FMCSA is developing a new operational model through its Comprehensive Safety Analysis (CSA) 2010 initiative. The goal of CSA 2010 is to develop and implement more effective and efficient ways for FMCSA, its state partners, and industry to reduce commercial motor vehicle crashes, fatalities, and injuries. CSA 2010 will help FMCSA and its state partners contact more carriers and drivers, use improved data to better identify high risk carriers and drivers, and apply a wider range of interventions to correct high risk behavior.

Background

In August 2004, FMCSA embarked on CSA 2010 - a comprehensive review and analysis of FMCSA's current commercial motor vehicle safety compliance and enforcement programs. The goal of CSA 2010 is the development and deployment of a new operational model - a new approach to using FMCSA resources to identify drivers and operators that pose safety problems and to intervene to address those problems. FMCSA understands how important it is to the success of this initiative to obtain active and timely feedback from its partners and stakeholders. The Agency held a series of public listening sessions on CSA 2010 in September and October of 2004. These sessions were designed to collect public input regarding ways FMCSA could improve its process of monitoring and assessing the safety performance of the commercial motor carrier industry. Participants were a cross section of individuals including industry executives, truck and bus drivers, insurance and safety advocacy groups, State and local government officials, and enforcement professionals. FMCSA was encouraged that the majority of participants supported the Agency's goal of improving the current process through the CSA 2010 initiative.

During the 2004 listening sessions, the stakeholder community expressed many different opinions regarding the various entities, activities, and environmental factors that contribute to safety. The sessions highlighted that safety indicators can be difficult to identify and measure. Participants also commented on the effectiveness of current processes and offered creative ideas for FMCSA to consider when crafting new policies and processes. For example, in almost every listening session, participants suggested using incentives rather than penalties to encourage safe behavior. Participants expressed a strong interest in comprehensive, consistent, relevant, and accurate data that are easily accessible to all. Some participants expressed a willingness to self-disclose data and to help keep safety data current. For further detail on the public listening sessions, visit FMCSA's Web site at www.fmcsa.dot.gov/safety-security/csalisteningsessions.htm and see the final report, Comprehensive Safety Analysis 2010 Listening Sessions.

Limitations of the Current Operational Model

FMCSA's compliance and safety programs improve and promote safety performance. However, despite increases in the regulated population, as well as increased programmatic responsibilities, Agency resources available for these efforts have remained relatively constant over time. In its present structure, FMCSA's compliance review (CR) program is resource-intensive and reaches only a small percentage of motor carriers. Onsite CRs take one safety investigator an average of 3 to 4 days to complete, and thereby determine a motor carrier's safety fitness. At present staffing levels FMCSA can perform CRs on only a small portion of the 700,000 active interstate motor carriers. These factors have made it increasingly difficult to make sustained improvements to motor carrier safety using existing programs and information systems.

In addition, the FMCSA Large Truck Crash Causation Study clearly indicates that increased attention should be given to drivers. Although FMCSA determines, to a limited extent, the compliance and safety performance of commercial motor vehicle drivers and pursues enforcement against them if warranted, current FMCSA systems do not evaluate the safety fitness of individual commercial motor vehicle drivers.

For these reasons FMCSA is exploring ways through CSA 2010 to improve its current processes for monitoring and assessing the safety performance of motor carriers and drivers.

New Operational Model

The goal of CSA 2010 is to develop a new approach to assessing the motor carrier safety performance of a larger segment of the motor carrier industry, while optimizing the use of Agency resources. CSA 2010 is designed to help FMCSA affect a larger number of motor carriers and drivers using a broader array of compliance interventions. In conceptualizing a new operational model, FMCSA began with a list of ideal attributes and components that it believes should be part of any model for safety oversight:

Flexible—Adaptable to Changing Environment. Accommodate changes to the transportation environment, such as evolutions in technology and changing programmatic responsibilities.

Efficient—Maximize Use of Resources. Produce greater efficiencies by maximizing use of resources to improve Agency productivity, as well as the safety performance of members of the motor carrier community.

Effective—Improve Safety Performance. Increase the quality of contact with the motor carrier community by identifying those behaviors associated with poor safety, and focusing compliance and safety efforts on those unsafe behaviors.

Innovative—Leverage Data and Technology. Improve safety by innovative use of data and technology to leverage its impact. Improve timeliness and accuracy of data used for determining safety fitness, and pursuing enforcement actions against unsafe entities of the motor carrier community. A key factor to the success of this component is the information technology/business transformation project COMPASS. More information on COMPASS is available at www.fmcsa.dot.gov/compass.

Equitable—Fair and Unbiased. Assess and evaluate motor carrier safety and enforce federal laws and safety regulations to ensure consistent treatment of similarly situated members of the motor carrier community.

The conceptual operational model for CSA 2010 shown above would measure safety performance and compliance, determine safety fitness, recommend interventions, apply interventions, and track and evaluate safety improvements for FMCSA-regulated entities. The model would continuously evaluate and monitor regulated entities' compliance and safety performance. It would be significantly different from the Agency's current operational model in that safety fitness determination made under CSA 2010 would be independent of the compliance review. Instead safety fitness determination would be based on performance data and could lead to a broader array of compliance interventions.

A model of this nature would be composed of four integrated and independent components: (1) Measurement, (2) Safety Fitness Determination, (3) Intervention Selection, and (4) Tracking, Evaluation, and Data Validation. Components are the portions of the operational model in which a distinct action would occur. These four components are represented as diamonds in the operational model diagram shown above. These components would be supported by three data elements that are represented by boxes in the diagram. They are (1) Safety Data, (2) Intervention History, and (3) Entity Characteristics.

This model would automatically categorize data into behavioral areas, examples of which are identified below as Behavioral Analysis and Safety Improvement Categories or BASICs. BASICs would represent behaviors that lead to or increase the consequences of crashes. Rather than relying solely on the results of a compliance review, FMCSA could use motor carrier or driver performance data in the identified behavioral areas to determine safety fitness. Among the BASICs currently under consideration to generate this measure are:

1. Unsafe Driving — Dangerous or careless operation of commercial motor vehicles. Data would include driver traffic violations and convictions for speeding, reckless driving, improper lane change, inattention, and other unsafe driving behavior.
   
   
2. Fatigued Driving — Driving commercial motor vehicles when fatigued. This would be distinguished from incidents where unconsciousness or an inability to react is brought about by the use of alcohol, drugs, or other controlled substances. Data would include (1) hours-of-service violations discovered during a compliance review, focused review, roadside inspection, or post-crash inspection, and (2) crash reports with driver fatigue as a contributing factor.
   
   
3. Driver Fitness — Operation of commercial motor vehicles (CMVs) by drivers who are unfit to operate a CMV due to lack of training, experience, or medical qualification. Data would include (1) inspection violations for failure to have a valid and appropriate commercial driver's license, or medical or training documentation, (2) crash reports citing a lack of experience or medical reason as a cause or contributory factor, and (3) violations from a compliance review or focused review for failure to maintain proper driver qualification files, or use of unqualified drivers.
   
   
4. Controlled Substances and Alcohol — Operation of a CMV while impaired due to alcohol, illegal drugs, and misuse of prescription medications or over-the-counter medications. Data would include (1) roadside violations involving controlled substances or alcohol, (2) crash reports citing driver impairment or intoxication as a cause, (3) positive drug or alcohol test results on drivers, and (4) lack of appropriate testing or other deficiencies in motor carrier controlled substances and alcohol testing programs.
   
   
5. Vehicle Maintenance — CMV failure due to improper or inadequate maintenance. Data would include (1) roadside violations for brakes, lights, and other mechanical defects, (2) crash reports citing a mechanical failure as a contributing factor, or (3) violations from a compliance review or focused review associated with pre-trip inspections, maintenance records, and repair records.
   
   
6. Improper Loading/Cargo Securement — Shifting loads, spilled or dropped cargo, and unsafe handling of hazardous materials. Data would include (1) roadside inspection violations pertaining to load securement, cargo retention, and hazardous material handling, and (2) crash reports citing shifting loads, or spilled/dropped cargo as a cause or contributing factor.
   
   
7. Crash/Incident Experience — Histories or patterns of high crash involvement, including frequency and severity. Data would include law enforcement crash reports and crashes reported by the carrier and discovered during compliance reviews.
   
   

The CSA 2010 operational model would regularly determine the safety fitness of motor carriers and drivers of commercial motor vehicles for which there is sufficient data, and as new data enter the operational model. A compliance review would not be required prior to a safety fitness determination.

The Interventions Component would identify appropriate FMCSA interventions for regulated entities with specific safety problems, depending on the outcomes of the Safety Fitness Determination and Measurement Components. An intervention, as used in this context, refers to any action FMCSA would take to correct unsafe behavior and achieve safety compliance. The Interventions Component would not necessarily rely on a compliance review to determine appropriate interventions. It would be designed as a tool to support correction of unsafe behavior. Once it has been determined that an intervention is necessary, an intervention would be selected to effectively and efficiently remediate the unsafe behavior. Interventions would be selected according to the scores from the Measurement and Safety Fitness Determination components, and the Entity Characteristics and Interventions History Data Elements.

Given the data-dependent nature of the CSA 2010 model under consideration, data validation would be essential. As FMCSA deploys its IT modernization project, COMPASS, robust data validation systems and techniques would be employed to ensure the accuracy and completeness of data. The Tracking, Evaluation, and Data Validation Component would support the three other components: Measurement, Safety Fitness Determination, and Intervention Selection. The information systems supporting CSA 2010 would track regulated entities and would associate them with the relevant data collected by FMCSA. FMCSA is working to replace existing paperwork tracking systems with automated data collection systems so that safety fitness determinations are made with the most current data available.

FMCSA is targeting full deployment of CSA 2010 by calendar year 2010, subject to budgetary constraints. The following timeline provides the major milestone dates that are planned prior to targeted deployment:

¹ Prototype refers to testing in a laboratory environment, whereas pilot refers to actual testing with state partners.