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entitled 'Motor Carrier Safety: The Federal Motor Carrier Safety 
Administration Has Developed a Reasonable Framework for Managing and 
Testing Its Comprehensive Safety Analysis 2010 Initiative' which was 
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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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