-tailed test at a level of α=0.05 

27 
To determine if the only difference in driver OOS rates between exempt and non-exempt carriers 

was that the non-exempt group was subject to HOS requirements, an additional comparison was 

made. HOS-related OOS violations were removed from the driver violations data for agricultural 

commodity carriers operating beyond a 100-air-mile radius. This produced a reduction from 40 

total violations to 13 violations, having removed 27 HOS-related violations, and resulted in a 

driver OOS rate of 3.0 percent. When this adjusted rate is compared to the 3.1 percent OOS rate 

for the agricultural carriers operating within a 100-air-mile radius, the difference is no longer 

statistically significant (see Table 15). This indicates that the reason the carriers operating 

beyond a 100-air-mile radius have a higher OOS rate than carriers operating within a 100-airmile radius is based on one being subject to HOS requirements and the other not. 

Because the survey data did not record any OOS violations for utility carriers operating beyond a 

100-air-mile radius there were no HOS violations to be removed. Therefore, the comparison of 

utility carrier driver OOS rates did not change from what was presented in Table 14, and the 

difference remained statistically insignificant. 

Table 15. Driver OOS Rates of Agricultural Commodity & Utility Carriers Driving Beyond or Within 

a 100-Air-Mile Radius (HOS violations removed from Beyond 100-Air-Mile Group) in the Four 

Survey States Combined 

Type of Carrier and OOS Rate Driving Within 100 Air-Mile 

Radius 

Driving Beyond 100 Air-Mile 

Radius 

Agricultural Carriers’ 

Driver OOS Rate 

3.1% 

 (n=260) 

3.0% 

 (n=440) 

Utility Service Carriers’ 

Driver OOS Rate 

4.8%. 

 (n=63) 

0% 

 (n=25) 

Source: Special Study Survey Data. 

6.2 CRASH RATES 

6.2.1 Agricultural Carriers Operating Within or Beyond 100-Air-Mile Radius 

The agricultural carriers inspected in the survey were matched with their MCMIS registration 

and crash information, sorted as described in the Phase 2 Methodology section of this study, and 

two groupings were created: (1) Carriers that exclusively drive within 100-air-miles and are 

exempt from the HOS requirements, and (2) Carriers that exclusively drive beyond 100-air-miles 

and are subject to the HOS requirements. Crash rates per 100 power units were calculated for 

each group for 2007 and 2008 (Table 16 and Table 17). 

The difference between these crash rates indicates that the agricultural carriers operating beyond 

a 100-air-mile radius and subject to the HOS requirements had a higher crash rate than those 

operating within a 100-air-mile radius and exempt from the HOS requirements. 

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29 

Table 16. Crash Rates by Time Period for Agricultural Commodity Carriers in the Phase 2 Survey 

and by Driving Distance (Exclusively Within a 100 Air-Mile Radius) 

Time 

Period Carriers Crashes

Power 

Units 

Crash 

Rate 

2007 39 15 509 2.95 

2008 42 26 548 4.74 

Source: Special Study Survey Data, MCMIS Data Snapshot for May 

22, 2009, and December 2007 and 2008 SafeStat runs. 

Table 17. Crash Rates by Time Period for Agricultural Commodity Carriers in the Phase 2 Survey 

and by Driving Distance (Exclusively Beyond a 100 Air-Mile Radius) 

Time 

Period Carriers Crashes 

Power 

Units 

Crash 

Rate 

2007 330 392 6,444 6.08 

2008 379 371 6,910 5.37 

Source: Special Study Survey Data, MCMIS Data Snapshot for May 

22, 2009, and December 2007 and 2008 SafeStat runs. 
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7. PHASE 2 CONCLUSIONS 

The Phase 2 analysis of the safety of agricultural and utility carriers and the impact of the HOS 

exemption yields the following conclusions: 

 In the four States participating in the survey (Idaho, Kansas, Maryland, and Michigan), 

the driver and vehicle OOS rates of the surveyed agricultural carriers were statistically no 

different from the OOS rates of all carriers in their States. Exceptions were in data from 

Idaho and Maryland where the agricultural carriers’ vehicle OOS rate was higher than the 

average rate for all carriers in each State, respectively. 

 When data from the four survey States were combined, the aggregated driver OOS rate 

was statistically higher than the national average driver OOS rate, but the vehicle OOS 

rate was not different from the national average. The States’ higher driver OOS rate for 

the agricultural carriers in the survey is most likely due to the fact that the majority of 

inspections came from Kansas (Table 11), which has a higher driver OOS rate than the 

national average (8.8 percent vs. 6.4 percent). 

 None of the States had utility carrier driver or vehicle OOS rates that differed from their 

State average OOS rates. When the data were aggregated, the utility carrier driver and 

vehicle OOS rate were not statistically different from the national averages. 

 When separating the agricultural carriers in the survey into two groups—those recorded 

as driving within a 100-air-mile radius and those that drove beyond a 100-air-mile 

radius—those operating beyond a 100-air-mile radius had a statistically higher driver 

OOS rate, but those operating within a 100-air-mile radius had a statistically higher 

vehicle OOS rate. After removing the HOS OOS violations from the agricultural carriers 

operating beyond a 100-air-mile radius, there was no statistical difference between the 

carriers operating within and those operating beyond a 100-air-mile radius. An analysis 

of utility carrier OOS rates showed no statistical difference between the two groups for 

either driver or vehicle OOS rates. 

 Agricultural carriers in the survey that were subject to the HOS requirements had higher 

crash rates per power unit than carriers exempt from the HOS requirements. 

In considering these conclusions, the reader should take into account that the number of 

participating States and the amount of data collected were less than what was called for in the 

Phase 2 study design (Table 11), so the statistical analysis of safety impacts was affected. 

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APPENDIX A: FMCSA FORM MCS-150, MOTOR CARRIER 

IDENTIFICATION REPORT 

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