2.  No new CSA driver regulations  No new CSA vehicle regulations  NO new CSA recordkeeping regulations  Not a system to “throw” 250,000 drivers off the road

3.  It is an enforcement system for: › Tracking, measuring, evaluating, and intervening with motor carriers (replacement for SafeStat) › A new method for rating carriers (will require rulemaking)

4.  All interstate carriers that have a USDOT number (regardless of “type”), including: › For hire (common or contract) › Private › Construction › Utility › Ag exempt › Non-CDL

5.  Designed to more effectively target carriers with problems  Allows FMCSA and States to have more tools to intervene with “potentially unsafe” carriers  Uses all data from the roadside to identify potential problems  Will mean more potential enforcement against poor performing carriers  Recently announced delay in implementation until 2011

6. Today’s Measurement System: SafeStatCSA 2010 SMS Organized by four broad categories - Safety Evaluation Areas (SEAs): Accident, Driver, Vehicle, and Safety Management Organized by seven specific BASICs Identifies carrier for a compliance review (CR)Identifies safety problems to determine whom to investigate and where to focus the investigation Uses only out-of-service (OOS) and moving violations from roadside inspections. Uses all safety-based roadside inspection violations No impact on safety ratingUsed to propose adverse safety fitness determination based on carriers’ current on-road safety performance (future) Violations are not weighted based on relationship to crash risk Violations are weighted based on relationship to crash risk Assesses carriers onlyAssesses carriers and drivers – the driver SMS is a tool for investigators to identify drivers with safety problems during carrier investigations

8.  No change: › Roadside inspections and associated violations › DOT-recordable crash reports › Intervention violations

10. SMS BASICs focus on behaviors linked to crash risk 1. Unsafe Driving (Parts 392 & 397) 2. Fatigued Driving (Hours-of-Service); Parts 392 & 395) 3. Driver Fitness (Parts 383 & 391) 4. Controlled Substances/Alcohol (Parts 382 & 392) 5. Vehicle Maintenance (Parts 393 & 396) 6. Cargo-Related (Parts 392, 393, 397 & HM) 7. Crash Indicator

11.  Unsafe Driving BASIC › Following too close › Speeding › Lane change › Passing and turning › Careless/reckless › RRXing

12.  Unsafe BASIC: › Now uses “utilization factor” in combination with power units during the normalizing process › Peer groups (now called safety event groups) based on number of inspections with Unsafe Driving violation rather than power units › Speeding broken into 4 violations (based on amount over the limit)

13.  Fatigued Driving BASIC › Operating a CMV when fatigued › 11, 14, 60/70 violations › False logs › Logs not current › Form and manner

14.  Driver Fitness BASIC › Multiple license › No license › Class and endorsement violations › Unqualified driver › Lack of training or experience › Under age

15.  Controlled Substances and Alcohol BASIC › Under the influence of drugs or alcohol › Possession of drugs and alcohol in CMV › Consumption of alcohol within 4 hour of duty

16.  Drug and Alcohol BASIC › Now uses relevant (driver) inspections to normalize the data (rather than power units) › Peer groups (now called safety event groups) are based on number of inspections with Drug and Alcohol violations rather than power units

17.  Vehicle Maintenance BASIC › Required lights not working or obscured › Conspicuity marking inadequate › Brake › Tire › Suspension › Steering › Periodic inspection

18.  Cargo-related BASIC › Hazmat (especially securement) › Failure to inspect cargo › Cargo securement

19.  Cargo-Related BASIC › Size and weight removed from scoring, however…

20.  Crash BASIC › DOT recordable crashes (preventability is not a factor, all crashes count) › Severity weighted based on injury or fatality vs. no injury and the release of a hazardous material (cargo)

21.  Crash BASIC › Now uses “utilization factor” in combination with power units during the normalizing process › Peer groups (now called safety event groups) based on number crashes rather than power units › Preventability is not considered, all crashes are scored in the system

22.  All BASICs › Severity weights update in all but Crash BASIC

24.  New intervention thresholds BASICPassengerHazMatProperty Unsafe Driving Fatigued Driving Crash 506065 Driver Fitness Drugs/Alcohol Vehicle Maintenance Cargo-Related 657580

26. Intervention process triggered by: –One or more deficient BASICs, –High crash indicator, or –Complaint or fatal crash. Intervention selection influenced by: –Safety performance, –HM or passenger carrier, and –Intervention history.

27.  No change › FMCSA reinforced that warning letter will be going out to all carriers with a deficient BASIC in December › Interventions fully operational nationwide in 2011

28.  No overall structural changes, CSA still uses: › Data Collection › Safety Measurement Systems (SMS) › Safety Evaluation › Progressive interventions  FMCSA still referring to program as “CSA 2010”  SMS replacing SafeStat and intervention rollout timeline stayed the same (begins November/December 2011)  Rulemaking related to new audit and rating process set for release Spring 2011

29. More Carriers will fall into the Marginal and Unfit Categories More Carriers will have some type of Interventions Drivers will receive more scrutiny Companies will need to carefully screen new drivers Greater need for “good” data/ “clean” inspections

30.  Educate Yourselves and Your Employees: › Understand the SMS Methodology and the BASICs › Check the website for information and updates (http://csa2010.fmcsa.dot.gov)http://csa2010.fmcsa.dot.gov › Raise awareness that every inspection counts and every violation counts  Ensure compliance › Review inspections and violation history over the past 2 years › Address safety problems now › Educate drivers about how their performance impacts their own driving record and the safety assessment of the carrier  Check and update records › Motor Carrier Census (Form MCS -150) › Routinely monitor and review inspection and crash data › Question potentially incorrect data (DataQs: https://dataqs.fmcsa.dot.gov) https://dataqs.fmcsa.dot.gov

31.  Learn the SMS process, specifically:  Severity weighting (nearly all on-road violations count, but how much?)  Time weighting (time reduces violation and crash values)  BASIC Measure calculation (specifically, which BASICs are helped by good inspections and which can only be helped by stopping violations)

32.  Learn the high severity driver violations and take steps to avoid them:  Jumping an out-of-service order  Reckless driving  Operating a vehicle while ill, fatigued, or under the influence  Texting while driving  Violating hours-of-service limits  False logs  Moving violations  Driver having multiple licenses  Driving a CMV while disqualified

33.  Learn the high severity vehicle violations and take steps to avoid them:  Operating an out-of-service vehicle  Tire defects  Suspension defects  Steering system defects  Required light not operating  Brake defects  Cargo not secured

34.  Learn the high frequency driver violations and take steps to avoid them:  Log violation, general (183,171 severity 2)  Speeding (129,714 severity 1, 4, 5, 7, or 10)  Log not current (129,689 severity 5)  No med certificate in possession (100,257 severity 1)  Non-English speaking driver (72,868 severity 4)  Over 14 hours (66,942 severity 7)  Failure to use seat belt (53,666 severity 7)  Over 11 hours (37,178 severity 7)  False log (36,291 severity 7)  Expired medical certificate (32,697 severity 1)

35.  Learn the high frequency vehicle violations and take steps to avoid them:  Required light inop. (378,730 severity 6)  No or defective light (276,381 severity 6)  Brake hose rubbing (214,504 severity 4)  General maintenance (198,704 severity 2)  Tire under 2/32 (195,456 severity 8)  Oil/grease leak (171,964 severity 3)  Brake out of adjustment (154,749 severity 4)  No periodic/annual inspection (146,539 severity 4)  Extinguisher violation (144,751 severity 2)  No brake lights (106,588 severity 6)

36.  BASIC scores surprisingly poor  Many inaccuracies in SMS reporting  Some states are several months behind in updating SMS data  Managing CSA 2010 (monitoring scores, filing appeals, etc.) very time consuming  Difficult to pinpoint issues to a region or location  Good record-keeping is essential

37.  Most significant regulatory action in over 20 years  Positive results on safety, but burdensome to carriers  New enforcement model impacts all carriers  Maintaining programs that address each BASIC is the key to avoiding interventions, but carriers must also establish programs and dedicate resources to “manage” CSA 2010.

38.  Having visibility into potential issues prior to SMS reporting will provide carriers a significant advantage  Unsafe drivers will create significant liability for carriers  Changes to the scoring methodology, enforcement actions and other program elements should be expected

39. Thank you for joining us!