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Comprehensive Safety Analysis 2010: A New Approach to Commercial Vehicle Safety
- 1. Comprehensive Safety Analysis (CSA) 2010 A New Way To Measure and Address Commercial Motor Vehicle Safety Industry Briefing April 12, 2010 U.S. Department of Transportation Federal Motor Carrier Safety Administration
- 3. Why Change?
- 4. Commercial Motor Vehicle Fatalities Rate of Commercial Motor Vehicle Fatalities is Leveling Off
- 8. CSA 2010 Defined
- 9. A New Operational Model (Op-Model)
- 10. A New Operational Model (Op-Model)
- 11. A New Operational Model (Op-Model)
- 12. A New Operational Model (Op-Model)
- 13. A New Operational Model (Op-Model)
- 17. SafeStat vs SMS Today’s Measurement System: SafeStat CSA 2010 SMS Organized by four broad categories - Safety Evaluation Areas (SEAs): Accident, Driver, Vehicle, and Safety Management Organized by seven specific BASICs Identifies carrier for a compliance review (CR) Identifies safety problems to determine whom to investigate and where to focus the investigation Uses only out-of-service (OOS) and moving violations from roadside inspections. Uses all safety-based roadside inspection violations No impact on safety rating Used to propose adverse safety fitness determination based on carriers’ current on-road safety performance (future) Violations are not weighted based on relationship to crash risk Violations are weighted based on relationship to crash risk Assesses carriers only Assesses carriers and drivers – the driver SMS is a tool for investigators to identify drivers with safety problems during carrier investigations
- 20. Example of SafeStat vs SMS The following slides provide examples of key differences between SafeStat and the new SMS
- 21. Carrier Measurement: SafeStat Results
- 22. Carrier Measurement: SMS Results
- 23. Violation Details Provided in SMS
- 24. Further Drilldown in SMS
- 33. Current vs CSA 2010 Intervention Process Current CR Process CSA 2010 Intervention Process Broad one-size-fits-all investigation Array of interventions can be tailored to address extent and scope of specific safety deficiencies Resource intensive for enforcement agencies and time consuming for carrier/fewer carriers contacted Less resource intensive for enforcement agencies and less time consuming for carrier/more carriers contacted Focuses on broad compliance based on rigid set of acute/critical violations Focuses on improving behaviors that are linked to crash risk Discovers what violations exist at that time Discovers what safety problem(s) are, why they exist, and how to correct them Major safety problems result in fines (Notice of Claim (NOC)) When problems found, major focus on carrier proving corrective action; significant problems continue to result in fines Focuses on carrier Expands focus to driver violations
- 36. CSA 2010 Test and National Roll-out
- 43. Summary
- 46. For more information, please visit: csa2010.fmcsa.dot.gov
Hinweis der Redaktion
- Why is the U.S. DOT/FMCSA introducing CSA 2010? This graph shows the rate of fatalities, over time, per 100 million vehicle miles travelled. The chart illustrates that the introduction of the agency’s new safety programs over the years have had a positive impact on safety. Because the rate has flattened over the past several years, FMCSA, along with its state partners, is introducing CSA 2010 as a pro-active measure to further reduce the fatality rate, building upon its past success with introducing innovative safety programs
- The leveling fatality rate motivated FMCSA to look carefully at its operational model. The agency found that: While the CR is an effective tool, it is labor intensive. In addition, safety ratings are tied to the labor intensive CR. With more vehicles on the road while enforcement resources remain stable, the need for more efficient tools became clear. FMCSA recognizes that many carriers have good records and effective safety programs and is introducing CSA 2010 as a way to better identify and address unsafe carriers.
- What is CSA 2010 and what are the benefits? The program leverages the use of technology by using safety performance data collected at roadside and through crash reports. It uses that data to identify unsafe carriers and drivers and to pinpoint their safety performance problems. The wider array of tools enables FMCSA and state partners to employ the right tool to address the identified safety problems, resulting in more efficiency for both the agency and the carrier It is better for carriers as less time will be taken from their business and better for FMCSA and state partners as they will be able to reach more carriers. The CR is effective but is not always necessary when the safety problems identified are limited in nature. CSA 2010 takes the best of the CR process, enhances it, and supplements it with other tools to accomplish what’s needed in a less intrusive, more focused fashion (a comprehensive tool , similar to the CR, is still available for use to address the worst performers/highest risk carriers) By alerting carriers early that they are on FMCSA’s radar, the new model provides an opportunity to carriers to fix safety problems before they grow and to get off of the radar quickly without the expense of a CR. Because the data is updated monthly, the new model requires sustained accountability.
- CSA 2010 is a pro-active initiative to improve the efficiency and effectiveness of FMCSA’s enforcement and compliance program. Uses ALL roadside inspection results and crash reports to identify safety deficiencies Employs a wider array of interventions tailored to problems instead of solely the time-intensive Compliance Review process Enables more carriers to be contacted earlier Requires sustained accountability of carriers AND increases accountability of drivers
- This is a diagram of the new operational model once it is fully deployed (post Safety Fitness Determination Rulemaking.) Beginning on the left, the model shows how safety violations from roadside inspections and crash data from crash reports feed into MCMIS (FMCSA’s collection system of data) The raw data is then measured (green Measurement box) and carrier performance is measured in 7 BASIC categories – Behavior Analysis and Safety Improvement Categories (BASICs) as listed in the box. In turn, the measures are used for Safety Evaluation in two ways (green Safety Evaluation box). First, from a policy perspective an evaluation is made to determine intervention selection (see arrows and yellow interventions box). Second, to the right of the traffic lights in the box, the measurements may be used in the future to determine safety fitness (in rulemaking) .
- The three main components of the new approach to CMV safety address HOW we are going to extend our reach beyond the population of carriers we currently address The Safety Measurement System is a new methodology – for OpModel Test States, results are available to industry in the Comprehensive Safety Information (CSI) system. For national roll out in the summer of 2010, results will be available to industry in a more powerful, nation-wide system. The new intervention process provides an array of tools that can be used depending on the specific safety problems of the carrier . This includes an “early warning’ in the form of a warning letter. The proposed approach to Safety Fitness Determination will be in rulemaking in the fall of 2009. The proposed rule ties fitness to current on-road safety performance with a rating not limited to acute/critical regulation violations from a CR.
- In CSA 2010, the focus is on identifying and then changing unsafe behavior with SMS serving as the foundation. SMS measures on-road safety performance of carriers in Behavior Analysis and Safety Improvement Categories SMS enables FMCSA and its state partners to identify high risk carriers and drivers and determine their safety deficiencies more specifically. All safety-based violations found at roadside are taken into account and each violation is assigned a weight based on its relationship to crash risk. SMS organizes violations by unsafe behaviors (BASICs) that can cause crashes FAQs Who will have access to this data? During the OpModel test, only carriers have access to their information. It is expected that for national roll out, level of availability will be similar to that of SafeStat today. Does crash preventability factor into anything? Will the new system improve crash data or will industry be assessed on same data? FMCSA has this on its radar and a team working on the issue. As results come in and decisions are made, information will be updated for industry.
- This slide lists the seven Behavior Analysis Safety Improvement Categories The methodology is designed to weight on-road safety data based on its relationship to crash risk and focuses on behaviors that lead to crash risk. The data is also time-weighted over a 24 month time period so that it is reflective of current on-road safety performance. If a carrier’s performance improves over the time, the safety performance score improves. HM regulation violations (171, 172, 173, 177, 178, 180) may also be found /included in other BASICs such as driver fitness, but the most concentrated BASIC for these is Cargo Related so they are listed there.
- This slide highlights the differences between SafeStat and SMS SMS Applies risk-based weightings to violations in order to identify high crash-risk carriers demonstrating PATTERNS of unsafe behavior roadside SMS Matches poor safety performance with appropriate level of intervention SMS Uses all SAFETY BASED roadside data, allowing more carriers with unsafe behavior to be identified for intervention SMS Includes two new Safety Measurement Systems (SMS) – one for carriers (CSMS) and one for individual CMV drivers (DSMS).
- The Agency has given consideration to individual driver ratings, but this would happen sometime in the future, not as a part of CSA 2010 implementation. In order for the Agency to begin rating drivers new authorities would be required through reauthorization AND rulemaking The next slide will address driver data that will be available to carriers and drivers in the near future
- The results seen in the following slides will likely be displayed differently upon national roll out but substantively , these screens show the comparison of SafeStat to SMS scores as well as information available in DSMS.
- The next four slides show how the Carrier SMS is different from SafeStat The example is based on REAL DATA although the carrier information is blacked out. The Carrier in SafeStat is flying under the radar with no SEA values above 75. The carrier does not have a safety rating as they have not had a compliance review However, moving to the next slide, you will see that the carrier has very different results when measured using current on-road safety performance data provided by SMS.
- This slide shows the carrier who was under the radar is SAFESTAT, is shown under SMS to have a serious safety deficiency related to Driver Fitness; the early identification of the problem is good news for both the carrier and the public The carrier’s rating is worse than 95% of the carriers evaluated in this BASIC in this peer group. The next screen shows the detailed information resulting in that percentile. From a carrier’s perspective, as well as the public’s perspective, identifying this safety problem early and putting actions in place to fix it before a crash occurs, increases safety for everyone, and in the long run saves the carrier money, the government time, and most important, saves lives. Such specific safety deficiencies may not warrant a full CR –but may indicate the need for a focused review which in turn can save carriers time while allowing the agency to effectively correct the specific safety problem
- So why is this carrier’s Driver Fitness score so high? This shows that it has multiple occurrences of no and expired medical certificates violations and drivers lacking the proper qualifications Of the 199 inspections related to drivers, 36 inspections have resulted in a violation of the Driver Fitness BASIC SMS is identifying a pattern of behavior across multiple inspections
- SMS Facilitates Problem Identification The new SMS website allows us to drill down to see further details related to this high driver fitness BASIC. It is clear that various drivers are having the same medical certificate issues, and these reports are coming in on multiple drivers from multiple states… the problem is not limited to one problem driver and indicates a process breakdown that the carrier is now in a position to fix.
- Clear understanding that data collected at the roadside is a critical component of all traffic safety initiatives. For example, CSA 2010, TACT etc… Important Note to bring up: ONLY information on inspection reports get to FMCSA, an inspection has to take place. For example, if a driver receives a speeding ticket but no inspection is performed, that will not show up in the measurement system. So for both the carriers and the enforcement agencies that use this data its importance cannot be underestimated. During the summer of 2008 FMCSA and its state partners working on the Op Model test (FSWG) identified a need to enhance the uniformity and quality of roadside violation data. During discussions the consensus was that the data in its current form is fundamentally sound, valid and useable However, opportunities exist to enhance the quality of data and in turn, improve the integrity of all traffic safety programs.
- The effort to enhance the quality and uniformity of the roadside violation data started at the Fall 2008 CVSA meeting with the creation of an Ad-hoc committee to look at this issue. Currently this committee is managing an Alliance-wide effort to enhance the overall quality and uniformity of the data. The effort has four core components listed on the screen. Consistent documentation of roadside inspection and violation data- Through a FMCSA funded high priority grant, CVSA began work on guidance that will promote and/or mandate the consistent documentation of roadside inspection and violation data. Standardized processes for challenging data- This initiative will provide procedural guidance on the management of the roadside data challenge process through our Data Q’s management system Increased awareness of the high level goals of the inspection program- This component of the roadside data uniformity initiative will focus on the increased importance of the roadside violation data and an understanding of how the data will be used. The goal is to broaden the understanding that every inspection counts and that there is a direct relation between the collection of the data and the end use of the data. Uniform inspection selections system- CVSA is currently facilitating discussions regarding the policies that govern when and how vehicles should be selected for an inspection. The goal is to focus discussions on implementing a valid and consistent vehicle and driver inspection selection process operated within the scope of a jurisdiction’s rules and policies that will promote roadside data uniformity.
- Good quality data has always been a priority for FMCSA and with the implementation of CSA 2010 it continues to be a primary focus. FMCSA has been working with States on complete reporting of large truck and bus crash and inspection data. Over that past several years FMCSA developed a comprehensive data quality program, and implemented several efforts to evaluate and monitor data that are reported, improve data, and correct errors in the data. The DataQs system is an electronic means for filing concerns about Federal and State data Through this system, data concerns are automatically forwarded to the appropriate office for resolution. The system also allows filers to monitor the status of each filing.
- The agency is in the process of developing a DataQs guide. This guidance is intended to act as a best practice for the States in resolving challenges and will help improve consistency and standardize the resolution process. The Guide will include; timeframes for responses, documents required to corroborate challenges are valid, sources available to validate data, recommended ‘due process’ procedures, the appeals process and others. Until the guide is available here are a few tips and suggestions. There are certain types of challenges that are inappropriate. ….. Complete documentation will expedite the resolution of a challenge, therefore be thorough! The review of a challenge is a research effort. Effectively a challenger is going in front of a “judge” and the judge is going to be looking for evidence. The State needs as much corroborating data or support documentation as possible in order to accurately resolve a challenge. Challengers should attach as much “evidence” as possible to refute the data that is displayed in FMCSA’s systems.
- New Interventions Process provides more tools to reach more carriers and influence safety compliance before crashes occur. SMS alerts FMCSA agents when an intervention is needed and recommends the appropriate type based on the safety problems. The focus of the new process is on changing behavior – For example: If a carrier has a particular problem, SIs will now look at WHY that carrier has that problem providing carriers insight and guidance to take corrective action. In the new model, FMCSA works with carriers to take real corrective action, while NOCs continue to be an important part of the process. SIs will use the Safety Management Cycle to walk carriers through their operations and to identify process breakdowns likely to result in safety problems. Safety Improvement Resources (SIRs) are a part of the new model and used to guide carriers in improving their operations.
- This graphic illustrates the Safety Management Cycle that is used to help carriers understand WHY a carrier is having a problem and HOW to fix it. SIs use the Safety Management Cycle to walk carriers through their operations and to identify process breakdowns likely to result in safety problems. Safety Improvement Resources (SIRs) are a part of the new model and used to guide carriers in improving their operations.
- This slide lists the interventions in increasing order of severity. While a progressive process is in place a carrier will enter the process anywhere from WL to on-site comprehensive depending on the nature and severity of the problems. Warning letters are a new intervention, though some states do send PRISM warning letters. The CSA 2010 warning letters are sent to a larger number of carriers, nationwide. This is likely to be some carriers’ first contact with FMCSA enforcement. It is a strong warning that the carrier is now on FMCSA’s radar and must improve its safety practices and results to get off of the radar. If a carrier continues with poor performance, it will be identified for an investigation. Off site investigations are a NEW intervention. They are used when a carrier passes the threshold of certain BASICs but an on-site intervention is not yet dictated. This intervention allows carriers and SIs to work together over the phone and computer to conduct the investigation and provide results. If a carrier doesn’t improve with this intervention, it will be identified for an focused or comprehensive on-site. On-site focused investigations are a NEW intervention. occur at a carrier’s place of business and are focused on specific problems. On-site comprehensive investigations are most similar to CRs. Cooperative Safety Plans are a new intervention. They are voluntary and may be used in conjunction with an NOV. They are NEVER used in lieu of an NOC. If an NOC is required, it is given. NOVs are not a new intervention but have a new focus in CSA 2010. This is the only follow up action that compels a carrier to do a corrective plan. NOCs and OOSs are the same as today’s NOCs and OOSs.
- This slide compares the current CR process with the new CSA 2010 Intervention Process. CSA 2010 provides a set of tools is chosen based on a carrier’s specific safety problems with t he severity of intervention based on safety performance CSA 2010 Intervention includes finding out why a carrier has a specific safety problem and then focuses on facilitating corrective action. The CSA 2010 Intervention Process will continue to use comprehensive on-site investigations for the highest crash-risk carriers FMCSA agents work with the carriers in a systematic way to identify problems and offer solutions, while still serving as a strong enforcement presence.
- It’s important to note that this is a proposed rule and that the success of CSA 2010 is not reliant on this proposed rule. What is really important is that there is a process that is used in the test today (and that will be used upon roll-out) for rating carriers under the existing regulations. The next slide describes the current rating process under CSA 2010.
- Per statutory language, a safety rating can only be issued to a carrier following a Compliance Review; and a Compliance Review is defined as an on-site investigation of a carrier; therefore, a rating can only be issued during an investigation that occurs at the carrier’s place of business. Because the onsite focused review only looks at a few areas of a carrier’s regulatory compliance, only a Conditional or Unsatisfactory rating may be applied based on findings. The Agency cannot provide a Satisfactory rating since it will not have reviewed all areas. As is current policy, a carrier may apply for an administrative request for upgrade and provide evidence of corrective action.
- Below is a history of the Operational Model Field Test Began as 30-month field test in 4 States: Colorado, Georgia, Missouri, New Jersey Randomly divided into control (34,493) and test (34,820) groups ~ 50%/50% Phased implementation of field test: Phase I Startup: Feb-08 to Sept-08 3 BASICS; emphasized off-site investigations; no A/B (high risk) carriers Phase II: Oct-08 to Jun-10 Fully operational – all BASICs, all interventions, and issuing safety ratings Additional speaking points: This program was developed from the ground-up with extensive research and input from field staff conducting the work The Operational Model test allows for real-world execution of the program and serves as a laboratory through which to identify issues and make improvements to the system before it rolls out in the summer of 2010.
- In the Spring of 2009, we added Montana and Minnesota –it’s important to note that the Canadian Provinces of Alberta and Ontario are also a part of the test. Additional states selected based on Good CR programs (state and fed) Willing to accept the challenge Existing strong relationships (HQ and field, fed and state) 2 border states Throughout test, participant states were seeking 100% involvement: additional states were also requesting participation, but we needed to retain our original test design for evaluation purposes. Therefore, 100% in new states 100% offers a clearer picture of what implementation / steady state will be – with respect to efficiency, workforce and workload and integration with national program/ congressional mandates ******************
- Spring 2010 – CSA 2010 Data Review Along with enforcement staff across the country, Motor Carriers will be able to see their safety data arrayed by the BASICs. They will receive guidance around how to improve in each of the BASICs and have an opportunity to work with their drivers and change their operations to improve their safety performance. They will have an opportunity to challenge any potentially erroneous data so that upon the Safety Management System (SMS) rollout, later in the year, enforcement resources will be deployed effectively and efficiently based on an improved data set. Fall/Winter 2010 – National Launch of CSA 2010 will include The new Safety Measurement System (SMS) will replace SafeStat – public will have access and enforcement will use it to identify and prioritize unsafe carriers for interventions SMS’s BASIC values will replaces today’s Safety Evaluation Area (SEA) values at the roadside Warning letters will be sent Nationwide, launching the first component of the new interventions process A step-by-step educational process for enforcement and motor carriers will begin in early 2010 and will include careful introduction of the new investigations (off-site, on-site focused and on-site comprehensive) and the new follow up interventions (comprehensive safety plans, increased use of notices of violation) Intensive, state-by-state, training for enforcement will begin later in 2011, in preparation for implementation of the new interventions process which will replace the one-size-fits all compliance review Upon completion of that training, on a state-by-state basis, the new program will be implemented. At that point, the Agency’s new enforcement program will be in place Nationwide
- In summary… Roadside inspections discover and document violations and provide the basis for intervention and enforcement (as well as capturing good data that can raise a safety score) Interventions attempt to change the unsafe behavior indicated by the violations; data from interventions are also captured on a carrier Proposed SFD linked to continually collected and assessed data collected at roadside inspections, as well as crash reports, and not limited to rating via CR results Less resource intensive options allow for greater number of interventions In conclusion, the greater number of interventions (and eventual SFD) results in the agency reaching more carriers and will lead to increased safety, while decreasing the amount of disruption to carriers who are investigated. This program is good for good carriers; these components help to establish an equal playing field for industry. CSA 2010 is strong on enforcement but more importantly, it’s a program that is designed to save lives and FMCSA is committed to working with drivers and carriers to achieve that goal. CSA 2010 is the next advancement in safety for the commercial motor vehicle industry. FMCSA is gratified that so many drivers, carriers and organizations have supported the development of the program. What we hope is that more people than ever will get home safely as a result.
- Register for a Compass Account to access the various FMCSA websites “ Raise awareness that every inspection counts and every violation counts” –train drivers to get good inspections and remind them to have due diligence with their responsibilities (i.e. pre-trip inspections)