CSA 2010 Update:
FMCSA’s Challenge: Industry Volume
• Significantly more carriers than federal/state investigators– FMCSA regulates ~725,000 interstate and foreign-
based truck and bus companies
• Compliance Review (CR) is effective, but it is labor intensive– Only able to reach < 2% (~12,000) of total carrier
population annually
FMCSA’s Existing Model
• SafeStat (over 53% of audits due to Safestat)
• Compliance Review Process
• Safety Ratings tied exclusively to Compliance
Review
• Focus is on the motor carrier
FMCSA’s Challenge: CMV-Related Fatalities
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1975
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Fat
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Roadside Insp Program (1984)
CR/ Safety Rating (1986) PRISM SafeStat
On-line (1999)
CSA 2010 Description
• CSA 2010 Operational Model ---– Target unsafe behavior.– Safety fitness tied to data; not CR or only
acute/critical violations.– Broad array of progressive interventions.– Focus is on carriers and drivers. – Leverage new technology, training, and
information.
CSA 2010: Meeting the Challenge
CSA 2010 is pro-active in improving FMCSA’s enforcement efficiencies and protecting lives:
– Extending their reach to more carriers and drivers
– Improving their ability to identify safety problems earlier
Target The Masses
• Studies have shown that when you look at a group of workers that they can broken down for the most part into three groups:
• 20% are self-starters/leaders. These people are already doing things the right way.
• 74% are followers. These people can go either way depending on the person leading.
• 6% are malcontents/non-conformers. These people will challenge authority.
• The key to your safety training success is to target the masses (the 74%). A small percentage change in this target group will have a huge impact on your program’s performance.
CSA 2010: Extending our Reach
CSA 2010 Safety Measurement System (SMS)
• Performance-based for determining motor carrier and driver safety
• Measures safety performance using all roadside inspection safety-based violations– This means not just out of service violations –
but ALL violations listed
• Weights time and severity of violations based on relationship to crash risk
• Calculates safety performance in 7 Behavior Analysis and Safety Improvement Categories (BASICs)
Behavioral Analysis & Safety Improvement Categories
BASICs for Carriers and Drivers
Behaviors That Lead To Crashes1. Unsafe Driving
2. Fatigued Driving
3. Driver Fitness
4. Controlled Substances and Alcohol
5. Vehicle Maintenance
6. Improper Loading/Cargo
7. Crash Indicator
Benefits of CSA 2010’s SMS
Today’s Measurement System CSA 2010 SMS
Organized by broad Safety Evaluation Areas (SEA)
Organized by specific Behavior Analysis Safety Improvement Categories
Identifies carrier for one-size-fits-all compliance review (CR) regardless of area to be improved
Identifies carriers for different level investigations based on specific safety issues
Weighs all Out-of-Service (OOS) and acute/critical violations equally
Uses risk-based weightings to incorporate link to crash causation
Assesses carriers only Assesses carriers and drivers
Uses only OOS and acute/critical violations Uses all roadside data
CSA 2010 Interventions - Carrier
•Warning Letter
•Targeted Roadside Inspection
•Off-Site Investigation
•On-Site Investigation - Focused
•Cooperative Safety Plan
•Notice of Violation
•On-Site Investigation - Comprehensive
•Notice of Claim
•Settlement Agreement
Incr
easi
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Sev
erit
y
CSA 2010 Proposed Operational Model
Benefits of CSA 2010’s Intervention Toolbox
Today’s Model CSA 2010 Interventions
One tool; one-size-fits-all Set of tools to use based on carriers’ safety problems
Broad examination of carrier; audit approach
Investigator can focus on carrier’s specific safety problems
Focuses on broad compliance based on rigid set of acute/critical violations
Focuses on improving behaviors that are linked to crash causation
Very resource intensive Less resource intensive
One size fits all approach regardless of level of safety deficiency
New approach to investigating and contacting carriers
Less carriers contacted More carriers contacted
Discover what safety problem is and issue a fine
Discover why carrier has a safety problem
Benefits of CSA 2010’s Safety Fitness Determination
Today’s Safety Fitness Rating SFD
Based on only critical/acute and vehicle out-of-service violations (OOS)
Uses violations of all safety based regulations
Adverse rating generally only issued with multiple deficiencies
Adverse rating can be issued based on 1 deficient area (stand alone BASICs and fundamental violations)
Only uses vehicle OOS violations found during roadside and acute/critical violations found during compliance review
Uses all violations found on the roadside and violations found during investigations
Issues 3 labels: Unsatisfactory, Conditional, Satisfactory
Issues 3 labels: Unfit, Marginal, Continue to Operate. Gets away from “seal of approval”
Updated only with a compliance review conducted
Updated monthly
CSA 2010 and Compliance Reviews
Question: Does CSA 2010 replace the compliance review, which is effective, with less intensive interventions?
Answer: No.
Under CSA 2010, FMCSA is not replacing the compliance review with less intensive alternatives where the onsite comprehensive review is needed to change unsafe behavior.
Instead, FMCSA is augmenting the CR with other interventions (warning letter, off-site and targeted on-site reviews) to address safety problems early before the carrier is considered a high crash-risk.
CSA 2010 and Enforcement
Question: Is CSA 2010 “light” on enforcement?
Answer: No. Under CSA 2010 FMCSA will still issue Unfit
Determinations, Notices of Claim, and Notices of Violation.
Once the SFD rule is in place, FMCSA can deem a carrier “Unfit” by on-road performance data alone.
It is anticipated that this rule will result in more carriers (5x as many) being placed out-of-service (OOS).
CSA 2010 Status
• Operational Model Design - Completed January 2008
• Operational Model Field Test – Began February 2008; Completion Planned June 2010– Test the validity, efficiency and effectiveness
of CSA 2010– Independent 3rd party evaluation conducted
by University of Michigan’s Transportation Research Institute
– Federal and State Work Group (FSWG)
• CSA 2010 National Implementation – Roll-out being planned for July through December 2010
CSA 2010 Field Test Design
• 30-month field test in 4 States: Colorado, Georgia, Missouri, New Jersey
• Randomly divided into control (34,421) and test (34,033) 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
Next Steps in Field Test
• Additional states– May 2009: Minnesota, Montana, Oregon
• 100% of the State participates in CSA 2010– Offers a more accurate picture of efficiencies, capabilities
and benefits– Tests integration with national program goals and
Congressional mandates– Provides more data to evaluate test including workload and
workforce analyses
Preliminary Field Test Output Phase I & II: Feb ‘08 – Jan’09
Summary Information Test Group Control Group
Number of Carriers in Population 34,168 34,546
Carriers Contacted 2,876 731
Percentage of Population Contacted 8.4% 2.1%
Warning Letters Sent 2,464 441
Roadside Inspections 101,498 106,513
Preliminary Field Test Output Phase II: Oct ‘08 – Jan ‘09
Investigation Type
Test Group
Control Group
Offsite 106 N/ AOnsite Focused 131 N/ AOnsite Comprehensive 40 160Total Completed 277 160
Completed Investigations
Preliminary Field Test OutputPhase II: Oct ‘08 – Jan ‘09
Post-Investigation Corrective Actions Type Test Group Control GroupCooperative Safety Plans (CSP) 106 N/ ANotices of Violation (NOV) 3 N/ ANotices of Claim (NOC) 25 35Total Follow-on Corrective Actions 134 35Corrective Actions As Percentage of Completed Investigations 48.40% 21.90%
Completed Post-Investigation Corrective Actions
Preliminary Field Test OutcomesEffectiveness of Interventions on Unsafe BASIC
Hazmat Carriers Feb - Apr May - Aug Sep - Nov
No. Carriers Deficient in Unsafe Driving BASIC
13 12 11
Total Carriers Intervened Upon in Feb-Mar
13 13 13
Percent 100.0 92.3 84.6
General Carriers Feb - Apr May - Aug Sep - Nov
No. Carriers Deficient in Unsafe Driving BASIC
22 17 11
Total Carriers with intervention in Feb-Mar
25 25 25
Percent 88.0 68.0 44.0
Performance of Test Group Carriers Deficient in Unsafe Driving BASIC After Being Intervened
Upon in Feb-Mar ‘08
Preliminary Field Test OutcomesEffectiveness of Interventions on Fatigue BASIC
Hazmat Carriers Feb - Apr May - Aug Sep - Nov
No. Carriers Deficient in Fatigued Driving BASIC
9 8 5
Total Carriers with intervention in Feb-Mar
10 9 9
Percent 90.0 88.9 55.6
General Carriers Feb - Apr May - Aug Sep - Nov
No. Carriers Deficient in Fatigued Driving BASIC
167 128 99
Total Carriers with intervention in Feb-Mar
178 178 178
Percent 93.8 71.9 55.6
Performance of Test Group Carriers Deficient in Fatigued Driving BASIC After Being Intervened
Upon in Feb-Mar ‘08
Preliminary Field Test Outcomes Program Effectiveness: Control vs. Test
Improvement in Relative Safety Performance of Carriers Exceeding a Phase 1 BASIC
75%
80%
85%
90%
95%
100%
Feb. - April Sept. - Nov
Time Period
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of
Ca
rrie
rs D
efi
cie
nt
in a
t L
ea
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Ph
as
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BA
SIC
Control Test (CSA 2010)
21% Of Test Carriers Compared to 7% of Control Carriers No Longer Deficient.
Preliminary evaluation results indicate that the CSA 2010 process is better at identifying and correcting behaviors leading to crashes:
Field Test: Warning Letter Feedback
FMCSA has received positive results from test group motor carriers.
• ~ 50 percent of carriers have logged onto website to view their performance data
• Received written feedback – Appreciative of notification of safety deficiencies– Advised FMCSA of their implemented corrective
actions
Meeting the Challenge: Summary
• New Safety Measurement System– More comprehensive– Better able to pinpoint specific violations– Better identifies high crash-risk behavior
• New Interventions Toolbox– More efficient/effective enforcement process– Wider range of interventions to compel compliance earlier– Match intervention with level of safety performance
• New Safety Fitness Determination rulemaking – Assess safety performance of larger segment of industry– Based on roadside performance, fundamental violations,
and intervention results
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