Compliance, Safety, Accountability - American Bus Association

CSACompliance, Safety, AccountabilityThomas BrayEditor, Transportation ManagementJ. J. Keller & Associates, Inc.

CSA OverviewWho is tracked?All interstate carriers that have a USDOT number(regardless of “type”) and their drivers

CSA Overview CSA process: Data collection New Safety Measurement System (SMS) Safety Evaluation (FitnessDetermination) based on SMS Comprehensive and progressiveinterventionsItalicized are areas that have been subject to change as theprogram has developedHowever, no structural changes have been made

CSA Data Data collection All crash data Roadside inspection data Intervention data

CSA SMS SMS: Uses seven “BASICs” (Behavior Analysis andSafety Improvement Categories) to analyzecarriers Measures safety performance using all roadsideinspection safety-based violations and allviolations discovered during interventions Weights based time and severity of violations(based on relationship to crash risk)

CSA SMS Seven BASICs Unsafe Driving (Parts 392, 397, etc.) Fatigued Driving (Parts 392 and 395) Driver Fitness (Parts 383 and 391) Controlled Substances/Alcohol (Part 382 and 392) Vehicle Maintenance (Parts 392, 393, and 396) Cargo Related (Parts 392, 393 Subpart I, and HMregulations) Crash Indicator

CSA SMSBASIC SMS process: Carriers are measured and then comparedin each BASIC Results of comparison is the “score”

CSA BASIC MeasurementEvents are first severity weighted Violations 1 to 10 (+2 if OOS*) *Applicable in Fatigued Driving, Driver Fitness, VehicleMaintenance, and Cargo-Related BASICs Accidents 1 to 3Events are then time weighted 0 to 6 months = 3 6 to 12 months = 2 12 + months = 1

CSA BASIC Measurement Safeties built in: Maximum of 30 severity points in a BASICfrom one inspection Stacking provision Data sufficiency requirements

CSA BASIC Measurement BASIC Measure process Event values in each BASIC are totaled “BASIC Measure” determined by dividing totalevent values by “normalizing factor” Unsafe Driving, Controlled Substance, and CrashBASICs: Number of power units x Utilization factor Fatigued Driving and Driver Fitness BASICs: Totalof all time weighted driver inspections Vehicle Maintenance and Cargo Related BASICs:Total of all time weighted vehicle inspections

CSA Evaluation Safety Evaluation/Safety FitnessDetermination (SFD) Below all thresholds: Continue to Operate (nocontact) Over a BASIC threshold: Marginal(progressive interventions) Unfit (correct or cease operations) Presently requires full compliance review

CSA EvaluationsCarrier assigned “Alert” status if over:InterventionThresholdsPassengerCarriersHazMatCarriersPropertyCarriersUnsafe DrivingFatiguedDrivingCrashDriver FitnessDrug andAlcoholVehicle Maint.Cargo Related50 60 6565 75 80

CSA Evaluation Intervention scoring: Based on violations of regulations discoveredduring audits and investigations Will not “improve” BASIC Score, but can “flip”a BASIC to “Alert” status

CSA Interventions Interventions Warning letter Targeted roadside enforcement (ISS-D) Focused off-site investigation Focused on-site investigation Comprehensive review (compliance review) Cooperative (corrective) safety plan Notice of Violation Notice of Claim/Settlement Agreement

CSA and Drivers Drivers Safety Measurement System (DSMS) inplace Will use same principles as Carrier SMS Data collection (BASICs) Safety evaluation occurs during carrierintervention (not monthly like carriers) Intervention if necessary (NOV and NOC)

CSA Pilot States States presently using full CSA program: The “original” four: Colorado Georgia Missouri New Jersey Added later: Minnesota Montana Kansas Maryland Delaware

CSA Rollout Nationwide rollout: CSA’s SMS has replaced SafeStat as officialcarrier tracking tool Early 2011 — State FMCSA offices bring usinginvestigative interventions as training iscompleted Until trained, Safety Investigators will use the CSASMS to generate “audit list” and use ComplianceReviews as only intervention

Surviving CSALearning the system Learn the SMS process, specifically: Severity weighting (all violations count, but thequestion is “how much!”) Time weighting (time heals all wounds in CSA) BASIC Measure calculation

Surviving CSA View your existing and incoming datathrough the “CSA lens” Existing data can be viewed at: Safety Measurement System (SMS) http://ai.fmcsa.dot.gov/SMS

Surviving CSAGet good data going into the system Good data means “no violation” inspectionsand no preventable crashes Not having a violation keeps the BASIC scoresdown (no “points” coming in, but moreimportantly… No violation inspections directly improve the scorein 5 of the 7 BASICs due to the normalizingprocess

Surviving CSAGet “wrong” data out of the system Learn and be willing to use the appealsprocesses: Federal DataQs (https://dataqs.fmcsa.dot.gov/login.asp) State Motor Carrier Safety Office CVSA Complaint Process

Surviving CSAAvoid inspections conducted due to preexistingviolations (“foolish inspections”): A moving violation Speeding Other traffic violations Operating with a visible violation Lights not working

Surviving CSA Train and track drivers on: CSA Defensive driving Compliance with the safety regulations(hours, qualifications, etc.) Vehicle inspection Roadside inspectionperformance

http://ai.fmcsa.dot.gov/SMS

CSA Questions? Contact info:Thomas Bray800-558-5011 x-2863tbray@jjkeller.com