Motor Carrier Safety
The Federal Motor Carrier Safety Administration Has Developed a Reasonable Framework for Managing and Testing Its Comprehensive Safety Analysis 2010 Initiative Gao ID: GAO-08-242R December 20, 2007About 5,500 people die each year as a result of crashes involving large commercial trucks or buses, and about 160,000 more are injured. While the fatality rate for these crashes has generally decreased over the last 20 years, the decline has leveled off in the most recent years. The Federal Motor Carrier Safety Administration (FMCSA) within the U.S. Department of Transportation shoulders the primary federal responsibility for reducing these crashes, fatalities, and injuries and recognizes the need to make improvements if it is to achieve further substantial safety advancements. A key FMCSA effort to improve motor carrier safety is implementing the agency's Comprehensive Safety Analysis 2010 (CSA 2010) initiative. Through CSA 2010, FMCSA expects to reduce motor carrier crashes, fatalities, and injuries by using better ways to identify unsafe carriers and drivers; assessing a larger portion of the motor carrier industry and holding carriers and drivers accountable for sustained performance by regularly determining their safety fitness; and expanding the range of interventions to be used with carriers and drivers that fail to comply with safety requirements. Congress asked us to conduct a broad assessment of FMCSA's progress in planning and implementing CSA 2010. Because much of the detailed work to develop and implement CSA 2010 remains to be done, our work has focused on how FMCSA has managed its initiative, rather than assessing safety benefits that might arise from it. Specifically, we reviewed: (1) how FMCSA sees CSA 2010 increasing safety, (2) whether FMCSA's overall framework for planning and implementing CSA 2010 is reasonable, and (3) the extent to which the operational test of the CSA 2010 model will inform FMCSA of its ability to fully implement the initiative in 2010.
FMCSA expects that CSA 2010 will provide safety benefits by enabling the agency to (1) increase its reach by assessing whether most motor carriers and drivers are safe and holding them accountable by regularly determining their safety fitness; (2) enhance its investigative and enforcement actions through the greater use of less resource-intensive interventions; and (3) improve its ability to identify safety deficiencies through better use of data. Under CSA 2010, all carriers--and eventually all drivers--with sufficient safety data available will receive a safety rating that is periodically updated. Currently, FMCSA is able to provide safety ratings for relatively few carriers and for no drivers. As described earlier, CSA 2010 will employ a progressive array of interventions that can be tailored to match the severity of the safety problems they are intended to correct. CSA 2010 intends to use new data--such as information from police accident reports about driver-related factors contributing to a crash--and improve existing data sources--by, for example, using its database of licensed commercial drivers to identify all drivers with convictions for unsafe driving practices, as well as the carriers they work for--to enable a more precise assessment of safety problems. CSA 2010 will support evolving and new enforcement and compliance efforts. For example, (1) carriers from Canada and Mexico that operate in the United States under open border agreements will be rated under CSA 2010 in the same way as U.S. carriers; (2) violations found through audits of new entrants--a program that FMCSA is working to strengthen--will be used in the CSA 2010 safety measurement system; and (3) data sources related to drivers' health--such as drivers' confirmed positive test results for controlled substances or alcohol--will be developed to focus attention on driver physical qualifications, a key FMCSA policy area. FMCSA has established a reasonable framework to plan and implement CSA 2010. In its planning efforts to date, it has met three factors associated with successful planning--set a clear project mission, established top leadership support, and developed a detailed plan. As FMCSA transitions from planning to implementing CSA 2010, it has met or is taking steps to meet those factors--such as consulting with affected stakeholders and providing needed technology and expertise to accomplish technical tasks--critical to the project's successful implementation. However, since some aspects of implementation are still being defined, we cannot yet assess FMCSA's efforts to effectively meet the success factors for implementation. For example, FMCSA has provided a range of technical resources to, among other efforts, develop the CSA 2010 operating model, initiate rulemaking, develop training instruments, and configure supporting data and information technology systems. However, certain efforts, such as rulemaking and data and information technology system configuration, will continue as the operational test progresses and may lead to refinement of the CSA 2010 concept. Therefore, an assessment of FMCSA's overall effort cannot be completed until these activities occur over the course of the operational test (from January 2008 through June 2010).
GAO-08-242R, Motor Carrier Safety: The Federal Motor Carrier Safety Administration Has Developed a Reasonable Framework for Managing and Testing Its Comprehensive Safety Analysis 2010 Initiative
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United States Government Accountability Office:
Washington, DC 20548:
December 20, 2007:
The Honorable Frank R. Lautenberg:
Chairman:
The Honorable Gordon H. Smith:
Ranking Member:
Subcommittee on Surface Transportation and Merchant Marine
Infrastructure, Safety, and Security:
Committee on Commerce, Science, and Transportation:
United States Senate:
Subject: Motor Carrier Safety: The Federal Motor Carrier Safety
Administration Has Developed a Reasonable Framework for Managing and
Testing Its Comprehensive Safety Analysis 2010 Initiative:
About 5,500 people die each year as a result of crashes involving large
commercial trucks or buses,[Footnote 1]and about 160,000 more are
injured. While the fatality rate for these crashes has generally
decreased over the last 20 years, the decline has leveled off in the
most recent years. (See fig. 1.) The Federal Motor Carrier Safety
Administration (FMCSA) within the U.S. Department of Transportation
shoulders the primary federal responsibility for reducing these
crashes, fatalities, and injuries and recognizes the need to make
improvements if it is to achieve further substantial safety
advancements. A key FMCSA effort to improve motor carrier safety is
implementing the agency's Comprehensive Safety Analysis 2010 (CSA 2010)
initiative. Through CSA 2010, FMCSA expects to reduce motor carrier
crashes, fatalities, and injuries by using better ways to identify
unsafe carriers and drivers; assessing a larger portion of the motor
carrier industry and holding carriers and drivers accountable for
sustained performance by regularly determining their safety fitness;
and expanding the range of interventions to be used with carriers and
drivers that fail to comply with safety requirements.
Figure 1: Commercial Motor Vehicle Fatality Rate, 1986 to 2005:
[See PDF for image]
This figure is a multiple line graph illustrating the commercial motor
vehicle fatality rate, 1986 to 2005. The vertical axis of the graph
represents fatalities per 100 million vehicle mile traveled. The
horizontal axis of the graph represents years from 1986 to 2005. Lines
depicted the rate for buses and for trucks.
Source: GAO presentation of Department of Transportation data.
Notes: Fewer buses are involved in fatal and nonfatal accidents than
large trucks, but they tend to involve more people.
The latest year for which data were available was 2005.
[End of figure]
While the CSA 2010 initiative began in 2004, much remains to be done
before its implementation in 2010. Until now, FMCSA has developed its
CSA 2010 operational concept into a prototype operational model and
will take a major step toward implementation next month (January 2008)
when it begins to test the CSA 2010 operating model in four states
(Colorado, Georgia, Missouri, and New Jersey).[Footnote 2]
You asked us to conduct a broad assessment of FMCSA's progress in
planning and implementing CSA 2010. Because much of the detailed work
to develop and implement CSA 2010 remains to be done, our work has
focused on how FMCSA has managed its initiative, rather than assessing
safety benefits that might arise from it. Specifically, we reviewed:
* how FMCSA sees CSA 2010 increasing safety;
* whether FMCSA's overall framework for planning and implementing CSA
2010 is reasonable, and;
* the extent to which the operational test of the CSA 2010 model will
inform FMCSA of its ability to fully implement the initiative in 2010.
We briefed your offices on December 7, 2007, and this report transmits
the results of our work. A copy of the briefing is enclosed.
Background:
Currently, FMCSA conducts compliance reviews to determine, through what
it calls safety fitness determinations, whether motor carriers are safe
enough to continue operating. These comprehensive on-site reviews
assess carriers' compliance with safety regulations through interviews
with company officials and reviews of records that pertain to, as
applicable, alcohol and drug testing of drivers, insurance coverage,
crashes, driver qualifications, driver hours of service, vehicle
maintenance and inspections, and transportation of hazardous materials.
While effective, compliance reviews are resource-intensive and allow
only a small percentage of the motor carrier industry to be evaluated-
-each year FMCSA and its state partners are able to conduct compliance
reviews of only about 2 percent of the estimated 724,000 motor carriers
subject to the federal safety and hazardous materials regulations.
[Footnote 3] In addition, because they focus on carriers,
compliance reviews generally do not directly result in compliance
actions against drivers.
Since August 2004, FMCSA has been developing a new approach under its
CSA 2010 initiative to measure safety and compliance, determine safety
fitness, recommend and apply interventions, and track and evaluate
safety improvements for both carriers and individual drivers. CSA 2010
is a data-driven approach to determining safety fitness that is not
contingent on compliance reviews. Under this approach, a measurement
system (computer algorithm) will use safety data inputs to rate the
safety performance of carriers and individual drivers.[Footnote 4]
Currently, FMCSA is focusing its efforts on the carrier component of
CSA 2010 and will turn its attention to the driver component following
the next highway statute reauthorization (the current authorization
expires in 2009), through which, according to FMCSA, it intends to gain
new authority to regulate drivers. Prior to reauthorization, FMCSA
plans to refine its driver measurement system to use it to identify
drivers with safety deficiencies and take enforcement actions, as
allowed under current authority, against them.
To determine carrier safety fitness, FMCSA will use data it
collects[Footnote 5] and intends to collect--pertaining to such things
as roadside inspection violations, accidents,[Footnote 6] drivers'
confirmed positive test results for controlled substances and
alcohol,[Footnote 7] and commercial driver's license
convictions[Footnote 8]--arranged in seven Behavioral Analysis and
Safety Improvement Categories (BASIC) that, according to FMCSA's
analysis of the data, are associated with unsafe performance. (See
table 1.)
Table 1: CSA 2010 BASIC Definitions and Data Sources for Carriers:
BASIC: Driver fitness;
Operational definition: Operation of commercial motor vehicles by
drivers who are unfit to operate them because they lack training,
experience, or medical qualification;
Data sources:
* Roadside inspection violations for failure to have a valid commercial
driver's license;
* Crash reports citing a lack of experience or medical reason as a
cause or contributing factor;
* Compliance review violations for failure to maintain proper driver
qualification files or use of unqualified drivers.
BASIC: Unsafe driving;
Operational definition: Dangerous or careless operation of commercial
motor vehicles;
Data sources:
* Driver traffic violations and convictions for speeding, reckless
driving, improper lane change, inattention, and other unsafe
driving behavior.
BASIC: Fatigued driving;
Operational definition: Driving commercial motor vehicles while
fatigued;
Data sources:
* Hours-of-service violations;
* Crash reports with driver fatigue cited as a contributing factor.
BASIC: Controlled substances and alcohol;
Operational definition: Operation of a commercial motor vehicle while
impaired by or in possession of alcohol, illegal drugs, or any other
substance that renders the driver incapable of safely operating a motor
vehicle;
Data sources:
* Roadside inspection violations involving controlled substances or
alcohol;
* Crash reports citing driver impairment or intoxication as a cause;
* Positive controlled substances or alcohol test results on drivers.
BASIC: Crash/incident experience;
Operational definition: Histories or patterns of high crash
involvement, including frequency and severity;
Data sources:
* Law enforcement crash reports;
* Crashes reported by the carrier that are discovered during on-
site investigations.
BASIC: Vehicle maintenance;
Operational definition: Failure of commercial motor vehicle due to
improper or inadequate maintenance;
Data sources:
* Roadside inspection violation for brakes, lights, and other
mechanical defects;
* Crash reports citing a mechanical failure as a contributing factor;
* Compliance review violations associated with pre-trip inspections,
maintenance records, and repair records.
BASIC: Improper loading/cargo securement;
Operational definition: Shifting loads, spilled or dropped cargo, and
unsafe handling of hazardous materials;
Data sources:
* Roadside inspection violations pertaining to load securement, cargo
retention, and hazardous material handling;
* Crash reports citing shifting loads or spilled/dropped cargo as a
cause or contributing factor.
Source: FMCSA.
Note: Most of the BASICs deal with driver characteristics and behavior.
FMCSA will address these driver behaviors by intervening with carriers
that use unsafe drivers. FMCSA will also use these same BASICs and
underlying data sources to determine the safety fitness of individual
drivers.
[End of table]
The safety measurement system will score carriers in each BASIC and
make a safety fitness determination[Footnote 9] to indicate (1) whether
a carrier should continue to operate, (2) if operational deficiencies
requiring FMCSA intervention exist, or (3) if a carrier should be
suspended from operating.[Footnote 10] (See fig. 2):
Figure 2: CSA 2010 Operating Model for Carriers:
{See PDF for image]
This figure is an illustration for the CSA 2010 Operating Model for
Carriers. The following data is depicted:
Start:
* Crash Reports;
* Driver traffic violations and convictions;
* Hours-of-service violations;
* Controlled substances and alcohol test results;
* Roadside inspection violations.
Safety data is collected from the above items, and sent to:
Safety Measurement System: BASICS:
* Driver fitness;
* Unsafe driving;
* Fatigued driving;
* Controlled substance and alcohol;
* Crash/incident experience;
* Vehicle maintenance;
* Improper loading/cargo securement.
At this point, a Safety Evaluation is performed. Any of the following
three situations can occur:
Safety Evaluation:
Continue to operate;
Return to collection of safety data.
Safety Evaluation:
Unfit;
Unfit suspension;
Suspend operation.
Safety Evaluation:
Marginal/Ongoing intervention;
Interventions:
* Warning letter;
* Targeted roadside inspection;
* Off-site investigation;
* On-site investigation;
* Cooperative safety plan;
* Notice of violation;
* Notice of claim;
* Consent agreement;
Return to collection of safety data.
Sources: FMCSA and GAO.
[End of figure]
When FMCSA finds indications of carrier safety problems through its
analysis of data--the safety measurement system will indicate if a
carrier is deficient in one or more BASICs--it plans to make flexible,
progressive interventions commensurate with both the behavior exhibited
by carriers and any safety intervention history.[Footnote 11] (See
table 2.) While these interventions are not new, FMCSA intends to apply
them in a more systematic manner under CSA 2010. For example, if a
safety measurement shows that a carrier is deficient in the driver
fitness BASIC, the system will automatically generate a warning letter
and, depending on the severity of the problem, may trigger an on-site
investigation, during which an inspector reviews the carrier's driver
qualification files, among other actions, to identify and correct the
deficiency. If these interventions do not remedy the problem, FMCSA may
apply more stringent actions, such as assessing penalties or, in the
worst case, suspending the carrier.
Table 2: Proposed CSA 2010 Carrier Interventions:
Intervention: Warning letter;
Description: The safety measurement system will automatically generate
a warning letter (to a carrier) when it detects that a carrier is
deficient in one or more BASICs. The letter will describe the safety
problem(s), offer suggestions for improvement, and explain how the
carrier may challenge the accuracy of FMCSA's findings.
Intervention: Targeted roadside inspection;
Description: The issuance of a warning letter will prompt inspectors at
permanent and temporary roadside inspection stations to inspect
carriers that are known to have deficiencies in one or more BASICs.
Intervention: Off-site investigation;
Description: Carriers that continue to demonstrate BASIC deficiencies
will be asked to voluntarily submit documents to help FMCSA evaluate
carrier safety management practices, determine the root causes of a
safety problem, and take corrective action. For example, FMCSA may ask
a carrier that is deficient in the controlled substances and alcohol
BASIC for records pertaining to its driver drug testing program. If a
carrier does not comply with FMCSA's request, the agency may intervene
through an on-site investigation.
Intervention: On-site investigation;
Description: Carriers that continue to demonstrate BASIC deficiencies,
that are involved in a fatal crash, or are the subject of a complaint
will undergo a focused on-site investigation so that FMCSA can attempt
to determine the root causes of a safety problem and take corrective
action. In instances of broad or complex safety problems, a carrier
will be subject to a comprehensive on-site investigation similar to
that currently performed during a compliance review.
Intervention: Cooperative safety plan;
Description: Following an off-site or on-site investigation, the
carrier and FMCSA will collaboratively create a safety plan that
addresses the root causes of problems, which the carrier will
voluntarily implement.
Intervention: Notice of violation;
Description: Carriers with regulatory violations that do not warrant
fines and can be immediately corrected will receive a formal notice
that requires a response.
Intervention: Notice of claim;
Description: Carriers with regulatory violations that are severe
and warrant penalties will receive a legal notice.
Intervention: Consent agreement;
Description: To avoid further enforcement proceedings, a carrier may
negotiate an agreement that will address the root causes of a safety
problem and result in a deferral of or reduction in penalties.
Nonregulatory solutions, such as the use of electronic onboard
recorders[A] or collision avoidance systems, may be incorporated into
the agreement.
Intervention: Unfit suspension;
Description: Carriers that do not comply with other interventions will
be prevented from operating. The carrier has the right to due process.
Source: FMCSA.
[A] Electronic onboard recorders are devices used to measure the amount
of time a driver operates a vehicle. Electronic onboard recorders may
be recommended, for example, for carriers that allow their drivers to
operate beyond hours of service limits set by law.
[End of table]
Results in Brief:
FMCSA expects that CSA 2010 will provide safety benefits by enabling
the agency to (1) increase its reach by assessing whether most motor
carriers and drivers are safe and holding them accountable by regularly
determining their safety fitness; (2) enhance its investigative and
enforcement actions through the greater use of less resource-intensive
interventions; and (3) improve its ability to identify safety
deficiencies through better use of data. Under CSA 2010, all carriers-
-and eventually all drivers--with sufficient safety data available will
receive a safety rating that is periodically updated. Currently, FMCSA
is able to provide safety ratings for relatively few carriers and for
no drivers. As described earlier, CSA 2010 will employ a progressive
array of interventions that can be tailored to match the severity of
the safety problems they are intended to correct. CSA 2010 intends to
use new data--such as information from police accident reports about
driver-related factors contributing to a crash--and improve existing
data sources--by, for example, using its database of licensed
commercial drivers to identify all drivers with convictions for unsafe
driving practices, as well as the carriers they work for--to enable a
more precise assessment of safety problems. CSA 2010 will support
evolving and new enforcement and compliance efforts. For example, (1)
carriers from Canada and Mexico that operate in the United States under
open border agreements will be rated under CSA 2010 in the same way as
U.S. carriers; (2) violations found through audits of new
entrants[Footnote 12]--a program that FMCSA is working to strengthen--
will be used in the CSA 2010 safety measurement system; and (3) data
sources related to drivers' health--such as drivers' confirmed positive
test results for controlled substances or alcohol--will be developed to
focus attention on driver physical qualifications, a key FMCSA policy
area.
FMCSA has established a reasonable framework to plan and implement CSA
2010. In its planning efforts to date, it has met three factors
associated with successful planning--set a clear project mission,
established top leadership support, and developed a detailed
plan.[Footnote 13] As FMCSA transitions from planning to implementing
CSA 2010, it has met or is taking steps to meet those factors--such as
consulting with affected stakeholders and providing needed technology
and expertise to accomplish technical tasks--critical to the project's
successful implementation. However, since some aspects of
implementation are still being defined, we cannot yet assess FMCSA's
efforts to effectively meet the success factors for implementation. For
example, FMCSA has provided a range of technical resources to, among
other efforts, develop the CSA 2010 operating model, initiate
rulemaking, develop training instruments, and configure supporting data
and information technology systems. However, certain efforts, such as
rulemaking and data and information technology system configuration,
will continue as the operational test progresses and may lead to
refinement of the CSA 2010 concept. Therefore, an assessment of FMCSA's
overall effort cannot be completed until these activities occur over
the course of the operational test (from January 2008 through June
2010).
The CSA 2010 operational test will inform FMCSA of its ability to
implement the carrier component of its initiative by enabling the real-
time use of the safety measurement system and interventions that
constitute the operating model.[Footnote 14] However, according to
FMCSA, the driver component cannot be fully tested until the agency
receives new authority to regulate individual drivers that the
department intends to seek as part of the next highway statute
reauthorization (the current authorization expires in 2009). FMCSA has
established a reasonable structure for and approach to evaluating the
test. Carriers in the four test states will be divided into test and
control groups (a conventional study method) to enable FMCSA to (1)
assess whether the CSA 2010 approach will yield better safety outcomes
than its current approach and (2) evaluate how resource intensive it is
to use the interventions. To determine whether CSA 2010 provides better
safety outcomes, FMCSA will, for example, compare changes to key safety
indicators--such as violation rates and BASIC scores--experienced by
the test and control groups from the beginning to the end of the test.
To evaluate the approach's effect on resource needs, FMCSA will look to
quantify such factors as (1) the number of people working on
interventions, (2) the number of carriers being contacted, (3) the
types of interventions used, and (4) the number of labor hours each
intervention takes.
Agency Comments and Our Evaluation:
In reviewing a draft of this report, the Department of Transportation
stated that it agreed with its contents. It offered a clarifying
comment, which we incorporated.
Scope and Methodology:
To determine how FMCSA sees CSA 2010 increasing safety, we reviewed
documents and interviewed FMCSA officials to discuss the benefits the
agency expects from its new safety initiative. Additionally, we
reviewed transcripts of recent congressional hearings on FMCSA to
identify (1) concerns about the agency's performance and (2) topical
issues affecting the motor carrier industry in general. We used the
broad findings from our review of the transcripts to assess how, if at
all, CSA 2010 addresses concerns about FMCSA and is affected by topical
industry issues. To assess whether the overall framework for planning
and implementing CSA 2010 is reasonable, we reviewed our work
pertaining to organizational transformation and professional
literature on project management topics. We determined that our review
of FMCSA's effort to plan and implement CSA 2010 fit within the
construct of project management and focused our effort on defining
project management success factors. Once we defined a framework of
project management success factors appropriate to our level of
analysis, we reviewed CSA 2010 project management and planning
documents and interviewed agency officials to determine the extent to
which FMCSA meets the success factors. To determine the extent to which
the operational test will inform FMCSA of its ability to fully
implement CSA 2010, we reviewed operational test planning documents and
held discussions with FMCSA officials to examine which CSA 2010
components will be tested and how the test will be evaluated. We then
applied findings from our review of the testing protocol to discuss the
implications of FMCSA's testing approach to its ability to implement
the initiative. To inform our overall analysis, we talked with a broad
range of stakeholders from industry and safety advocacy groups and
discussed their views on CSA 2010. We conducted our review from April
2007 through December 2007 in accordance with generally accepted
government auditing standards.
As agreed to with your offices, unless you publicly announce the
contents of this report earlier, we plan no further distribution until
30 days from the report date. We will then send copies of this report
to congressional committees and subcommittees with responsibilities for
commercial motor vehicle safety issues, the Secretary of
Transportation, the Administrator of FMCSA, and the Director of Office
of Management and Budget. We will also make copies available to others
upon request. In addition, the report will be available at no charge on
GAO's Web site at [hyperlink, http://www.gao.gov].
Should you or your staff have any questions on matters discussed in
this report, please contact me at (202) 512-2834 or flemings@gao.gov.
Contact points for our Offices of Congressional Relations and Public
Affairs may be found on the last page of this report. Key contributors
to this report were James Ratzenberger, Assistant Director; Michael
Armes; Joanie Lofgren; Denise McCabe; and Walter Vance.
Signed by:
Susan A. Fleming:
Director, Physical Infrastructure Issues:
Enclosures:
[End of correspondence]
Enclosure I:
Briefing for Congressional Staff:
FMCSA Has Developed a Reasonable Framework for Managing and Testing Its
CSA 2010 Initiative:
Results:
Objectives:
CSA 2010 is a key FMCSA initiative to (1) assess whether most carriers
and drivers are safe enough to continue operating and (2) deploy an
expanded range of interventions to address safety problems. The CSA
2010 safety measurement systems score carriers and drivers in seven
Behavioral Analysis and Safety Improvement Categories (BASIC), and
interventions are based on the severity of safety problems.
We reviewed (1) how FMCSA sees CSA 2010 increasing safety, (2) whether
FMCSA‘s overall framework for planning and implementing CSA 2010 is
reasonable, and (3) the extent to which the operational test of the CSA
2010 model will inform FMCSA of its ability to fully implement the
initiative in 2010.
Scope and Methodology:
To carry out our work, we (1) reviewed FMCSA documents, interviewed
agency officials, and reviewed transcripts of congressional hearings
related to FMCSA; (2) reviewed our work on organizational
transformation and professional literature on project management topics
and developed a framework of project management success factors based
on our reviews; and (3) reviewed FMCSA documents and interviewed agency
officials about testing protocols and applied our findings to discuss
implications of FMCSA‘s testing approach to its ability to implement
its initiative. To inform our overall analysis, we talked to a broad
range of stakeholders from industry and safety advocacy groups.
Summary of Results:
FMCSA expects CSA 2010 to provide increased safety benefits.
* Increased reach by rating safety fitness of most carriers and drivers
and holding them accountable for sustained performance through regular
reassessments.
* Enhanced investigative and enforcement ability through greater use of
less resource-intensive interventions.
* Improved ability to identify safety problems through better use of
data.
FMCSA is taking a reasonable approach to planning and implementing CSA
2010.
* Has met success factors related to project planning.
* Has met or is taking steps to meet success factors related to project
implementation; effectiveness of efforts will not be apparent until
implementation progresses further.
Operational test beginning January 2008 will partially inform FMCSA of
its ability to implement CSA 2010.
* Test will assess carrier component (and driver component to a lesser
extent) of CSA 2010.
* FMCSA has established a reasonable structure for and approach to
evaluating the test.
CASA 2010 Operational Concept:
Figure : CSA 2010 Operational Concept:
{See PDF for image]
This figure is an illustration for the CSA 2010 Operational Concept.
The following data is depicted:
Start:
* Crash Reports;
* Driver traffic violations and convictions;
* Hours-of-service violations;
* Controlled substances and alcohol test results;
* Roadside inspection violations.
Safety data is collected from the above items, and sent to:
Safety Measurement System: BASICS:
* Driver fitness;
* Unsafe driving;
* Fatigued driving;
* Controlled substance and alcohol;
* Crash/incident experience;
* Vehicle maintenance;
* Improper loading/cargo securement.
At this point, a Safety Evaluation is performed. Any of the following
three situations can occur:
Safety Evaluation:
Continue to operate;
Return to collection of safety data.
Safety Evaluation:
Unfit;
Unfit suspension;
Suspend operation.
Safety Evaluation:
Marginal/Ongoing intervention;
Interventions:
* Warning letter;
* Targeted roadside inspection;
* Off-site investigation;
* On-site investigation;
* Cooperative safety plan;
* Notice of violation;
* Notice of claim;
* Consent agreement;
Return to collection of safety data.
Sources: FMCSA and GAO.
[End of figure]
CSA 2010 Implementation Schedule:
Date: Completed, as of December 2007;
FMCSA Action:
* Developed prototypes of safety measurement system algorithms for
carriers and drivers.
* Developed operational definitions and policies for using carrier
interventions.[Footnote 15];
* Developed plans to operationally test carrier safety measurement
system and interventions.
Date: January 2008;
FMCSA Action:
* Begin phase 1 of operational test of carrier safety measurement
system and interventions in four states (Colorado, Georgia, Missouri,
and New Jersey); three of seven BASICs and eight of nine interventions
to be tested. [Footnote 16]
Date: June 2008;
FMCSA Action:
* Begin phase 2 of operational test of carrier safety measurement
system and interventions in same four states; all BASICs and 8 of 9
interventions to be tested.
Date: 2008-2010;
FMCSA Action:
* Continue to develop data resources for carrier and driver safety
measurement systems.
* Develop and issue rules to (1) establish use of carrier safety
measurement system in determining safety fitness and (2) enable FMCSA
to collect individual drivers‘ controlled substances and alcohol test
results (in cases of positive test results indicating a driver‘s use of
controlled substances or alcohol).
* Evaluate operational test and report results to agency officials at 6-
month intervals beginning June 2008.
* Propose legislation as part of highway statute reauthorization to
provide FMCSA with new authority to determine safety fitness of and
take interventions affecting individual drivers.
Date: To be determined;
FMCSA Action:
* Train staff in all states on CSA 2010 carrier safety measurement
system and interventions. [Footnote 17]
Date: June 2010:
FMCSA Action:
* Complete operational test of carrier safety measurement system and
interventions.
* Begin deploying CSA 2010 carrier safety measurement system and
interventions to all states. [Footnote 18]
Date: To be determined (post 2010);
FMCSA Action:
* Operationally test and deploy CSA 2010 driver safety measurement
system and interventions in all states.
[End of table]
Expected Safety Benefits:
Benefit: Increased reach by rating the safety fitness of most carriers
and drivers and holding them accountable through regular reassessments;
FMCSA Rationale:
* Safety rating based on performance data, not tied to compliance
review;
- CSA 2010”Most carriers and drivers will receive a safety rating
derived from BASIC scores; [Footnote 19] regular updates intended to
sustain safety performance and promote accountability;
- Current approach” Compliance review needed to make safety rating;
FMCSA conducts compliance reviews and provides safety ratings on
approximately 2% of the estimated 724,000 carriers registered with
FMCSA.
* Carriers from Canada and Mexico will be rated the same way as U.S.
carriers.
* New entrants will be rated, in part, on results of new entrant audits
that FMCSA is planning to strengthen.
Benefit: Enhanced investigative and enforcement ability through greater
use of less resource-intensive interventions. Deploying CSA 2010 may
require changes to FMCSA‘s legislative authority as interventions
supplant compliance reviews. We did not assess the extent to which
these changes may be necessary.
FMCSA Rationale:
* Flexible and progressive interventions will allow tailoring of
investigative and enforcement actions to correct unsafe behavior;
[Footnote 20]
- CSA 2010”Interventions linked to BASIC scores:
* Warning letter automatically sent when threshold exceeded on one or
more BASICs; targeted roadside inspections, used to gain additional
safety data, applied to carriers that received warning letters;
* Off-site investigations used to address administrative discrepancies;
for example, carriers could provide records missing from FMCSA files.
* Focused on-site investigations, which are less resource-intensive
than comprehensive on-site investigations, conducted to address
specific problem identified by BASIC scores;
- Current approach”Compliance review, a resource-intensive action, is
the primary intervention triggered by evaluation of Motor Carrier
Safety Status Measurement System (SafeStat) scores.
* More interventions will be made under CSA 2010.
* Operational test will be used to develop qualitative and quantitative
assessments of interventions to determine, for example;
- whether interventions are clearly enough defined to enable their
consistent application;
- how different BASIC thresholds affect the number of interventions,
or;
- whether FMCSA and state partners will have sufficient resources to
follow up on expected number of interventions.
Benefit: Improved ability to identify safety problems through better
use of data. Data in FMCSA‘s Motor Carrier Management Information
System, which is currently used by SafeStat for rating carrier safety,
will also be used to measure carrier safety under CSA 2010. While we
have previously reported on problems with the quality of FMCSA‘s data,
our current work does not examine the effect of these problems on the
operation of the CSA 2010 model.
FMCSA Rationale:
* Expanded sources and improved quality of data will allow for more
robust safety measurement;
- CSA 2010”Divides data into seven BASICs to enable more precise safety
measurement and targeted interventions. FMCSA plans to:
* use new data on test results for drivers‘ use of controlled
substances and alcohol (contingent on rulemaking) and;
* coordinate with states to (1) more accurately code reported traffic
violations, (2) identify drivers convicted of traffic violations, (3)
capture driver-related factors in crash reports, and (4) conduct more
post-crash inspections;
- Current approach” SafeStat uses data in four categories to identify
high-risk carriers that are prioritized for compliance reviews.
* Will include all violations in making a safety fitness determination,
as recommended by the National Transportation Safety Board.
* Developing data sources related to driver health”obtaining confirmed
positive test results for use of controlled substances and
alcohol”focuses attention on driver physical qualifications, a key
FMCSA policy area.
[End of table]
CSA 2010 Framework:
Successful Projects: We identified a framework of 10 success factors
related to project management;
Overall Assessment: CSA 2010 is transitioning from the planning phase
to the implementing phase(see enc. II).
* FMCSA has met success factors associated with planning phase”setting
clear project mission, establishing top leadership support, and
developing project plan.
* FMCSA has met or is taking steps to meet success factors associated
with implementing phase.
Success Factor: Set a clear project mission that establishes goals and
sets direction;
* Our assessment: FMCSA has met this success factor.
FMCSA Actions:
* Established mission to implement more effective and efficient ways
for FMCSA, its state partners, and industry to reduce commercial motor
vehicle crashes, fatalities, and injuries.
* Established overall goals to (1) assess more carriers and drivers,
(2) apply a wider range of interventions to correct high-risk behavior,
and (3) use improved data to better identify high-risk carriers and
drivers.
* Publicized intent to implement CSA 2010 to motor carrier community.
Success Factor: Establish top leadership support to allocate resources
and delegate authority to project managers.
* Our assessment: FMCSA has met this success factor.
FMCSA Actions:
* Established a dedicated CSA 2010 team to manage planning and
implementation under direction of the Chief Safety Officer, who has
agencywide authority to assign tasks supporting CSA 2010. [Footnote 21]
- For example, in June 2007, the Chief Safety Officer formally tasked
Associate Administrators with 26 actions to support continued
development of CSA 2010.
* Contracted with the Volpe Center to provide technical assistance to
the CSA 2010 team.
* Requested $5.6 million in its fiscal year 2008 budget to support CSA
2010.
Success Factor: Develop a project plan that details actions required
for implementation.
* Our assessment: FMCSA‘s approach to project planning seems
reasonable; new graphic format of plan shows relationships among and
sequencing of tasks better than the format of the earlier master plan.
We assessed FMCSA‘s approach to planning, but not the reasonableness of
FMCSA‘s plan or the likelihood of the agency‘s meeting interim
milestone dates and the June 2010 deployment date.
FMCSA Actions:
* Developed a master plan”organized according to the structure of the
technical subteams that make up the CSA 2010 team”in August 2006
(updated June 2007) as a staff-level working document that details
tasks, start and end dates, and responsible parties.
- June 2007 update shows a longer time period (30 months) for
conducting the operational test and evaluating results than was
depicted in the August 2006 plan (17 months).
- June 2007 update shows deployment of CSA 2010 beginning 5 months
later (June 2010) than was depicted in the August 2006 plan (January
2010).
* Developed a new plan format in October 2007 that graphically
illustrates the schedule.
- Schedule shows intent to conduct 30-month operational test and begin
deployment in June 2010 (same as June 2007 plan update).
- Plan is to be used across the agency to convey schedule for
implementing CSA 2010.
Success Factor: Consult with affected stakeholders.
* Our assessment: FMCSA has met this success factor to this point;
effectiveness of future stakeholder consultation will be evident as CSA
2010 takes its final form prior to implementation.
FMCSA Actions:
* Held public forums to obtain feedback from stakeholders and provide
information on the conceptual direction and progress of CSA 2010.
- Public listening sessions September/October 2004 (6 sessions),
November 2006, and December 2007.
- Motor Carrier Safety Advisory Committee meeting (May 2007). [Footnote
22]
* Participated in industry-sponsored events such as Commercial Vehicle
Safety Alliance workshop (September 2007).
* Included three state officials (from the Colorado State Patrol, South
Carolina State Patrol, and the Missouri Department of Transportation)
on the CSA 2010 team.
* Conducted briefings with transportation officials and industry groups
in states where CSA 2010 will be operationally tested (Colorado,
Georgia, Missouri, and New Jersey).
Success Factor: Select and train members of the project team.
* Our assessment: FMCSA has met this success factor. We assessed
FMCSA‘s effort to develop a project team, but not the qualifications of
the FMCSA staff assigned to the team.
FMCSA Actions:
* Established CSA 2010 team responsible for developing operational
model (new safety measurement systems and interventions), planning
operational test, and coordinating rule and policy changes among other
efforts needed to implement the initiative. [Footnote 23]
- Staffed full-time positions for Program Manager (reports to Chief
Safety Officer), Assistant Program Manager, and Program Assistant.
- Assigned headquarters (3 total), field (10 total), and state partner
(3 total) staff collateral duty (up to 50%) to the team.
- Contracted with Volpe Center and technical consultants for support.
[Footnote 24]
Success Factor: Provide needed technology and expertise to accomplish
technical tasks.
* Our assessment: FMCSA has taken steps to address various technical
requirements; effectiveness of efforts will be seen in results of the
operational test. We did not assess the qualifications of FMCSA‘s or
its consultants‘ personnel or the technical quality of their efforts.
FMCSA Actions:
* Assembled staff with a range of skills and experience”enforcement,
data analysis, information technology, training, legal”to support
technical aspects of CSA 2010 development and implementation.
- Operational model development:
* Enforcement and information technology specialists (supported by
Volpe Center) developed data sources (BASICs) and the computer
algorithm used to measure the safety fitness of carriers and drivers.
* Enforcement and legal specialists developed interventions (for
carriers) and operational definitions for their use.
- Implementation:
* Information technology specialists identified needs and continue to
coordinate with FMCSA‘s Office of Information Technology to ensure
information technology and data systems will be in place to operate CSA
2010.
* Data analysis specialists (supported by technical consultant) are
developing plans for collecting data during the operational test and
making measurements to assess effectiveness of test.
* Legal specialists supported development of rules needed to (1) use
the carrier safety measurement system as a means of determining carrier
safety fitness and (2) obtain confirmed positive test results for
individual drivers‘ use of controlled substances and alcohol.
* Training specialists (supported by technical consultant) are
developing training materials and a plan for training investigators in
the four states where CSA 2010 will be tested.
Success Factor: Sell project to its intended users (FMCSA and the state
investigators who will use CSA 2010 within the scope of their safety
enforcement duties).
* Our assessment: FMCSA has taken initial steps to meet this success
factor; effectiveness of efforts will be seen as CSA 2010 moves closer
to deployment.
FMCSA Actions:
* Developed a change management strategy and action plan that discusses
ways to communicate the reasons for change and outlines steps for
addressing users‘ concerns and possible resistance to change.
* Contracted with a technical consultant to build upon and implement
portions of the change management strategy and action plan; the
consultant will:
- develop communications tools such as poster boards and a one-page
briefing paper,
- maintain an updated CSA 2010 Web site,
- interview internal and external stakeholders, and,
- train FMCSA and state staff on use of CSA 2010. [Footnote 25]
Success Factor: Control project by monitoring and providing timely
feedback.
* Our assessment: FMCSA has met this success factor to this point;
effectiveness of efforts will be determined as the initiative
progresses and control becomes more complex. We assessed FMCSA‘s
framework for monitoring CSA 2010 implementation, but not the
effectiveness of FMCSA‘s monitoring efforts.
FMCSA Actions:
* Senior officials:
- FMCSA Administrator receives briefings and provides feedback at key
decision points.
* A January 2007 briefing resulted in taskings to Associate
Administrators that engaged line staff in supporting implementation.
* A June 2007 briefing resulted in approval to develop new
rules”enabling FMCSA to (1) determine safety fitness of carriers using
new safety measurement concept and (2) collect confirmed positive test
results for individual drivers‘ use of controlled substances and
alcohol”needed to support implementation.
- Chief Safety Officer maintains oversight via biweekly meetings with
CSA 2010 Program Manager.
* CSA 2010 team:
- Periodic meetings enable planning and coordination.
- Assignment of staff to multiple technical subteams enhances cross-
team communication.
Success Factor: Establish a network for and communicate needed
information to key stakeholders.
* Our assessment: FMCSA has met this success factor to this point;
effectiveness of future efforts will be seen as CSA 2010 moves toward
deployment.
FMCSA Actions:
* FMCSA‘s efforts pertaining to this success factor are evident in
elements of those previously discussed:
- consult with affected stakeholders (p. 16),
- sell project to its intended users (p. 18), and,
- control project by monitoring and providing timely feedback (p. 18).
Success Factor: Troubleshoot and manage unexpected problems and
deviations from plan.
* Our assessment: FMCSA has yet to face a significant unexpected
problem; effectiveness of future efforts will be seen as CSA 2010
implementation progresses.
FMCSA Actions:
* FMCSA‘s efforts pertaining to this success factor are evident in
elements of one previously discussed:
- control project by monitoring and providing timely feedback (p. 18).
[End of table]
Testing and Evaluating CSA 2010:
Our Assessment: Use of test and control groups for evaluative purposes
is a conventional practice; FMCSA‘s approach to structuring its
operational test seems reasonable.
Test Components:
* The operational test will enable FMCSA to evaluate the carrier
component of CSA 2010 by assessing:
- whether the CSA 2010 approach will yield better safety outcomes than
FMCSA‘s current approach and,
- how carriers react to and how work of investigators is affected
(qualitatively and quantitatively) by using the interventions.
* The operational test will not evaluate the driver component of CSA
2010 to the same extent as the carrier component.
- Driver measurement system will be used to facilitate driver
enforcement actions where needed.
- Implementation of the driver component is contingent upon new
legislative authority”that FMCSA intends to request as part of the
highway statute reauthorization”for FMCSA to determine fitness of and
make interventions affecting individual drivers.
- FMCSA has not established a schedule for testing and deploying the
driver component.
* CSA 2010 operational model test will divide carriers from four states
into test and control groups of about 37,000 carriers in each group.
- Test group will be subject to CSA 2010 interventions.
- Control group will be subject to existing enforcement interventions.
* Operational test will be conducted over 30 months from January 2008
to June 2010 in two phases.
- Phase I (begins January 2008):
* BASICs: unsafe driving, fatigued driving, vehicle maintenance.
* Interventions to be tested: warning letter, targeted roadside
inspection, off-site investigation, on-site investigation, cooperative
safety plan, notice of violation, notice of claim, consent agreement.
[Footnote 26]
- Phase II (begins July 2008):
* All BASICs.
* Same interventions as Phase I.
* FMCSA will make adjustments to operating model”may decide to use
fewer interventions, for example”as test results dictate and will
proceed with implementation as long as safety benefits can be achieved.
Our Assessment: Overall, FMCSA‘s approach to evaluating CSA 2010 seems
reasonable. We did not assess evaluation measures or methodologies
because they were being developed at the end of our fieldwork.
Test Components:
* Third-party consultant will develop plan to evaluate the operational
test and will assist FMCSA in conducting the evaluation.
- Evaluation reports will be provided at 6-month intervals beginning
June 2008.
* FMCSA is considering several methods to determine CSA 2010 safety
benefits:
- Evaluating whether CSA 2010 safety measurement system is better at
identifying unsafe carriers than current methods (e.g., Does CSA 2010
identify unsafe carriers that would be overlooked under current
approach using SafeStat?).
- Comparing changes to key safety indicators experienced by test and
control groups, for example:
* Violation rate (change from beginning to end of test).
* BASIC scores (change from beginning to end of test).
- Evaluating the effect of individual interventions on safety outcomes.
* FMCSA intends to evaluate CSA 2010‘s effects on carriers and on
investigators‘ work through qualitative and quantitative assessments.
- Qualitative evaluation will consider:
* whether interventions are clearly enough defined to enable their
consistent application,
* how carriers perceive the interventions, and,
* if unexpected obstacles to the application of a new intervention
exist.
- Quantitative evaluation will consider:
* the number of people working on new interventions,
* the number of carriers being contacted, and by which interventions,
and,
* how much time (labor hours) each intervention takes.
[End of table]
[End of enclosure]
Enclosure II:
Project Management Success Factors:
{See PDF for image]
This enclosure is an illustration of a timeline for Project Management
Success Factors.
The timeline depicts movement from planning to implementation along a
period of time as follows:
2004: Initiation;
2008: Operational test;
2010: Deploy;
20XX: Closeout.
The timeline also depicts planning factors and implementation factors.
Factors are shown in logical order, but are not intended to represent
discreet events. In practice, order may vary and steps should be
examined in relation to each other as well as to their individual
effect on the project over its life cycle.
Several factors are a blend of planning and implementation as the
project management moves through the timeline.
Provide network for and communicate information:
2004: planning factor;
2008: blended factor;
Closeout: implementing factor.
Monitor and provide feedback to control project:
2004: planning factor;
2008: blended factor;
Closeout: implementing factor.
Troubleshoot and manage problems:
2004: planning factor;
2008: blended factor;
Closeout: implementing factor.
Planning and implementation factors:
Set clear project mission: planning factor;
Establish top management support: planning factor;
Develop project schedule and plans: planning factor;
Consult with all stakeholders: implementation factor;
Select and train necessary staff for project team: implementation
factor;
Provide expertise to address technical tasks: implementation factor;
Sell project to stakeholders: implementation factor.
Source: FMCSA and GAO adaptation of Dennis P. Sleven and Jeffrey K.
Pinto, Balancing Strategy and Tactics in Project Implementation," Sloan
Management Review (Fall 1987;29.1).
[End of enclosure]
Footnotes:
[1] Large trucks are those with a gross vehicle weight greater than
10,000 pounds. A bus is a motor vehicle that is used to carry more than
eight passengers (including the driver).
[2] The operational concept of CSA 2010 involves using a computer
algorithm to measure safety performance and an expanded set of
interventions to address safety problems. The computer algorithm will
be used during the operational test to identify carriers with safety
problems and to prompt FMCSA interventions. The operational test will
enable FMCSA to determine the impact of CSA 2010 on safety outcomes
(such as effect on violation rates) compared to its current approach to
regulating safety.
[3] According to FMCSA, this is the number of commercial motor carriers
registered in its Motor Carrier Management Information System (MCMIS)
as of September 2007. It includes an unidentified number of carriers
that are registered but are no longer in business.
[4] FMCSA has developed two separate measurement systems--one for
carriers and one for drivers--for use under CSA 2010.
[5] Data for CSA 2010 will primarily be drawn from MCMIS. Our previous
work assessed FMCSA data reliability and discussed problems with the
quality of the crash data reported to FMCSA. See GAO, Motor Carrier
Safety: Federal Safety Agency Identifies Many High-Risk Carriers but
Does Not Assess Maximum Fines as Often as Required by Law, GAO-07-584
(Washington, D.C.: Aug. 28, 2007). Our current work does not examine
the effect of these problems on the operation of the CSA 2010 model.
[6] Police accident reports that are uploaded by states to MCMIS do not
always contain sections to document driver-related factors contributing
to a crash. FMCSA intends to redesign MCMIS and work with states to
support the redesign of police accident reports to allow for the
collection and reporting of driver-related factors contributing to a
crash.
[7] FMCSA intends to collect, contingent upon rulemaking, all confirmed
positive tests for controlled substances and alcohol for commercial
drivers from medical officials via a Web portal and maintain the
information in a national database.
[8] FMCSA can currently access information on commercial driver's
license convictions using its Commercial Driver's License Information
System (CDLIS). However, the CDLIS database cannot be searched to
identify all drivers with a specific commercial driver's license
violation. In other words, CDLIS can be used to query an individual
driver's records, but it cannot produce a list of all drivers who have
been convicted of a specific violation. In conjunction with its CDLIS
modernization effort, FMCSA is developing a method that would allow it
to use conviction data to identify all drivers with unsafe driving
records and the carriers they work for.
[9] FMCSA's ability to determine carrier safety fitness under CSA 2010
is contingent upon completion of rulemaking. FMCSA plans to publish a
notice of proposed rulemaking on this issue by summer 2008 and expects
that the final rule will be in place approximately a year later.
[10] Safety fitness determinations will be affected by the type of
violation a carrier makes. For example, FMCSA will evaluate violations
found through interventions to determine if they are from what the
agency considers areas of essential safety management. If essential
safety management violations are 10 percent or more of records checked,
failure of the corresponding BASIC will result. Additionally, FMCSA has
identified 15 violations that it believes are so fundamental to
ensuring safety, that a carrier making any one of the violations will
be deemed unfit.
[11] Interventions can also be initiated by other means such as a
carrier being the subject of a complaint or involved in a fatal crash.
FMCSA has not yet developed interventions for individual drivers.
According to FMCSA, development of these interventions is contingent
upon it gaining new authority to assess individual drivers' safety
fitness through reauthorization of the highway statute.
[12] Carriers newly registered with the Department of Transportation
are subject to an 18-month safety monitoring period. During this
period--generally between 3 and 6 months after a new registration is
obtained--a carrier will receive a safety audit to determine if it has
the necessary systems in place to ensure basic safety management
controls. Failure to demonstrate basic safety management controls may
result in the revocation of the carrier's new-entrant registration.
[13] We reviewed project management literature and identified 10
factors associated with the successful planning and implementation of
projects. Efforts associated with successful project planning are (1)
setting a clear project mission that establishes goals and sets
direction; (2) establishing top leadership support to allocate
resources and confer authority to project managers; and (3) developing
a project plan that details actions required for implementation.
Efforts associated with successful project implementation are (1)
consulting with affected stakeholders; (2) selecting and training
members of the project team; (3) providing needed technology and
expertise to accomplish technical tasks; (4) selling the project to its
intended users; (5) controlling the project by monitoring and providing
timely feedback; (6) establishing a framework for and communicating
needed information to key stakeholders; and (7) troubleshooting and
managing unexpected problems and deviations from the plan.
[14] The CSA 2010 operational test will take place over 30 months,
beginning in January 2008 and concluding in June 2010. A 30-month test
period is planned to account for the sequential steps of (and time lags
between) identifying a problem, allowing the carrier to take remedial
action, and gathering data over a period of time to see if safety
improvements have been made.
[15] Operational definitions related to phase 2 of the operational test
are scheduled to be completed in March 2008.
[16] See page 20 for details.
[17] FMCSA has yet to define plans for training safety investigators
(FMCSA and state staff) in all states. The results of the operational
test will be used to determine plans for rolling out training to all
states.
[18] Evaluation of the operational test may result in changes to the
CSA 2010 operating model”for example, certain interventions may be
altered or eliminated if the test reveals problems with their
use”however, FMCSA will still deploy CSA 2010 in some form as long as
it expects to achieve safety benefits above its current approach.
[19] Safety ratings are contingent upon sufficient data being available
to determine BASIC scores. Carriers and drivers without sufficient data
will not receive safety ratings. Rating safety fitness of individual
drivers is contingent upon FMCSA‘s obtaining authority through
reauthorization of the highway statute.
[20] Interventions discussed are applicable to carriers. According to
FMCSA, development of driver interventions depends on it receiving
authority to regulate individual drivers through reauthorization of the
highway statute.
[21] The Chief Safety Officer is a senior administration official
reporting directly to the FMCSA Deputy Administrator.
[22] The Motor Carrier Safety Advisory Committee, established in
September 2006, is a group”consisting of up to 20 members representing
the motor carrier industry, safety advocates, and safety enforcement
officials appointed by the FMCSA Administrator”that provides advice and
recommendations to the FMCSA Administrator on motor carrier safety
programs and regulations. The committee is scheduled to conduct public
meetings at least four times per year to address the agenda set by
FMCSA.
[23] Personnel assigned to the CSA 2010 team are staffed to one or more
technical subteams (10 technical subteams were in place as of September
2007) that are responsible for coordinating various aspects of
developing and implementing CSA 2010.
[24] FMCSA has contracted with a technical consultant to assist with
training and change management and plans to contract with a second
technical consultant to support evaluation of the operational test.
[25] Training will initially be provided to FMCSA and state staff in
the four states where CSA 2010 is to be operationally tested.
[26] Currently, FMCSA can suspend a carrier only upon conducting a
compliance review. To suspend carriers under CSA 2010, FMCSA must issue
a rule that defines how safety fitness determinations will be made and
protects carriers‘ due process rights. Because this rule will not be
completed until the operational test is well underway, FMCSA will not
be using this intervention in its test. If a poor-performing carrier in
the test group is unresponsive to interventions, it will be removed
from the test and subjected to a compliance review and related
enforcement actions (including suspension).
[End of section]
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