Transcript Comprehensive Safety Analysis (CSA) 2010 Re

CSA: A Way to Measure and
Address Commercial Motor
Vehicle Safety
Driver Briefing
December 2012
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Agenda
• What is Compliance, Safety, Accountability
(CSA)?
• CSA’s Results
• CSA’s Three Core Components
• What Does CSA Mean for Drivers?
• Summary
• Safety Measurement System (SMS)
Improvements
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What Is CSA?
• CSA is the Federal Motor Carrier
Safety Administration’s (FMCSA)
enforcement and compliance
program used to achieve the
Agency’s mission to prevent
commercial motor vehicle (CMV)
crashes, fatalities, and injuries.
• CSA was designed, field-tested,
and refined over five years prior
to national launch in December
2010.
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Where It All Started
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CSA Operational Model
Model based on Safety Fitness Determination (SFD) rulemaking
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CSA’s Results
• Violations per roadside inspection are down 8%
• Driver violations per roadside inspection are down 10%
• The SMS has enough performance data to evaluate nearly 40% of
active carriers
– Those carriers are responsible for more than 92% of reported crashes
• As of January 2012, FMCSA sent more than 50,000 warning
letters
– An independent evaluation of the field test showed that most carriers
improved safety compliance after receiving a warning letter or other
intervention
• The website housing the SMS hosted 48 million user sessions in
2012; a 60% increase over the prior year
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CSA’s Three Core Components
1. An SMS that:
– Identifies unsafe carrier and driver behaviors that lead to crashes
– Uses all safety-based roadside inspection violations to assess compliance
with existing regulations
– Includes investigation findings
2. A Safety Interventions process that:
–
–
–
–
Includes an array of interventions
Focuses on specific unsafe behaviors
Identifies causes of safety problems
Defines and requires corrective actions
3. An SFD process that:
– Requires rulemaking, expected to begin in early 2013
– Would be tied to on-the-road safety performance and replace the current
system
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1. The SMS
The SMS is FMCSA’s workload prioritization tool that:
• Uses State-reported crash records, all roadside inspection
safety-based violations, and certain violations found during
inspections to identify carriers for interventions
– Previous system used only out-of-service (OOS) and certain moving
violations
• Uses 24 months of data; recent events are weighted more
heavily than older ones
• Assigns severity weights to violations based on relationship
to crash risk
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1. The SMS (cont.)
The SMS is FMCSA’s workload prioritization tool that:
• Calculates safety performance based on seven BASICs
• Triggers the Safety Interventions process (e.g., warning
letters, investigations)
• Will feed the new SFD process once rulemaking is completed
• Is designed to be continually improved as more information is
available through data and analysis
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The SMS BASICs
BASICs focus on behaviors linked to crash risk
1. Unsafe Driving (Parts 392 & 397)
2. Hours-of-Service (HOS) Compliance
(Parts 392 & 395)
3. Driver Fitness (Parts 383 & 391)
4. Controlled Substances/Alcohol
(Parts 382 & 392)
5. Vehicle Maintenance (Parts 392, 393 & 396)
6. HM Compliance
(Federal Motor Carrier Safety Regulations (FMCSRs) Part 397 & HM
Regulations (HMRs) Parts 171, 172, 173, 177, 178, 179, and 180)
7. Crash Indicator
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Driver Information
• All violations count toward a carrier’s percentile rank
– If received while driving for that carrier
• Only violations within the control of the driver (as
deemed by the Agency) count toward a driver’s safety
profile
– For example: speeding, HOS violations, etc.
• Carriers cannot see the historic driver safety profile
– Carriers can only see the violations received while the driver
was employed by the driver’s current company.
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Driver Information (cont.)
• Individual driver safety profiles are used by investigators
during carrier investigations only
– To identify drivers with safety problems
– To prioritize the driver sample during carrier investigations
– To issue Notice of Violations (NOVs)/Notice of Claims (NOCs) to
individual drivers based on this driver investigation as appropriate
• The SMS BASICs are sent to Roadside Inspectors
– Assist in determining the level of inspection
– North American Standard Inspection procedure does not change
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CSA’s Three Core Components
1. The SMS
2. Safety Interventions process
3. SFD process
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2. Safety Interventions Process
The Safety Interventions process addresses the:
• WHAT
Discovering violations and
defining the problem
• WHY
Identifying the cause or
where the processes broke down
• HOW
Determining how to fix it/prevent it by using the Safety
Management Cycle (SMC)
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SMC
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Intervention Tools
• Warning letters
• Investigations
– Offsite Investigations
– Onsite Focused Investigations
– Onsite Comprehensive Investigations
• Follow-on corrective actions
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Cooperative Safety Plan (CSP)
NOV
NOC
Operations OOS Order (OOSO)
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CSA’s Three Core Components
1. The SMS
2. Safety Interventions process
3. SFD process
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3. SFD Process
SFD would:
• Incorporate on-road safety performance via the SMS, which is
updated on a monthly basis
• Continue to include major safety violations found as part of
investigations
• Produce an SFD to determine if a carrier is unfit to operate
Draft rulemaking is currently in review within USDOT
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3. SFD Process
Current Safety Rating Process
CSA incorporates the existing safety rating process and
will continue to do so until SFD goes into effect:
• Drivers are not rated
• Drivers do not face any more suspension risk under
CSA
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What CSA Means to Drivers
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How Does CSA Impact Drivers?
CSA puts an emphasis on drivers:
• All violations found during roadside inspections count toward
carrier and driver safety measurement according to vehicle or
driver violation type
• BASIC information/percentile ranks are sent to Roadside
Inspectors as a tool in the decision of whether to inspect and
what level to inspect a specific CMV
– Roadside Inspectors see carrier information/percentile ranks
– Roadside Inspectors do not see driver measurement information
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Information on Drivers
• The SMS provides investigators with information on individual
drivers to:
– Enable investigators to conduct more effective and efficient
investigations
– Allow for a targeted sampling of drivers for those carriers already
identified for investigations
– Facilitate follow-up for Serious Violations
• Under CSA, individual drivers are not assigned safety ratings
or SFDs
• The SMS has been made available to the public to facilitate
transparency
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Information on Drivers (cont.)
Pre-employment Screening Program (PSP)
• Mandated by Congress and is not a part of CSA
• “Driver Profiles” from FMCSA’s Driver Information
Resource are available to carriers through PSP
• Driver Profiles are only released with driver authorization
and include inspection and crash data
• PSP is currently available; access and additional
information can be found at www.psp.fmcsa.dot.gov
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What Can Drivers Do Now?
• Know and follow safety rules and regulations
– CMV web-based driving tips can be found at
http://www.fmcsa.dot.gov/about/outreach/education/driverTips/index.htm
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What Can Drivers Do?
• Become knowledgeable about the BASICs and how FMCSA evaluates safety
under CSA
– Review the SMS Methodology at http://csa.fmcsa.dot.gov/outreach.aspx
• Advocate for safety among all professional drivers
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What Can Drivers Do? (cont.)
• Spread the word about CSA and encourage fellow drivers to:
– Check the CSA Website for more information and updates at
http://csa.fmcsa.dot.gov
– Maintain copies of inspection reports
– Become knowledgeable about employers’ safety records by checking carrier safety
information online (http://ai.fmcsa.dot.gov/)
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Frequently Asked Questions
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Frequently Asked Questions (FAQs)
• Does CSA give FMCSA the authority to put drivers out of work?
– No. CSA does NOT give the Agency the authority to remove drivers
from their jobs. A change of that magnitude would require
rulemaking and no such effort is underway.
• Does CSA give FMCSA the authority and processes to rate
drivers and revoke their Commercial Driver’s Licenses (CDLs)?
– No. Driver safety profiles are available to investigators, but these
are not used to rate drivers and/or revoke CDLs; State licensing
agencies perform that function.
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FAQs (cont.)
• Do tickets or warnings that drivers receive while operating their
personal vehicles impact the SMS?
– No.
• Does the SMS hold carriers responsible for drivers’ errors, such
as speeding?
– Yes. Carriers are held accountable for drivers’ errors because they
are responsible for the job performance of those who work for
them.
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FAQs (cont.)
• Do carriers and drivers need to register for CSA and fulfill
mandatory training?
– No. CSA is primarily focused on helping FMCSA improve its
enforcement operations. Carriers and drivers do not need to
register for CSA nor is there a mandatory training requirement.
• Is there a way to request a data review of potentially erroneous
or improper violations on carrier and/or driver records?
– Yes. The DataQs program (https://dataqs.fmcsa.dot.gov) allows
carriers and drivers to request a data review of information that
resides in FMCSA databases such as crash and inspection
reports.
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FAQs (cont.)
• Is it considered an inspection every time I talk to an inspector at
a weigh station?
– Not necessarily. Law enforcement perform two types of actions at
the roadside: a screening and an inspection. A screening
evaluates a CMV to determine if that driver and/or vehicle
warrants an inspection. Screening methods may vary by
jurisdiction. A screening does not constitute an inspection and an
inspection report is not generated.
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The SMS Improvements
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The SMS Improvement Process
• The SMS is designed and intended to be continually
improved.
– Better technology, new data, and continuing analysis will provide both
means and opportunity for refinement
• FMCSA has taken a systematic approach to rolling out
improvements.
– Prioritizing and packaging changes at regular intervals
– Providing a preview period for motor carriers prior to implementation
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Schedule of SMS Changes
March 2012
• Motor carriers and enforcement staff previewed the SMS changes
• Preview participants are able to view the carriers’ percentile ranks without the
changes (“normal”/public SMS site) and with the enhancements (preview site)
March 27, 2012 through July 30, 2012
•
Federal Register Docket was open for comments about the SMS Preview
December 2012
• SMS public website was updated with the SMS changes discussed
– Both logged-in users and the general public can see percentile ranks
– Crash Indicator and the HM Compliance BASIC percentile ranks are available to only
logged-in users
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The SMS Changes
1. Strengthened the Vehicle Maintenance BASIC by incorporating
cargo/load securement violations from the Cargo-Related BASIC
2. Changed the Cargo-Related BASIC to the HM Compliance BASIC to
better identify safety problems related to HM
3. Better aligned the SMS with Intermodal Equipment Provider (IEP)
regulations
4. Aligned violations included in the SMS with Commercial Vehicle
Safety Alliance (CVSA) inspection levels by eliminating vehicle
violations derived from driver-only inspections and driver violations
from vehicle-only inspections
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The SMS Changes (cont.)
5. More accurately identifying carriers involved in transporting HM
or passengers
6. Modified the SMS Display to:
–
–
Change terminology (replaced terms Insufficient Data and
Inconclusive) to fact-based definitions
Break out crashes with injuries and crashes with fatalities
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The SMS Changes (cont.)
1. Strengthened the Vehicle Maintenance BASIC by
incorporating cargo/load securement violations from the
Cargo-Related BASIC
• Allows for appropriate workload prioritization while reducing a bias
in the Cargo-Related BASIC whereby flatbed operators were
disproportionately identified for intervention
―This bias was the reason that the Cargo-Related BASIC was not public
•
Analysis showed that moving these violations resulted in more
effective and efficient workload prioritization
•
The Vehicle Maintenance BASIC remains public
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The SMS Changes (cont.)
2. Changed the Cargo-Related BASIC to the HM Compliance
BASIC
• Removed load securement violations so that only HM violations
remained
• Provided a more objective comparison with respect to HM compliance;
consequences of crashes and cargo spills can be greatly exacerbated
when HM are involved
• Enabled enforcement staff to better identify and address HM safety
issues
• FMCSA intends to make the HM Compliance BASIC public; however,
the final decision will be made at the end of the preview period
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The SMS Changes (cont.)
3. Better aligned the SMS with IEP regulations
• Previously, the SMS did not use violations associated with the
condition of an IEP trailer (if it is assigned to an IEP).
•
FMCSA has recently revised IEP logic to properly attribute each
IEP trailer violation to either the IEP or the motor carrier based
on the ability of the driver to find the violation as part of a pretrip inspection.
•
IEP violations assigned to a motor carrier are now used towards
calculating the carrier’s Vehicle Maintenance BASIC.
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The SMS Changes (cont.)
4. Eliminated vehicle violations derived from driver-only
inspections and driver violations from vehicle-only inspections
• The SMS includes Level III (driver-only) inspections in the Vehicle
Maintenance BASIC, only when vehicle violations are noted on the
inspection
• Enforcement and industry have raised concerns that some vehicle
violations fall outside the scope of the inspection and could bias
the BASIC results
• Analysis showed that this concern merited attention, so FMCSA has:
―Removed vehicle violations found during driver-only inspections
―Removed driver violations found during vehicle-only inspections
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The SMS Changes (cont.)
5. More accurately identifying carriers involved in
transporting HM or passengers
These carriers are subject to more stringent thresholds in the SMS
HM Carriers
Passenger Carriers
New definition enables FMCSA to focus
resources on carriers involved in the
majority of placardable HM transport
New definition removes many low-capacity
vehicles (e.g., vans and taxis) that are
generally outside of FMCSA’s authority
• At least 2 HM placardable vehicle
inspections; 1 within the past 12
months
• At least 5% total inspections
indicated as HM placardable vehicle
inspections
• Adds all for-hire carriers with 9-15
passenger capacity vehicles and
private carriers with 16+ capacity
• Removes all carriers with only 1-8
capacity and private carriers with 115 passenger capacity
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The SMS Changes (cont.)
6. Modified the SMS Display to address feedback about
current terminology
• Feedback has indicated that stakeholders find some
current terminology confusing
• FMCSA previewed its effort to modify that terminology by:
―
―
Replacing the terms “Insufficient data” and “Inconclusive” with fact-based
descriptions
Breaking out crashes with fatalities and crashes with injuries
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Additional SMS Changes for December
2012
Based on feedback gathered during the comment period, the
Agency also incorporated additional changes to the SMS in
December:
1. Removed 1 to 5 mph speeding violations
– FMCSA has aligned speeding violations to be consistent with current
speedometer regulations (49 CFR 393.82) that require speedometers
to be accurate within 5 mph.
– Applies to the prior 24 months of data used by the SMS and all SMS
data moving forward.
2. Lowered the severity weight for speeding violations that do not designate
mph range above the speed limit.
– The severity weight was lowered to 1 for violations.
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Additional SMS Changes for December
2012
3. Aligned the severity weight of paper and electronic logbook violations
– FMCSA now equally weights paper and electronic logbook violations in
the SMS for consistency purposes.
4. Changed the name of the Fatigued Driving (HOS) BASIC to the HOS
Compliance BASIC
– This BASIC continues to have a strong association with future crash
risk. This action was taken to reflect that the BASIC includes HOS
recordkeeping requirements that, by themselves, do not necessarily
indicate fatigued driving or driving in excess of allowable hours.
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For more information, visit:
http://csa.fmcsa.dot.gov
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