The document discusses the Comprehensive Safety Analysis 2010 (CSA 2010) program which is an improved approach by the Federal Motor Carrier Safety Administration (FMCSA) to reduce commercial motor vehicle crashes. CSA 2010 introduces a new Safety Measurement System (SMS) to assess carriers' safety performance based on their violations. It also includes a new intervention process and will eventually incorporate a new Safety Fitness Determination. The program is currently being tested and will be rolled out nationally through 2011.
This is a brief explanation of FMCSA’s compliance and enforcement model as it is applied today: SafeStat is the measurement system that collects information from Roadside Inspections and Crash Reports to determine the relative safety of carriers. That measurement score is then used to prioritize which carriers the Agency should go see to look at their business operations. The Compliance Review is the onsite review/investigative procedure that the agency uses to look into the carriers operations. Finally, carriers are issued a Safety Rating of Satisfactory, Marginal or Unsatisfactory based on that Compliance Review
Though FMCSA has been successful in decreasing fatality rates using today’s model, that decrease has leveled over time. At the same time the carrier population has increased and there are now significantly more carriers than Agency resources. Though the CR is an effective tool in determining the safety practices of a carrier, it is labor intensive and therefore, the Agency is only able to reach about 2% of the carrier population annually.
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Talking Points : This program is dependent on roadside inspection data. Data is tied to the motor carrier USDOT number within the data collected on carrier performance is driver information and driver performance. Driver data is collected as well used in driver prioritization during carrier investigations. DRIVERS WILL NOT BE RATED and DRIVERS are at no greater risk of license suspension than they are in the current model that includes CR’s and the use of SAFESTAT for measurement purposes.
This slide gives an overview of the 3 main components of this new operational model: SMS allows the agency the improved ability to identify demonstrated safety problems CSA 2010 employs an array of interventions instead of one single labor-intensive option –the Compliance Review SFD would be tied to current safety performance; not limited to acute/critical violations from a Compliance Review SFD requires rulemaking, not part of initial rollout
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) 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) .
ALL VIOLATIONS FOUND ROADSIDE GO INTO THE CARRIER SAFETY PERFORMANCE ASSESSMENT. ONLY THOSE VIOLATIONS WITHIN THE CONTROL OF THE DRIVER ARE ATTRIBUTED TO HIM/HER Currently, the driver safety performance results are strictly being used as an investigative tool for law enforcement and are not available to carriers, drivers, or the public. Under CSA 2010, FMCSA will not rate or determine the safety fitness of individual CMV drivers beyond what is currently defined in the Federal Motor Carrier Safety Regulations. However, this does not preclude FMCSA from developing a driver rating or safety fitness determination process at some time in the future.
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.
ALL VIOLATIONS FOUND ROADSIDE GO INTO THE CARRIER SAFETY PERFORMANCE ASSESSMENT. ONLY THOSE VIOLATIONS WITHIN THE CONTROL OF THE DRIVER ARE ATTRIBUTED TO HIM/HER
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.
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.
CSA 2010 incorporates the existing safety rating process and will continue to do so until SFD would go into effect Drivers will not be rated Ratings are issued based on investigation findings : On-site comprehensive investigations can result in Satisfactory, Conditional or Unsatisfactory ratings Onsite focused investigations can result in Conditional or Unsatisfactory Ratings Offsite investigations do not result in a rating Carriers can request an administrative review of its safety rating(§385.17) More language if needed: 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.
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