Motor Carriers: Establishing System for Self-Reporting Equipment Problems Appears Feasible, but Safety Benefits Questionable and Costs Unknown
Published: 2016-12-02T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: In 2015, more than 4,000 people were killed in crashes involving large trucks. To identify carriers with the highest crash risk, FMCSA uses information from roadside inspections and crashes to rank each carrier's safety performance relative to other carriers in seven categories, including one on vehicle maintenance. Some stakeholders have proposed a system for carriers or their drivers to self-report en route vehicle equipment problems to FMCSA. Reported equipment problems that were repaired within a certain time period would not affect the carrier's relative ranking, potentially incentivizing carriers to make repairs more quickly.
The Fixing America's Surface Transportation Act included a provision for GAO to examine the cost and feasibility of establishing a system for carriers or drivers to self-report vehicle equipment problems to FMCSA. This report examines (1) the potential safety impacts of a self-reporting system and (2) factors that could affect its feasibility and cost.
GAO reviewed relevant regulations, information on other existing DOT self-reporting systems, and prior related GAO work. GAO also interviewed a non-generalizable sample of representatives from six industry and safety associations, six carriers, and six drivers about this potential system for self-reporting equipment problems. GAO selected carriers to include those with diverse fleet sizes and average distances traveled, and drivers from six additional carriers.
DOT provided technical comments, which were incorporated as appropriate.
section_title: What GAO Found
paragraphs: Establishing a system that would provide incentives for trucking companies to self-report equipment problems may not necessarily yield safety benefits. Most stakeholders GAO interviewed—including selected carriers and drivers—thought a self-reporting system would be unlikely to produce safety benefits, stating that it would not incentivize quicker repairs. If repairs are not made more quickly, there would be no positive impact on safety. Three drivers, however, thought a self-reporting system could yield some safety benefits if it incentivized drivers to do more thorough inspections of their vehicles. Officials from industry groups and the Federal Motor Carrier Safety Administration (FMCSA) noted that a self-reporting system could negatively impact safety, such as by encouraging distracted driving if drivers report equipment problems on their cell phones while driving. Moreover, estimating the potential safety impacts of such a system requires information that is not currently available, such as how equipment problems that would be permitted to be self-reported are related to crashes.
Example of a Driver Receiving a Violation for a Previously Identified Equipment Problem under Current System and under a Self-Reporting One
FMCSA has the statutory and regulatory authority to establish a system for self-reporting equipment problems, and technology exists to create it, but its costs are unknown. Also, establishing such a system could pose challenges for FMCSA, carriers, and drivers. For example, developing a new system could delay efforts FMCSA has under way to improve its information technology, and carriers or drivers may have difficulty selecting their specific equipment problem from the more than 300 potential vehicle maintenance violations. Further, without information on key design features of a self-reporting system, such as whether reporting would be through a telephone hotline or a web-application, it is not possible to estimate costs with any reasonable degree of confidence. FMCSA developed a rough estimate that a self-reporting system would cost between $5 and $10 million to establish and operate for the first year.

section_title: Letter
paragraphs: Large trucks and buses transport billions of tons of freight and travel  hundreds of billions of miles every year on our nation’s highways.  Because these commercial motor vehicles travel alongside citizens in  passenger vehicles, safety is an important concern. In 2015, more than  4,000 people were killed in crashes involving large trucks, the majority of  whom were either in another vehicle or were pedestrians or bicyclists.  Crashes involving commercial motor vehicles can be caused by a variety  of factors, including driver error or equipment problems such as faulty  brakes or flat tires. The Federal Motor Carrier Safety Administration  (FMCSA) sets requirements in regulations for the operating condition of  vehicles operated by commercial motor carriers (“carriers”). These  include requirements for the maintenance of commercial motor vehicle  parts and accessories such as lights, reflectors, brakes, fuel systems, and  tires. Carriers and commercial motor vehicle drivers are responsible for  ensuring their vehicles meet those requirements at all times. If a driver  identifies some aspect of his or her vehicle’s equipment that is out of  compliance with these regulations—for instance brakes that do not  adequately stop and hold the vehicle—the carrier (or its agent, e.g., the  driver or a repair facility) is responsible for repairing the problem before  the vehicle is on the road.
To enforce compliance with FMCSA regulations, FMCSA partners with  states’ law enforcement agencies and others to perform roadside  inspections of commercial motor vehicles. Inspectors compare the  vehicle’s condition to requirements listed in FMCSA’s regulations, and  review the driver’s credentials. If an inspector determines that a vehicle is  out of compliance with those regulations, the carrier is issued a violation,  which is reported to FMCSA. In 2015, federal and state inspectors  conducted approximately 3.4 million roadside inspections, including 2.3  million vehicle inspections that resulted in 3.8 million vehicle maintenance  violations, ranging from less severe (e.g., one of several marker lights  out) to more severe (e.g., a problem with brakes that could lead to a  crash). With inspection and crash information, FMCSA uses its Safety  Measurement System (SMS) to generate a percentile ranking of a  carrier’s safety performance relative to other carriers in several different  categories. Each category is referred to as a Behavior Analysis and  Safety Improvement Category (BASIC), and includes vehicle  maintenance, among other things.
Some industry stakeholders have raised the possibility of instituting a  system for carriers and their drivers to self-report equipment problems  that they identify to FMCSA. These stakeholders have suggested that if  an inspector identified a self-reported equipment problem during an  inspection, it should not count against the carrier’s vehicle maintenance  BASIC percentile if repaired within a specified time frame.
The Fixing America’s Surface Transportation Act (FAST Act) included a  provision for us to examine the cost and feasibility of establishing a  system for self-reporting en route equipment problems for commercial  motor carriers, and report by December 4, 2016. The provision described  some parameters of a potential system for self-reporting equipment  problems, including that it would apply only to equipment problems  identified en route, which we defined as those identified after a driver  conducted his required pre-trip inspection at the beginning of each work  day and before a driver conducted his required inspection report at the  end of each work day. In addition, carriers or drivers that self-reported an  equipment problem and subsequently received an inspection and  violation for that problem would have to self-report that the problem had  been repaired for FMCSA to exclude the violation from the carrier’s  vehicle maintenance BASIC percentile.
This report examines (1) potential safety impacts of establishing a system  for self-reporting equipment problems and repairs for commercial motor  carriers and their drivers, and (2) factors that could affect the feasibility  and cost of establishing a system for self-reporting equipment problems  and repairs.
To perform this work, we reviewed relevant regulations, information on  other existing systems for self-reporting safety-related information,  (FMCSA’s National Consumer Complaint Database and the Federal  Aviation Administration’s (FAA) Aviation Safety Action Program), and our  past work on FMCSA’s Compliance, Safety, Accountability (CSA)  program. We also interviewed FMCSA officials and selected  stakeholders—representatives from six associations (industry and safety  groups), representatives of six commercial motor carriers, and six  commercial motor vehicle drivers. The six carriers included two large, two  medium, and two owner-operators, who are individuals who own and  operate their own trucks as an independent company. The six drivers  were from six additional carriers and included four drivers for large  carriers and two drivers for medium-sized carriers. Associations were  selected for their work in the motor carrier and highway safety arenas.  Carriers were selected for diversity in fleet size and haul distance.  Additional carriers provided a list of drivers from which we selected  drivers for diversity in haul distance. Views we gathered from these  stakeholders are not generalizable to all industry and safety groups,  motor carriers, or drivers.
Because the self-reporting system is hypothetical at this point, we made  three broad assumptions about the system, based on its description in the  FAST Act and our review of relevant regulations.
First, only equipment problems that do not render a commercial motor  vehicle “out-of-service” under FMCSA regulations would be reportable  under a self-reporting system.
Second, the term “en route” refers to equipment problems that were  identified while the driver was on his daily trip—that is, after a driver  conducted his required pre-trip inspection at the beginning of each  work day, and before a driver conducted his required inspection report  at the end of each work day.
Finally, any equipment problems identified and reported would have to  be repaired before the driver’s next day on duty.
When interviewing stakeholders, we asked for their views on how, if at all,  they or others (in the case of associations) might use such a system, and  an estimation of its potential safety impacts. We did not systematically try  to identify any unintended consequences of establishing a self-reporting  system, such as whether carriers or drivers would “game the system” by,  for example, using it to report equipment problems during a trip that  should have been identified in a pre-trip inspection and repaired before  the trip began.
To examine the potential safety impacts of this hypothetical self-reporting  system, we identified existing guidance (Office of Management and  Budget and Department of Transportation) on estimating the benefits of a  new government program. We then determined if there was sufficient  information available to apply such guidance and estimate the benefits of  a self-reporting system. To identify published data on the relationship  between non-out-of-service equipment problems and safety outcomes,  we used a literature review conducted for a 2014 GAO report on FMCSA  as a starting point, and consulted with GAO experts and FMCSA to  identify any data published since 2014.
We conducted this performance audit from March 2016 to December  2016 in accordance with generally accepted government auditing  standards. Those standards require that we plan and perform the audit to  obtain sufficient, appropriate evidence to provide a reasonable basis for  our findings and conclusions based on our audit objectives. We believe  that the evidence obtained provides a reasonable basis for our findings  and conclusions based on the audit objectives.
subsections: section_title: Background
paragraphs: The commercial motor-carrier industry is a vital part of the U.S. economy.  As of December 2015, FMCSA estimated that there were 551,150 active  carriers and approximately 6 million commercial drivers operating in the  United States. The domestic commercial motor-carrier industry includes  a range of businesses, including private and for-hire freight transportation,  passenger carriers, and specialized transporters of hazardous  materials. These carriers also range from small carriers with only one vehicle that is owned and operated by a single individual, to large  corporations that own tens of thousands of vehicles.
FMCSA is responsible for overseeing this large and diverse industry. In  fiscal year 2016, FMCSA had a budget of approximately $580 million and  more than 1,000 staff members located at its Washington, D.C.,  headquarters, four regional service centers, and 52 division offices.
FMCSA establishes regulations for all interstate motor carriers in addition  to intrastate hazardous-material carriers. FMCSA regulations set  requirements, among others, for the motor vehicle parts and  accessories—“equipment”—required for safe operation. For example,  FMCSA’s regulations require vehicles to have certain lights, tire tread  depth, and parking brakes.
Other FMCSA regulations require carriers and their drivers to  systematically inspect, repair, and maintain their vehicles. Before  beginning their trip each day, commercial motor vehicle drivers must  conduct a pre-trip inspection to ensure that their vehicles are in safe  operating condition, meaning that they meet the maintenance  requirements set forth in FMCSA regulations. Commercial driver’s  license tests require drivers to show they can inspect the engine  components, brakes, steering, and other equipment. If during the pre- trip inspection the driver identifies an equipment problem that would affect  the safe operation of the vehicle, the driver must ensure it is repaired  before starting a trip. At the end of each day, drivers are also required to  prepare a daily vehicle inspection report (DVIR), which lists any  equipment problems identified that day. Drivers submit the DVIRs to  their carrier, which must repair any issues before sending the vehicle on  another trip. Regulations also require carriers to conduct comprehensive  inspections of their vehicles annually. FMCSA regulations set the  minimum requirements for commercial motor vehicles, but individual  carriers may have their own additional requirements regarding when and  how their vehicles are inspected and repaired.
To oversee the safety performance of the commercial motor carrier  industry, FMCSA and state agencies such as highway patrols perform  roadside inspections of carriers’ vehicles. These roadside inspections are  intended to provide a snapshot of commercial motor vehicles’  maintenance and assess the effectiveness of carriers’ maintenance  programs.
Specially trained and certified personnel serve as inspectors and select  commercial motor vehicles for inspection as they pass through a roadside  inspection location such as a weigh station. The inspector compares the  vehicle’s condition to requirements listed in FMCSA’s regulations and  issues a violation if there are discrepancies. If the inspector determines  that the violation could likely cause an accident or breakdown (for  example, if more than 20 percent of the vehicle’s brakes are defective)  the vehicle is placed out-of-service until it is repaired. FMCSA  regulations prohibit carriers from operating a vehicle that has been  deemed “out-of-service” by an inspector. The Commercial Vehicle Safety  Alliance, an association comprised of federal and state commercial-  vehicle safety officials and private industry representatives, provides  guidance on the criteria that render a vehicle out-of-service. Even if  violations are found, if the vehicle is not deemed out-of-service, the driver  is allowed to continue driving, though FMCSA regulations require carriers  to repair all violations before the vehicle starts another trip. In addition,  within 15 days of receiving the violation, carriers must certify they have  made repairs by signing a copy of the inspection report and sending it to  the state department of transportation. See figure 1 for four examples of  vehicle maintenance violations—the top two depict improper load  securement and the bottom two depict missing wheel fasteners. In both  rows, the violation on the right is an out-of-service violation.
FMCSA uses the data on violations submitted by inspectors to rank  carriers’ relative safety performance in seven categories and assign  carriers to a percentile in each. One of the categories, the vehicle  maintenance Behavior Analysis and Safety Improvement Category  (BASIC), takes into account violations related to failing to properly  maintain a commercial motor vehicle and failing to secure loads. FMCSA  uses these BASIC percentiles to identify and target “high-risk” carriers for  interventions, such as warning letters and on-site investigations.
In 2014, we reported on the effectiveness of SMS and found that FMCSA  faces challenges in reliably assessing safety risks for the majority of  carriers. We recommended that FMCSA revise the SMS methodology to  better account for limitations in drawing comparisons of safety  performance information across carriers. As of November 2016, FMCSA  has not implemented our recommendation. The FAST Act directed  FMCSA to address the issues raised in our report and required that  FMCSA remove the BASIC percentiles from public view on its website  until then, which it has done.
section_title: While Potential Safety Impact of a Self- Reporting System Is Difficult to Determine, FMCSA and Selected Stakeholders Suggested Safety Benefits Are Unlikely
subsections: section_title: Identifying Potential Safety Impact of a System for Self-Reporting Equipment Problems Is Challenging
paragraphs: One of the challenges in assessing the safety impact of a potential  system for self-reporting equipment problems is its hypothetical nature.  As described above, based on one of the provisions in the FAST Act and  discussions with FMCSA and stakeholders, we made a number of  assumptions about such a system. We assumed that a self-reporting  system would: apply only to problems identified during a driver’s day, that is between  the pre-trip inspection and the end of the day when the driver vehicle  inspection report is completed; not apply to equipment problems that would result in out-of-service  require drivers to report equipment problems and repairs through a  telephone hotline or Internet website or other electronic platform;  require repairs to be made before the beginning of the next day on  duty (e.g., within a day of when the problem was reported, if the driver  ended his trip that evening and planned another trip the following  day);  still result in a carrier receiving a violation for the equipment problem if  pulled over for a roadside inspection, but once a self-reported  equipment problem was repaired within the requisite time frame and  FMCSA was so notified, FMCSA would exclude the violation from the  carrier’s relative safety ranking (i.e., BASIC percentile for vehicle  maintenance); and not prompt FMCSA to take action if a carrier or driver self-reported an  equipment problem, but never received a violation for that equipment  problem.
Figure 2 below illustrates some of the key differences between the current  process for identifying and repairing equipment problems and the process  under a potential self-reporting system with the features assumed above.
The Office of Management and (OMB) and the Department of  Transportation (DOT) provide guidance on estimating a program’s  societal impact, such as its health and safety benefits, through a benefit- cost analysis. For example, DOT’s Economic Analysis Primer states that  a benefit-cost analysis requires the identification of a base case—usually  the status quo—so that the benefits and costs associated with  implementing the new program can be compared against this base. For  a new program designed to affect safety, identifying the base case and  the potential benefits of the new program generally requires data on past  events related to the type of bad outcomes (i.e., injuries and deaths) that  the new program is expected to reduce.
Even after putting some parameters on a hypothetical system for self- reporting equipment problems (i.e., our assumptions), estimating its  overall safety impact is challenging for two key reasons:  1.  We did not identify any conclusive data on the “base case” or status  quo for a self-reporting system—that is, data on how non-out-of- service equipment problems are related to safety outcomes. FMCSA  and the National Highway Traffic Safety Administration estimated that  equipment problems such as braking capacity, tire or wheel failure, or  shifting cargo were the critical reason for a crash in about 10 percent  of the crashes for which a critical reason was assigned to a truck, as  reported in the Large Truck Crash Causation Study. However, this  study was issued 11 years ago and did not separately present data for  or otherwise discuss the extent to which non-out-of-service equipment  problems were related to crashes. Further, our review of literature and  interviews with FMCSA did not identify any additional data.  Consequently, there is no baseline against which to evaluate the  extent to which safety may be improved with the implementation of  such a system.  2.  Even if such data were available, we determined that an assessment  of potential safety impacts would also require information on the  extent to which a self-reporting system would change the frequency or  speed with which drivers make equipment repairs. This would require  information on both the frequency and speed with which carriers  currently make repairs, and how a self-reporting system would change  that behavior. Both, however, are unknown and difficult to determine  because they would require predicting behavior under hypothetical  conditions.
section_title: Most Selected Stakeholders Told Us Their Use of a Self- Reporting System Would Be Affected by Factors Such as Ease of Use
paragraphs: For a self-reporting system to impact safety, carriers and drivers would  have to use it, but the majority of carriers and drivers we interviewed said  their use of a potential self-reporting system would depend on various  factors. The most frequently cited factor was ease of use. For example,  some said they preferred a telephone hotline to a web-based application;  others said the opposite. One carrier and one driver said they would use  a self-reporting system if they thought they were traveling a route where  an inspection was likely. Another carrier said it might use a self-reporting  system if it afforded them increased flexibility to wait to repair low risk  equipment problems at a less expensive repair facility, such as the  carrier’s own maintenance facility.
Representatives from five of six industry and safety associations we  interviewed said they would be unlikely to support a self-reporting system  as outlined above. Industry and safety representatives cited reasons such  as an administrative burden for drivers and carriers, and potentially  negative safety impacts, as described below. Representatives from one  industry association noted that a self-reporting system should allow  drivers to simply record an equipment problem in their driver vehicle  inspection report (DVIR) when they notice the problem. If by chance a  driver was pulled over subsequent to recording in the DVIR, the driver  could show the record to the inspector and not receive a violation for that  equipment problem. However, as discussed above, for FMCSA to ensure  that self-reported equipment problems were repaired, FMCSA would first  have to receive a record of a violation. Then, after receiving certification  of the accompanying repair, FMCSA would ensure that the violation was  not included in the calculation of the carrier’s vehicle maintenance BASIC  percentile. Thus, noting the equipment problem on a DVIR would not be  sufficient.
section_title: Most Carriers and Drivers Anticipated No Significant Safety Benefits of a Self- Reporting System, and FMCSA and Other Stakeholders Said It May Negatively Impact Safety
paragraphs: To impact safety, a self-reporting system would also have to prompt  drivers and carriers to change the way they identify and repair equipment  problems, yet the majority of carriers and drivers we interviewed said the  system would not change, for example, how quickly they made repairs.  As described above, FMCSA regulations require drivers to conduct a pre- trip and end-of-day inspection of their vehicle and to ensure that any  identified issues are repaired before driving. Carriers and drivers we  interviewed said that if they identify an equipment problem en route, that  is, after their pre-trip inspection, they work with their carrier to determine  when and where to repair the problem. Many carriers and drivers we  interviewed said they would continue to identify and repair equipment  problems the same way and with the same speed under a system for self- reporting equipment problems.
More generally, the majority of carriers and drivers we interviewed stated  that any safety impacts of a self-reporting system—positive or negative— would be minimal. For example, three drivers thought a self-reporting  system could potentially yield some safety benefits if it incentivized  drivers to do more thorough pre-trip or en route inspections. This could  lead to better identification and quicker repair of equipment problems. On  the other hand, three carriers and two other drivers we interviewed  thought a self-reporting system could potentially yield some negative  safety impacts if it incentivized some drivers to delay or avoid making  repairs for problems they had self-reported.
Further, FMCSA officials and safety association representatives we  interviewed stated that they believed a self-reporting system could lead to  negative safety outcomes. FMCSA officials said that a self-reporting  system could result in carriers trying to “game the system,” for example  by using it to report equipment problems during a trip that should have  been identified in a pre-trip inspection and repaired before the trip began.  FMCSA officials said that this type of delayed repair could lead to a more  serious maintenance condition occurring. Representatives from safety  associations said that carriers and drivers might delay making repairs  until the end of any permitted time period or might engage in distracted  driving while typing or calling in an en route equipment problem on their  cell phones.
section_title: FMCSA Has the Statutory and Regulatory Capability to Establish a Self- Reporting System, but FMCSA and System Users May Face Challenges, and Costs are Unknown
subsections: section_title: We Did Not Identify Any Statutory or Regulatory Barriers to Establishing a System for Self-Reporting Equipment Problems
paragraphs: Neither we nor FMCSA identified any statutory or regulatory barriers to  establishing a system for self-reporting equipment problems. When  Congress established FMCSA in 1999, it granted the agency authority to  develop and enforce commercial motor-vehicle safety regulations and  practices to promote a safe and efficient transportation system. With this  authority, FMCSA created regulations setting requirements for vehicles’  operating condition and roadside inspections. Under this authority,  FMCSA could create a system for self-reporting equipment problems.
Similarly, we did not identify any barrier in existing regulations to  establishing a self-reporting system. FMCSA officials stated that if a self- reporting system were in place, vehicles would still be required to meet  the minimum vehicle condition requirements and inspectors would  continue to inspect vehicles to ensure compliance with these regulations  and issue violations. Rather than altering existing regulations, FMCSA  officials said a potential self-reporting system would require FMCSA to  change its internal policy document that outlines how FMCSA calculates  carriers’ vehicle maintenance BASIC percentiles.
section_title: FMCSA and Users Could Face Challenges Implementing a Self- Reporting System
paragraphs: While the technology exists for FMCSA to establish a system for self- reporting equipment problems, the agency may face challenges  implementing such a system. FMCSA officials stated they could design a  self-reporting system to be compatible with the agency’s existing IT  systems. FMCSA currently uses its Motor Carrier Management  Information System (MCMIS) to manage motor carrier and driver  performance data, including inspection and investigation results.  FMCSA officials said they could potentially use MCMIS to manage self- reported equipment problem information, but there might be challenges  matching self-reported vehicle maintenance issues with violations issued  by inspectors in the MCMIS database. For example, to exclude  equipment problem violations that were self-reported and repaired from  BASIC percentile calculations, FMCSA would have to match the self- reported equipment problem and repair to a corresponding report of a  violation issued by an inspector for that same equipment problem. This  could be difficult if, for example, the driver and inspector coded the  equipment problem differently (e.g., driver recorded “inoperative required  lamps” and inspector recorded “inoperative head lamps”). Safety  advocacy groups believed more oversight would be necessary to ensure  carriers actually made repairs, but FMCSA and multiple carriers believed  showing proof of repairs for every report (e.g., receipts or written repair  orders) as opposed to simply self-certifying a repair, would be too time- consuming.
In addition, we found in October 2016 that FMCSA has faced long- standing delays with software development. Creating a self-reporting  system could place new demands on FMCSA’s information technology  resources. FMCSA has put a hold on rolling out new enforcement  strategies, such as offsite investigations (investigations conducted  remotely using documents submitted by carriers, such as toll receipts,  border crossing records, or drug testing records), until the agency has  finished creating an improved software system to manage these  enforcement activities. Developing a self-reporting system could further  delay these software improvements. FMCSA officials estimated it could  take between 3 and 5 years to develop a self-reporting system. FMCSA  officials, one safety advocacy group, and an industry group we  interviewed echoed this concern, suggesting that a self-reporting system  could divert FMCSA resources from other IT priorities. For example, one  industry group thought FMCSA should focus on improving its DataQ  system, which allows carriers to challenge, and correct as appropriate,  violations appearing on their records.
Finally, FMCSA officials told us that building, implementing, and  maintaining a self-reporting system would require significant resources.  For example, FMCSA would need to comply with the Paperwork  Reduction Act of 1995 (PRA), a process that FMCSA officials said has  been time consuming in the past. The PRA requires agencies to minimize  the paperwork burden of their information collections (e.g., driver’s license  and Vehicle Identification Number (VIN) information in the case of a self- reporting system) and evaluate whether a proposed information collection  is necessary for the proper performance of agency functions. To do so,  the agency must complete an “information collection request,” which  includes a report on why certain information is being collected and an  estimate of the cost to the public.
Carriers and drivers could also face challenges using a potential system  for self-reporting equipment problems. For example, both a web  application and telephone hotline would require drivers to have cell  service—which is not always the case for drivers in remote areas of the  country. It could be possible, therefore, for a driver to be stopped for an  inspection before he was able to report an equipment problem. If the  system were a web application, drivers would need smartphones to report  an equipment problem, but some drivers may not have one. If the system  were a telephone hotline, two carriers and one driver worried the hotline  could become inundated with calls with long wait times, though as noted  above, it is not clear how many carriers would utilize such a system.
Carriers or drivers could also face challenges accurately entering required  information. For example, FMCSA could require drivers to enter their 17- digit VIN along with their Commercial Driver’s License number when  reporting an equipment problem or repair, but entering this many digits  could yield errors. Additionally, drivers would need to identify the violation  that most closely matched their equipment problem, out of more than 300  potential vehicle maintenance violations. In some instances, that may be  difficult to do; for example, there are 17 different violations related to  reflective sheeting (e.g., not having reflectors on mud flaps). As discussed  above, the way a driver or carrier self-reported a problem could differ from  the way an inspector reported the violation. Similarly, identifying whether  an equipment problem could render a vehicle out of service could be  challenging. Equipment problems may or may not place a vehicle out-of- service depending on their severity. For example, regulations require a  vehicle’s front tire treads to be at least 4/32 of an inch deep. Drivers will  receive a violation if the tread is less than that requirement, but will only  be placed out of service if the tread is less than 2/32 of an inch deep.  Thus, it is possible that a driver could self-report a “tire tread depth”  problem into a self-reporting system, but be operating with an out-of- service tread depth.
section_title: Without Details of System’s Design, Total Costs Cannot Be Quantified
paragraphs: According to our cost-estimating guidance, creating an accurate cost  estimate for any program requires a description of the system and its  technical and performance characteristics—characteristics that are not  currently known for this self-reporting system. For example, we do not  know whether the system would be a web-based application or a staffed  hotline, nor do we know the extent to which FMCSA would need to review  reports submitted in the system. Design options such as these would  affect the number of FMCSA staff needed to operate and maintain the  system and would require different amounts of IT investment. Therefore, without knowing these design characteristics, we cannot estimate the  initial cost of developing a potential self-reporting system or the continued  costs of maintaining it with any degree of confidence.
However, two existing DOT self-reporting systems can provide a  benchmark for potential costs of a self-reporting system, though these  systems differ from an equipment problem self-reporting system in  substantive ways. FMCSA maintains the National Consumer Complaint  Database (NCDDB), which allows drivers and the general public to submit  complaints ranging from moving companies damaging household goods  to drivers being forced to operate unsafe equipment. According to  FMCSA officials, this database received approximately 20,000 reports in  2015, and cost approximately $1 million to operate in that year. While the  NCCDB seems similar to a system for self-reporting equipment problems  in that it allows drivers to self-report information through both a website  and hotline, it differs in that NCCDB complaints do not feed into another  FMCSA IT system, as self-reported equipment problems would need to.  FMCSA officials thought that linking the self-reported equipment problems  and MCMIS data systems would be the most costly part of developing a  system for self-reporting equipment problems.
FAA maintains the Aviation Safety Action Program (ASAP), which allows  pilots, flight attendants, and maintenance employees to voluntarily report  safety incidents to help FAA identify potential precursors to accidents.  FAA officials reported that in 2015 ASAP received 98,000 reports and  cost approximately $23 million in personnel costs only. This amount did  not include the cost to establish ASAP or costs for operating the system  itself. ASAP is similar to a motor carrier system for self-reporting  equipment problems in that by self-reporting, users can avoid violations,  but differs in a number of key ways. For example, ASAP does not include  reporting for equipment problems, its focus is on identifying potential  precursors to accidents, and it devotes significant resources to  assembling committees to review each ASAP report and identify a  corresponding corrective action, something which a motor carrier self- reporting system likely would not.
While we cannot estimate costs for the type of self-reporting system  described in this report with any degree of confidence, FMCSA broadly  estimated that a self-reporting system would cost between $5 and $10  million to establish and operate for the first year. FMCSA officials said this  estimate did not use other DOT self-reporting systems as a benchmark  nor did it explicitly include training, testing, or data storage—some of the  factors that GAO’s cost-estimating guide identifies as key to establishing  and maintaining a new electronic system. Therefore, this estimate may  not cover the full cost of establishing a system for self-reporting  equipment problems.
section_title: Agency Comments
paragraphs: We provided a draft of this report to DOT for review and comment. DOT  provided technical comments, which we incorporated as appropriate.
We are sending copies of this report to relevant congressional  committees, the Secretary of Transportation, and the Administrator of  FMCSA. In addition, the report is available at no charge on GAO’s  website at http://www.gao.gov.
If you or your staff have any questions about this report, please contact  me at (202) 512-2834 or flemings@gao.gov. Contact points for our  Offices of Congressional Relations and Public Affairs may be found on  the last page of this report. GAO staff who made major contributions to  this report are listed in appendix I.
section_title: Appendix I: GAO Contact and Staff Acknowledgments
subsections: section_title: GAO Contact
section_title: Staff Acknowledgments
paragraphs: In addition to the individual named above, H. Brandon Haller (Assistant  Director), Sarah Farkas (Analyst-in-Charge), Amy Abramowitz, Russell  Burnett, David Hooper, Catrin Jones, Delwen Jones, and Malika Rice  made key contributions to this report.