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United States Government Accountability Office: 

Report to Congressional Committees: 

September 2011: 

Motor Carrier Safety: 

More Assessment and Transparency Could Enhance Benefits of New 
Oversight Program: 


GAO Highlights: 

Highlights of GAO-11-858, a report to congressional committees. 

Why GAO Did This Study: 

Over 3,600 people in this country died in 2009 as a result of crashes 
involving large commercial trucks and buses. Until recently the 
Federal Motor Carrier Safety Administration (FMCSA) and its state 
partners tracked the safety of motor carriers—companies that own these 
vehicles—by conducting resource-intensive compliance reviews of a 
small percentage of carriers. In 2004, FMCSA began its Compliance, 
Safety, and Accountability (CSA) program. CSA is intended to identify 
and evaluate carriers and drivers posing high safety risks. FMCSA has 
focused on three key CSA oversight activities to evaluate carriers: a 
new Safety Measurement System (SMS) using more roadside inspection and 
other data to identify at-risk carriers; a wider range of 
“interventions” to reach more at-risk carriers; and using SMS data to 
suspend unfit carriers. FMCSA expected to fully implement CSA by late 
2010. FMCSA also plans to separately use data to rate drivers’ fitness. 

In this report, GAO assessed: (1) the status of the CSA rollout and 
issues that could affect it and (2) CSA’s potential to improve safety. 
GAO reviewed CSA plans and data, visited eight states, and interviewed 
FMCSA, state, and industry officials. 

What GAO Found: 

Close to a year after the anticipated completion date, FMCSA has 
partially implemented two of the three planned CSA carrier oversight 
activities-—the new SMS and an expanded set of interventions-—in all 
states; however, it still cannot use CSA safety ratings to get unsafe 
carriers off the road because it has not completed a rulemaking needed 
to do so. Specifically, 

* FMCSA implemented SMS in 2010, as scheduled, to replace the prior 
system, known as SafeStat. The system allows FMCSA to evaluate, score 
and rank the safety of carriers and identify at-risk carriers needing 
intervention. However, states have had to expend resources to respond 
to carriers that have requested reviews of inspection violations shown 
in the system. 

* FMCSA has implemented most of the expanded array of enforcement 
interventions for at-risk carriers, including issuing warning letters 
and initiating focused reviews of carriers’ safety operations that 
allow FMCSA to reach more at-risk carriers; however, it has delayed 
implementation of two interventions-—Off-site Investigations and 
Cooperative Safety Plans-—because the technology needed to implement 
them will not be completed until at least 2012. 

* FMCSA has not yet begun using SMS data to suspend unfit carriers, 
and is 2 years behind in issuing and completing the rulemaking needed 
to use these data instead of a time-consuming compliance review. FMCSA 
expects to finalize the rulemaking in 2013. 

In addition, FMCSA has had mixed success managing implementation of 
CSA oversight activities thus far. FMCSA performed well in conducting 
outreach to carriers and responding to stakeholder concerns, but 
experienced difficulties in realigning its workforce for CSA and 
adapting staff to CSA’s new safety paradigm. FMCSA has not provided 
comprehensive information to Congress and the public on the risks 
associated with either the delayed carrier intervention activities or 
operational and management issues that arose during implementation and 
its plans to mitigate these risks; thus Congress may lack information 
needed to make decisions about CSA. Moreover, FMCSA has taken initial 
steps to separately measure drivers’ fitness to operate trucks and 
buses by seeking new legislative authority to prohibit unsafe drivers 
from operating in interstate commerce. However, FMCSA has not 
specified time frames for developing this measurement, how it will 
ultimately be used, or whether delaying the implementation will affect 

It is too early to definitively assess the extent to which CSA will 
improve truck and bus safety nationwide. Data from a pilot test 
suggest that SMS and the expanded range of intervention tools provides 
a more effective means of contacting these carriers and addressing 
their safety issues. However, CSA’s success depends on the 
availability of sufficient inspection data for carriers. For example, 
small carriers are less likely to receive enough roadside inspections 
to be scored and ranked in SMS. FMCSA has begun but not finished 
performance measures for CSA and has not yet collected the data needed 
to use them, so the extent that it can show CSA improves safety is 

What GAO Recommends: 

GAO recommends that FMCSA (1) develop a plan to implement driver 
fitness ratings in a reasonable timeframe and (2) regularly report to 
Congress on problems and delays in implementing CSA and plans to 
mitigate risks. FMCSA provided technical comments and agreed to 
consider the recommendations. 

View [hyperlink,] or key 
components. For more information, contact Susan Fleming at (202) 512-
2834 or 

[End of section] 




Some CSA Oversight Activities Are Functional but Others Are 
Indefinitely Delayed, and Implementation Problems Could Compromise the 
Program's Effectiveness: 

CSA has the Potential to Improve Safety by Identifying More At-Risk 
Carriers, but the Program's Full Impact Nationwide Is Unclear: 


Recommendations for Executive Action: 

Agency Comments: 

Appendix I: Objectives, Scope, and Methodology: 

Appendix II: GAO Contact and Staff Acknowledgments: 


Table 1: CSA Data Categories and Sources: 

Table 2: Interventions Available Under CSA: 

Table 3: CSA Carrier Oversight Activities and Their Implementation 
Status and Safety Implications: 

Table 4: Status of CSA's Interventions and Benefits and Limitations: 

Table 5: Data Sufficiency Rates, by BASICs and Carrier Size, Test 

Table 6: Associations Interviewed: 

Table 7: State Partners Interviewed During CVSA Conference: 

Table 8: Criteria for State Selection: 

Table 9: Federal and State Agencies and Organizations Interviewed 
During State Visits: 


Figure 1: Sample SMS Screenshot: 


BASIC: Behavior Analysis and Safety Improvement Categories: 

CSA: Compliance, Safety, and Accountability program: 

CVSA: Commercial Vehicle Safety Alliance: 

DSMS: Driver Safety Measurement System: 

FMCSA: Federal Motor Carrier Safety Administration: 

FRA: Federal Railroad Administration: 

ISS-2010: Inspection Selection System: 

MCMIS: Motor Carrier Management Information System: 

NPRM: Notice of Proposed Rulemaking: 

PSP: Pre-Employment Screening Program: 

PTC: Positive Train Control: 

SMS: Safety Measurement System: 

UMTRI: University of Michigan Transportation Research Institute: 

Volpe: John A. Volpe National Transportation Systems Center: 

[End of section] 

United States Government Accountability Office: 
Washington, DC 20548: 

September 29, 2011: 

Congressional Committees: 

Large commercial trucks and buses are vital for the movement of goods 
and people across America.[Footnote 1] However, in 2009, 3,619 people 
died and 93,000 were injured in the United States as a result of 
crashes involving large commercial trucks or buses.[Footnote 2] The 
Federal Motor Carrier Safety Administration (FMCSA), within the U.S. 
Department of Transportation, is the agency charged with reducing 
commercial motor vehicle-related crashes, fatalities, and injuries. To 
carry out this responsibility, FMCSA partners with states to conduct 
roadside inspections. From 1997 through 2010, FMCSA used a program 
known as SafeStat[Footnote 3] to track how well motor carriers--the 
companies that own these commercial vehicles--complied with safety 
standards. SafeStat identified some carriers with poor safety 
performance based mainly on motor carrier crash data, which we have 
found in past reports to have data quality problems.[Footnote 4] Using 
its previous approach, FMCSA was able to review only a small 
percentage of the more than 500,000 motor carriers operating in the 
United States in a given year. At the time, the primary means to 
review these carriers' safety performance was through a detailed 
compliance review.[Footnote 5] In an attempt to increase the number of 
motor carriers that FMCSA can evaluate each year and, ultimately, to 
reduce the number of crashes involving commercial vehicles, FMCSA 
began to develop the Compliance, Safety, and Accountability program 
(CSA) in 2004.[Footnote 6] CSA includes a new system--the Safety 
Measurement System (SMS)--for identifying motor carriers that are at 
risk of causing a crash or safety hazard. FMCSA originally intended to 
fully implement CSA by the end of 2010. 

Officials with FMCSA describe CSA as a fundamental change in measuring 
and addressing motor carrier safety. CSA, for which FMCSA has 
obligated more than $30 million to implement,[Footnote 7] involves new 
processes and information for FMCSA staff, the state-level enforcement 
officials involved in motor carrier inspections, the motor carrier 
companies, and the drivers of commercial motor vehicles. CSA employs a 
new system to use existing carrier safety data collected during 
roadside inspections to measure carrier safety performance and 
introduces new ways of intervening with carriers that have been 
identified to have safety problems. A 2009 Senate Committee report, 
adopted by the conference committee, directed GAO to conduct a study 
as part of the continued monitoring of CSA's implementation.[Footnote 
8] In this report, we assess (1) the status of the CSA rollout and any 
issues that could affect the full and effective implementation of the 
program and (2) CSA's potential to improve safety. In addition, we 
were asked to provide information on CSA's costs. We provided this 
cost information in a separate correspondence in February 2011 
[Footnote 9] and address the rest of the request in this report. 

To address both objectives we focused primarily on FMCSA's oversight 
of large commercial trucks, which are much more prevalent on the 
nation's highways than buses and account for the vast majority of 
accidents involving motor carriers. We reviewed previous GAO reports 
on CSA, FMCSA plans and reports regarding CSA implementation, and CSA 
staffing and budget documents. We interviewed officials from FMCSA, 
the National Transportation Safety Board, and associations 
representing the motor carrier industry. We also visited eight states 
(see app. I for a list) and interviewed and gathered documents from 
FMCSA field staff and state enforcement officials. We selected these 
states based on several criteria including participation in an FMCSA 
operational test of CSA, extent of motor carrier activity, and the 
quality of safety data provided to FMCSA. We also conducted brief 
structured telephone interviews of 55 carriers involved in trucking. 
These carriers were based in the eight states included in our state 
visits and were selected on the basis of fleet size. The carriers were 
not statistically representative of the motor carrier fleet so results 
are not generalizable to all motor carriers. To address the second 
objective, we reviewed and analyzed an evaluation of the CSA 
operational test conducted for FMCSA by the University of Michigan 
Transportation Research Institute (UMTRI) as well as UMTRI and FMCSA 
reports on safety data quality. We also analyzed FMCSA data on motor 
carrier safety. 

We conducted this performance audit from July 2010 through September 
2011 in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objectives. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objectives. Appendix I 
contains more detailed information on our scope and methodology. 


FMCSA and state law enforcement agencies in partnership enforce safety 
standards for the more than 500,000 interstate motor carriers[Footnote 
10] operating in the United States.[Footnote 11] States and, to a 
lesser extent, FMCSA staff, perform roadside inspections[Footnote 12] 
of vehicles to check for driver and maintenance violations and then 
provide the data from those inspections to FMCSA for analysis and 
determinations about a carrier's safety performance. FMCSA also 
obtains data from the reports filed by state and local law enforcement 
officers when investigating commercial motor vehicle accidents or 
regulatory violations. FMCSA provides grants to states that may be 
used to offset the costs of conducting roadside inspections and 
improve the quality of the crash data the states report to FMCSA. In 
addition, FMCSA's field offices in each state, known as divisions, 
have investigators who conduct safety reviews of carriers identified 
by state inspection and other data as unsafe or at risk of being 
unsafe. Most states augment FMCSA investigators' efforts by reviewing 
carrier operations as well. 

Before CSA, FMCSA relied primarily on comprehensive compliance reviews 
on-site at carriers to determine whether they were operating safely. 
[Footnote 13] Carriers were selected for these reviews based on safety 
assessments generated by FMCSA's statistical enforcement model--
SafeStat--that used data obtained from accident reports and other 
safety data supplied by FMCSA's state partners (see table 1). During 
these reviews, an investigator would visit a motor carrier to assess 
compliance with safety regulations by interviewing company officials 
and reviewing records that pertain to alcohol and drug testing of 
drivers, insurance coverage, crashes, driver qualifications, the 
number of hours a driver has worked within a certain time period, 
vehicle maintenance, prior inspections, and transportation of 
hazardous materials. FMCSA officials believe that such comprehensive 
compliance reviews are an effective way to assess a carrier's safety 
performance. However, compliance reviews are extremely resource 
intensive; therefore, only a small percentage of the motor carrier 
industry can be evaluated in this manner, given limited federal and 
state resources. Annually, for example, FMCSA and its state partners 
have conducted compliance reviews of about 3 percent of registered 
motor carriers. As a result, FMCSA was not able to evaluate the vast 
majority of registered motor carriers and most were not assigned a 
safety rating. 

In 2004, FMCSA began to design and develop CSA, a program to better 
target resources toward unsafe carriers, deploy a more comprehensive 
array of interventions, and proactively evaluate safety performance 
based on data, rather than solely based on compliance reviews. Through 
implementation of CSA, FMCSA expects to assess a larger portion of the 
motor carrier industry and to increase the emphasis on driver safety. 
Additionally, FMCSA expects to use data to identify unsafe carriers 
and drivers earlier to address safety problems before crashes occur. 
In this way, FMCSA intends to create a culture of compliance, in which 
officials and carriers will work together to address safety issues 
early, and carriers will have access to information and resources that 
can help them better comply with safety regulations. FMCSA officials 
expect this approach will more efficiently use FMCSA and its state 
partners' resources. FMCSA expects to significantly reach, or "touch," 
more carriers--thus improving their safety--and ultimately reduce 
motor carrier crashes, injuries, and fatalities. 

To date, FMCSA has focused its implementation efforts on carriers-- 
examining the safety performance of the company--whether it be a 
trucking company with hundreds of vehicles or a small company 
operating one or two trucks. FMCSA's implementation efforts also 
include an increased assessment of the safety behavior of the drivers 
for carriers selected for intervention. FMCSA also intends to rate or 
determine the fitness of all drivers, regardless of whether the 
carriers they work for are selected for intervention. The rating would 
cover such things as whether the driver was driving while impaired by 
drugs or alcohol or received tickets for moving vehicle violations. 

SMS--the first oversight activity under CSA--is intended to allow 
FMCSA to more accurately assess a carrier's safety performance. SMS is 
applied to safety data obtained primarily from roadside inspections as 
well as from crash reports. These data are sorted into six Behavior 
Analysis and Safety Improvement Categories (BASIC) that are associated 
with unsafe performance according to FMCSA's analysis. In addition to 
the six BASICs, SMS also incorporates data based on a carrier's crash 
involvement (see table 1). 

Table 1: CSA Data Categories and Sources: 

BASIC/Crash indicator: Crash Indicator; 
Description: Histories or patterns of high crash involvement, 
including frequency and severity[A]; 
Data sources: 
* Law enforcement crash reports; 
* Crashes reported by the carrier that are discovered during on-site 

BASIC/Crash indicator: Controlled Substances and Alcohol; 
Description: Operation of a commercial motor vehicle (CMV) by a driver 
who is impaired due to alcohol, illegal drugs, or misuse of 
prescription or over-the-counter medications, including possession of 
controlled substances or alcohol; 
Data sources: 
* Roadside inspection violations involving controlled substances or 
* Compliance review violations related to alcohol and/or substance 
testing programs and drivers testing positive for alcohol or 
controlled substances. 

BASIC/Crash indicator: Driver Fitness; 
Description: Operation of a CMV by a driver who is unfit to operate it 
due to lack of training, experience, or medical qualification; 
Data sources: 
* Roadside inspection violations for failure to have a valid 
commercial driver's license; 
* Compliance review violations for failure to maintain proper driver 
qualification files or using unqualified drivers. 

BASIC/Crash indicator: Fatigued Driving; 
Description: Operation of a CMV while ill, fatigued, or in 
noncompliance with hours-of-service regulations; 
Data sources: 
* Hours-of-service violations; 
* Compliance review violations related to hours of service 

BASIC/Crash indicator: Cargo-Related; 
Description: Failure to properly prevent shifting loads, spilled or 
dropped cargo, or unsafe handling of hazardous materials on a CMV; 
Data sources: 
* Roadside inspection violations pertaining to load securement, cargo 
retention, and hazardous material handling; 
* Compliance review violations related to loading or transporting 
hazardous material as well as labeling, testing and inspecting cargo 

BASIC/Crash indicator: Unsafe Driving; 
Description: Operation of CMVs in a dangerous or careless manner; 
Data sources: 
* Driver traffic violations including convictions for speeding, 
reckless driving, improper lane change, inattention, and other unsafe 
driving behavior; 
* Compliance review violations related to speeding and safeguarding 
and securing vehicles containing hazardous or explosive materials. 

BASIC/Crash indicator: Vehicle Maintenance; 
Description: Failure to properly maintain a CMV; 
Data sources: 
* Roadside inspection violations for brakes, lights, and other 
mechanical defects; 
* Compliance review violations associated with pre-trip inspections, 
maintenance records, and repair records. 

Source: GAO presentation of FMCSA information. 

[A] SMS evaluates a motor carrier's crash history. Although crash 
history is not specifically a behavior, it can be a consequence of a 
behavior and may indicate a problem with the carrier that warrants 

[End of table] 

Once the data are sorted into the seven data categories, the SMS 
algorithm measures and generates scores for the carrier's safety 
performance in each category. Carriers are placed into peer groups 
(i.e., other carriers with similar numbers of inspections or size) and 
ranked according to performance. The rankings determine which carriers 
are not operating with optimal safety practices and, therefore, will 
be prioritized for intervention. CSA is intended to improve upon 
SafeStat, which measured safety in only four safety evaluation areas: 
driver, vehicle, safety management, and accident (equivalent to the 
SMS Crash Indicator). CSA uses a wider array of safety data to create 
a more nuanced understanding of a carrier's safety performance and 
presents that information using more refined categories. 

FMCSA has made carriers' SMS scores available to carriers themselves 
as well as to the public, including shippers and insurers.[Footnote 
14] Carriers are allowed to request reviews of any data they believe 
are incorrect through an FMCSA system known as DataQs. These requests 
for review can include moving violations reported by state authorities 
that carriers believe are invalid or mistakenly attributed to the 
wrong carrier. FMCSA forwards each request for review to the state in 
which the carrier was cited. States then research the issue, often by 
contacting the inspector who conducted the inspection and his or her 
supervisor. Based on this research, states decide if the violation is 
warranted and make changes if necessary. 

All of these safety data are collected and maintained in FMCSA's 
existing Motor Carrier Management Information System (MCMIS).[Footnote 
15] Our previous work assessed FMCSA data reliability and identified 
problems with the quality of crash data reported to FMCSA, including 
data that were inaccurate, incomplete, and not reported in a timely 
manner.[Footnote 16] FMCSA has been making efforts to improve crash 
data quality, including awarding Safety Data Improvement Program 
grants to states to improve their crash data. States' efforts to 
improve crash data include expanding electronic reporting; improving 
the timeliness, completeness, and accuracy of reporting; and 
standardizing police accident report forms. 

The second oversight activity under CSA is the introduction of a 
variety of interventions for interceding with carriers when their SMS 
scores indicate safety deficiencies. The expanded array of 
interventions available under CSA offers FMCSA more flexibility and 
the opportunity to apply interventions commensurate with a carrier's 
safety performance (see table 2). The new interventions were created 
to get carriers to improve behaviors linked to possible crash risk. As 
a result, these carriers have the opportunity to take corrective 
actions to avoid another intervention in the future. Under CSA, 
interventions that involve investigations follow a process known as 
the Safety Management Cycle which will expand investigations from 
simply identifying what violations occurred to determining why 
violations exist so that FMCSA can offer more constructive improvement 

Table 2: Interventions Available Under CSA: 

Intervention: Warning Letter[A]; 
Description: SMS automatically generates a warning letter to a carrier 
when it detects that a carrier has exceeded a specified threshold in 
one or more BASICs. This 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[A]; 
Description: The Inspection Selection System prompts inspectors at 
permanent and temporary roadside inspection stations to inspect 
carriers that are known to have exceeded thresholds in one or more 

Intervention: Off-site Investigation[A]; 
Description: Carriers that continue to exceed BASIC thresholds will be 
asked to voluntarily submit documents to help FMCSA evaluate carrier 
safety management practices, determine the root causes of the safety 
problem, and take corrective action. For example, FMCSA may ask a 
carrier that exceeds the threshold 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 Focused Investigation[A]; 
Description: Carriers that (1) continue to exceed BASIC thresholds, 
(2) are involved in a fatal crash, or (3) 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 specific safety problem 
and take corrective action. 

Intervention: On-site Comprehensive Investigation; 
Description: In instances of broad or complex safety problems, a 
carrier will be subject to a comprehensive on-site investigation 
similar to those conducted by FMCSA prior to CSA. 

Intervention: Cooperative Safety Plan[A]; 
Description: Following an off-or on-site investigation, the carrier 
and FMCSA will collaboratively create a safety plan that addresses the 
root causes of the problem, which the carrier has the option to 

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. To avoid further intervention, including 
fines, the carrier must provide evidence of corrective action or 
initiate a successful challenge to the violation. 

Intervention: Notice of Claim; 
Description: Carriers with regulatory violations that are severe and 
warrant penalties will receive a legal notification of violation and 

Intervention: Unfit Suspension/Out-of-Service order; 
Description: Carriers that receive a final unsatisfactory rating based 
on an on-site investigation will be prevented from operating. 

Source: FMCSA. 

[A] This intervention is new and is to be implemented as part of CSA. 

[End of table] 

While some of the interventions, such as Notice of Violation and 
Notice of Claim, available under CSA are not new, FMCSA intends to 
apply them in a more systematic manner under CSA. For example, 
according to FMCSA, the agency only issued a handful of Notices of 
Violation over the past 5 years because prior FMCSA information 
technology systems did not provide the capacity to issue and track 
them.[Footnote 17] Under CSA, Notices of Violations can be issued in 
conjunction with Cooperative Safety Plans, giving carriers a framework 
in which to address the violations. In another example, the agency 
intends to increase its use of the Notice of Claim. 

The third oversight activity under CSA is determining a carrier's 
fitness to operate motor vehicles, known as a Safety Fitness 
Determination. FMCSA plans to use SMS scores to make a Safety Fitness 
Determination to indicate whether a carrier should continue to operate 
or should be suspended from operating (i.e., be ordered "out-of- 
service"). Currently, FMCSA determines a carrier's fitness to operate 
based only on the outcome of an onsite comprehensive investigation, 
similar to how it was done under SafeStat.[Footnote 18] If a review 
shows that a motor carrier is unfit to operate pursuant to governing 
regulations, FMCSA can issue an Out-of-Service order that prohibits 
the carrier from operating until the deficiencies are corrected. 
However, as part of CSA, FMCSA plans to initiate a rulemaking that 
will enable it to use SMS-generated scores to determine if carriers 
are unfit to operate.[Footnote 19] FMCSA has not determined if the 
same categories currently used to determine if a carrier is fit to 
operate--"satisfactory," "conditional," and "unsatisfactory"--will be 
used, but it does not plan to increase the number of categories. 

In 2008, FMCSA launched an operational-model test (pilot)[Footnote 20] 
of the CSA program in four states and later expanded the pilot to five 
more states over 30 months through June 2010. During Phase 1, four 
states (Colorado, Georgia, Missouri, and New Jersey) tested CSA on 
carriers with the exception of those with the poorest SafeStat 
ratings.[Footnote 21] Fifty percent of the non-excluded carriers in 
each state were subject to certain aspects of the CSA model-- 
specifically a subset of the BASICs and the interventions--and the 
other 50 percent were subject to SafeStat. During Phase 2, the 
carriers subject to CSA in those four states, including those excluded 
from Phase 1, were then subjected to all of the BASICs and 
interventions. Later, FMCSA added Delaware, Kansas, Maryland, 
Minnesota, and Montana to the pilot testing, with 100 percent of the 
carriers in each state subject to all of the BASICs and interventions. 
UMTRI analyzed the results of Phase 1 of the pilot as well as 
supplementary results from Phase 2 and issued its final report in 
August 2011.[Footnote 22] 

In February 2011, we reported that FMCSA obligated more than $30 
million for costs related to CSA from fiscal years 2007 through 2010. 
[Footnote 23] FMCSA used these funds to develop the SMS and new 
interventions, conduct and evaluate the pilot test, conduct travel and 
training related to CSA, and develop information technology related to 

Some CSA Oversight Activities Are Functional but Others Are 
Indefinitely Delayed, and Implementation Problems Could Compromise the 
Program's Effectiveness: 

Close to a year after the anticipated completion date, FMCSA has 
partially implemented two of the three planned CSA oversight 
activities--the SMS and an expanded set of interventions--in all 
states; however, it still cannot use CSA safety ratings to (1) use CSA 
to assess the fitness of motor carriers or (2) assign safety fitness 
determinations to individual drivers that would prohibit them from 
operating trucks and buses. Although it has been delayed, FMCSA has 
begun to implement the CSA oversight activities directed at carrier 
safety, including SMS and carrier interventions, such as Warning 
Letters and On-site Focused investigations. However, FMCSA has yet to 
issue the Notice of Proposed Rulemaking (NPRM), originally scheduled 
to be finalized in 2009, that would allow it to use CSA data to get 
unsafe carriers off the road. At present, it appears that FMCSA will 
not be issuing the rulemaking until later this year at the earliest. 
Furthermore, in implementing these CSA oversight activities, FMCSA has 
experienced issues that could affect CSA's effectiveness. However, 
FMCSA has not provided comprehensive information to Congress and the 
public on the status of CSA as well as the risks associated with these 
delays and issues, and how it plans to mitigate those risks. Moreover, 
FMCSA has only recently taken steps to separately measure the fitness 
of drivers to operate trucks and buses, as research has shown that 
drivers--not vehicle problems--cause most carrier crashes. FMCSA has 
not specified time frames for developing this component or how it will 
ultimately be used. 

FMCSA Has Fully or Partially Implemented Some Carrier Oversight 
Activities but Operational Issues Could Compromise Effectiveness: 

Although two of CSA's three planned oversight activities for 
evaluating carriers are at least partly implemented and functional to 
varying degrees, implementation remains a work in progress. The first 
CSA oversight activity--developing SMS--was implemented in December 
2010, as scheduled, and is functional (see table 3). For the second 
oversight activity, seven of the nine interventions--five of which are 
new--are generally functioning as intended. Two others--Off-site 
Investigations and Cooperative Safety Plans--have been delayed 
indefinitely because the technology needed to implement them is not 
yet operational. With respect to the third planned oversight activity, 
suspending unfit carriers on the basis of SMS scores, FMCSA originally 
intended to finalize the rulemaking by 2009 but this effort has been 
delayed; FMCSA now plans to issue the Notice of Proposed Rulemaking 
later this year and will not finalize the rulemaking until 2013. 
According to FMCSA officials, they delayed the rulemaking because of 
needed changes to SMS that arose during the pilot. In addition, they 
indicated that FMCSA has a backlog of other key rulemakings that has 
affected its ability to complete the CSA rulemaking.[Footnote 24] 

Table 3: CSA Carrier Oversight Activities and Their Implementation 
Status and Safety Implications: 

CSA carrier oversight activity: SMS; 
FMCSA uses this system to score and rank carriers in the BASIC 
categories and the crash indicator; 
Extent implemented: Fully; 
Status as of September 2011: FMCSA began using SMS in all states in 
December 2010; 
However, at this time, FMCSA is not making the Cargo-Related BASIC and 
Crash Indicator scores publicly available; 
Safety implications: FMCSA is using SMS to identify carriers with 
safety problems and high crash risk behaviors for appropriate 

CSA carrier oversight activity: Interventions; 
FMCSA conducts an array of interventions based on the carrier BASIC 
and Crash Indicator scores to encourage carriers to address their 
safety violations; 
Extent implemented: Partially; 
Status as of September 2011: Since December 2010, seven of nine 
interventions have been fully implemented and two have not.[A]; 
FMCSA has suspended plans to implement the remaining two interventions 
(Off-site Investigations and Cooperative Safety Plans) nationwide 
until it completes a key piece of technology needed to implement them; 
Safety implications: The new interventions that FMCSA has implemented 
provide the agency more options to deal with at-risk carriers than 
were provided under SafeStat; 
Until all interventions are implemented and finalized, FMCSA and 
states will not be able to realize CSA's full intended benefit. For 
example, FMCSA previously estimated that Offsite Investigations would 
increase the number of carriers contacted by 35 percent. 

CSA carrier oversight activity: Suspending unfit carriers; 
FMCSA will also use a new Safety Fitness Determination to provide 
carriers with a safety rating (e.g., determine whether or not a 
carrier is fit to operate based on roadside inspection data); 
Extent implemented: Not implemented; 
Status as of September 2011: Although FMCSA originally intended to 
complete the rulemaking necessary to implement a new safety fitness 
standard by 2009, FMCSA now intends to complete the rulemaking by 
early 2013. However, according to the National Transportation Safety 
Board and a trucking association, a final rule could be delayed 
depending on the extent of public comments and other factors; 
Safety implications: Until the rulemaking is complete, FMCSA will 
continue to use the safety fitness determination rating process used 
under SafeStat, which requires a compliance review to identify unfit 
carriers and thus few carriers will be subject to fitness 

Source: GAO. 

[A] All of the interventions have been implemented in the nine pilot 
states. In addition, all of the interventions have been implemented in 
Alaska, according to FMCSA officials. For purposes of this report, 
when we refer to interventions not being implemented, we are referring 
to those that have not been implemented on a nationwide basis. 

[End of table] 

Safety Measurement System: 

FMCSA fully implemented the system to measure the performance of 
carriers in all safety categories in 2010. This information is 
provided to carriers to help them identify and address their own 
safety issues. Additionally, FMCSA has made most carriers' safety data 
publicly available since December 2010 (see fig. 1 for a sample 
screenshot of carrier information available to the public). Shippers 
and insurers, among others, can now use this information to make 
business decisions. However, as figure 1 shows, the Crash Indicator 
score and the Cargo-Related BASIC score are not being made publicly 
available. Stakeholders raised concerns that the Crash Indicator 
includes all crashes, including those in which the driver was not 
accountable. FMCSA took an interim step to make the Crash Indicator 
score available only to the carrier. FMCSA plans to contract with the 
Department of Transportation's John A. Volpe National Transportation 
Systems Center (Volpe) to develop a system to allow states to 
determine if a driver is accountable for a particular crash. FMCSA 
expects Volpe to begin work on this effort in January 2012. 
Specifically, FMCSA intends to allow carriers to request changes to 
their violations data by providing a police accident report to 
demonstrate that the carrier should not be held accountable for a 
particular crash. Similarly, the motor carrier industry raised 
concerns about biases created by grouping different types of carriers 
together for the Cargo-Related BASIC, specifically grouping open deck 
carriers (flat bed carriers) with those that use enclosed trailers. 
FMCSA agreed with the industry that these biases may exist and decided 
not to make the Cargo-Related BASIC data publicly available. In 
addition, industry raised concerns about FMCSA's original plans to 
base individual carrier crash rates on the number of power units, 
i.e., trucks they operate, as opposed to the number of vehicle miles 
traveled. FMCSA agreed that vehicle miles traveled is a more equitable 
measure of exposure when determining crash rates. After considering 
industry concerns, FMCSA modified the measurement system to now use a 
combination of power units and vehicle miles traveled to analyze crash 
risk. According to most trucking association officials we interviewed, 
FMCSA has been willing to listen to carriers' concerns while 
implementing CSA and, according to several, has responded by making 

Figure 1: Sample SMS Screenshot: 

[Refer to PDF for image: screen shot illustration] 

ABC Trucking: 
DOT#: 000000: 
SMS Methodology: 

Select a BASIC below to view details: 

BASICS Overview: (Based on a 14-month record, ending March 25, 2011) 

Unsafe Driving: 
On-Road: Inconclusive; 
Investigation: [Empty]; 
BASICS Status: [Empty]. 

Fatigued Driving (Hours-of-Service): 
On-Road: 99%; 
Investigation: Icon A; 
BASICS Status: Icon B. 

Driver Fitness: 
On-Road: 97%; 
Investigation: Icon A; 
BASICS Status: Icon B. 

Controlled Substances and Alcohol: 
On-Road: No violations; 
Investigation: Icon A; 
BASICS Status: Icon B. 

Vehicle Maintenance: 
On-Road: 89.4%; 
Investigation: Icon A; 
BASICS Status: Icon B. 

On-Road: Not available; 
Investigation: Not available; 
BASICS Status: Not available. 

Crash Indicator: 
On-Road: Not available; 
Investigation: Not applicable; 
BASICS Status: Not applicable. 


Icon Legend: 

[A] Serious violation cited within last 12 months from an 

[B] Denotes this carrier exceeds the FMCSA intervention threshold 
relative to its safety event grouping based upon roadside data and/or 
has been cited with one or more serious violations within the past 12 
months during an investigation. Therefore, this carrier may be 
prioritized for an intervention action and roadside inspection. 

View Complete Measurement Profile: 

Summary Of Activities: 

Total Inspections: 
Number: 34. 

Vehicle Inspections: 
Number: 19; 
OOS Rate: 32%. 

Vehicle Driver Inspections: 
Number: 34; 
OOS Rate: 24%. 

Hazardous Materials Inspections: 
Number: 0; 
OOS Rate: 0. 

Total Crashes: 
Number: 1. 

Number: 1. 

Number: 1. 
Recent Investigations: 

The following are up to five most recent investigations: 

Intervention Type: Compliance Review; 
Date: 8/11/2010. 
Data Center: 
Scope: Logged-in users only. 

File Type: Excel. 


Source: FMCSA. 

[End of figure] 

Another issue that has arisen during the implementation of this part 
of CSA is that state enforcement agencies, such as state police or 
state highway patrol agencies, have experienced some difficulties 
handling motor carriers' requests to review violations data through 
FMCSA's DataQs system. In the months before FMCSA began implementing 
CSA nationwide, as well as after FMCSA began implementing CSA, 
carriers have been requesting reviews of violations data at a higher 
rate than in the past and, in some cases, straining states' resources. 
Although carriers previously could request reviews of violations data 
through the DataQs system, carriers did not challenge the data as 
often because SafeStat focused on only certain violations. Because CSA 
uses all violations to determine carriers' SMS scores and has made an 
expanded range of data about the motor carriers' safety records 
available to them, carriers have taken a much greater interest in 
these data. Specifically, in August 2010, when FMCSA first made the 
violations data available for carriers' review, the number of requests 
for review was about 2,600 per month. This number increased to a high 
of about 5,000 per month in October 2010, 2 months after FMCSA made 
carriers' BASICs scores available for their review. Although this 
number has since decreased to about 3,700 per month by May 2011 and 
decreased further to about 3,000 by August 2011, it is still higher 
than when FMCSA first made violations data available for carriers' 
review. Specifically, state officials in four of the eight states we 
visited told us they have experienced significant increases in the 
volume of these requests, which has strained their resources. For 
example, in Maryland, the volume of requests for data review has 
increased from 65 in August 2010 to 122 in May 2011 before decreasing 
to 78 by August 2011. To deal with the increase, the Maryland State 
Police added another person to handle the requests. Similarly, in 
Texas, the number of requests for data review increased from 195 
requests in August 2010 to 285 by May 2011 before decreasing to 225 by 
August 2011. To handle the increase, Texas officials reassigned staff 
to handle the increased workload but planned to wait before hiring 
someone permanently. In addition to the impact on state resources, 
state officials in California said the increase in requests could 
affect their ability to resolve them within 10 days, FMCSA's goal for 
responding to carriers. Although the volume of data review requests 
from carriers has been declining, it is unclear if this trend will 
continue as implementation of CSA progresses. 

Trucking associations have raised concerns about how states handle 
these requests, as well as about states' willingness to change 
violations data. According to state law enforcement officials, states 
review the requests and correct violations that are in error. 
Officials also indicated that some requests reflect carriers' efforts 
to have as many violations removed from carriers' records as possible. 
In January 2011 FMCSA--in conjunction with its State Partners--
developed and issued a guide to address issues concerning consistency 
among states in handling requests to review violations data.[Footnote 


Thus far, FMCSA has fully implemented seven of the nine interventions 
nationwide.[Footnote 26] Of these seven, three are new--the Warning 
Letter, Targeted Roadside Inspection, and Onsite Focused 
Investigation.[Footnote 27] The Notice of Violation,[Footnote 28] 
Notice of Claim, Onsite Comprehensive Investigation, and Operations 
Out-of-Service Order existed before CSA and thus were already 
implemented nationwide. Together, as table 4 shows, these 
interventions provide a range of benefits. While FMCSA previously 
expected to implement two other new interventions--Off-site 
Investigations and Cooperative Safety Plans--nationwide by August 
2011, it has delayed their implementation in the nonpilot states 
because it has not yet finished developing the key technology required 
to manage them.[Footnote 29] This technology, known as Sentri, is part 
of FMCSA's ongoing information technology modernization effort and is 
intended to provide FMCSA enforcement and field staff easier access to 
carrier and driver information and to help FMCSA and states target 
unsafe carriers and drivers. FMCSA officials indicated that, although 
the agency's current legacy systems contain the information 
investigators need to conduct Off-site Investigations and Cooperative 
Safety Plans, the systems do not interact very well.[Footnote 30] 
According to FMCSA, one of Sentri's benefits is that it will create an 
environment with a single interface where users can conduct inquiries, 
inspections, investigations, and interventions, and create and review 
reports. Additionally, Sentri will align information technology 
systems with the changes to the investigative processes resulting from 
the interventions. FMCSA expects to complete this technology in April 
2012. FMCSA officials indicated that the delays were due to 
communication problems between information technology and program 
offices--who are customers--as to the data requirements for the 
system. Specifically, officials said that program offices needed to 
better explain and define requirements so that everyone understands 
them. According to FMCSA, its information technology office has put in 
place new collaboration and communications methods with the sponsoring 
program units.[Footnote 31] We have reported in the past on the 
importance of establishing an agreed-upon set of requirements for 
customers and stakeholders.[Footnote 32] Until FMCSA completes this 
technology and can fully implement all of the interventions, it will 
not be able to reach the increased number of carriers originally 

Table 4: Status of CSA's Interventions and Benefits and Limitations: 

Intervention: Warning Letter[A]; 
Implementation status: Fully implemented nationwide; 
Benefit: During the pilot test, FMCSA was able to "touch" more 
carriers with minor violations through the warning letter, which uses 
relatively fewer resources than any of the other interventions; 
Limitations: No enforcement mechanism. FMCSA depends on the carrier to 
take corrective action in response to the letter. 

Intervention: Targeted Roadside Inspection[A]; 
Implementation status: Fully implemented nationwide; 
Benefit: FMCSA provides data to roadside inspectors indicating a 
carrier's specific safety problems; 
Limitations: Some states we talked to have reduced hours and staffing 
at locations, such as weigh stations, where inspections are conducted 
(see next section). 

Intervention: Off-site Investigation[A]; 
Implementation status: Implemented only in the nine pilot states; 
Benefit: Provides enforcement agencies the ability to investigate more 
carriers by reviewing records away from carriers' place of business; 
Limitation: Effectiveness hinges on carriers providing complete and 
accurate supporting documentation; 
technology problems have delayed implementation nationwide. 

Intervention: On-site Focused Investigation[A]; 
Implementation status: Fully implemented nationwide; 
Benefit: FMCSA can focus on carriers' specific safety problems rather 
than a more resource intensive comprehensive investigation, thus 
allowing FMCSA to reach additional carriers with known on-road 
performance problems; 
Limitation: Until all investigators are comfortable conducting On-site 
Focused Investigations, FMCSA will not realize the intended benefits 
of focusing only on areas identified as problematic. 

Intervention: On-site Comprehensive Investigation; 
Implementation status: Fully implemented nationwide; 
Benefit: Provides an in-depth study of a carrier's full safety profile; 
Limitation: Very labor intensive. 

Intervention: Cooperative Safety Plan[A]; 
Implementation status: Implemented only in the nine pilot states; 
Benefit: Will allow FMCSA and the carrier to collaboratively identify 
the root causes of safety problems and avoid them in the future; 
Limitation: FMCSA and states have no assurance carrier will actually 
implement plan after it is developed; technology problems have delayed 
implementation nationwide. 

Intervention: Notice of Violation; 
Implementation status: Fully implemented nationwide; 
Benefit: Can be issued based on SMS scores; 
does not require use of investigative resources; 
carrier must provide evidence of corrective action to avoid further 
action, including fines[B]; 
Limitation: None. 

Intervention: Notice of Claim; 
Implementation status: Fully implemented nationwide; 
Benefit: Provides means of penalizing carriers monetarily; 
Limitation: Time to adjudicate cases is lengthy, according to FMCSA. 

Intervention: Unfit Suspension/Out-of-Service Order; 
Implementation status: Fully implemented nationwide; 
Benefit: FMCSA can continue to exercise its authority to put carriers 
out of service; 
Limitation: FMCSA cannot issue these based on SMS data until a 
rulemaking is complete. Once the rulemaking is complete. 

Source: FMCSA: 

[A] A new intervention available under CSA. 

[B] A Notice of Violation triggers a Notice of Claim or investigation 
if the carrier is unresponsive, and time to adjudicate Notice of Claim 
cases can be lengthy, according to FMCSA. 

[End of table] 

One issue that could influence the effectiveness of the interventions 
is training. As a result of the delay in completing Sentri and the 
decision to delay implementing off-site investigations and cooperative 
safety plans, FMCSA revised its training plans for nonpilot states. 
Originally, FMCSA planned to provide 1 week of classroom training to 
FMCSA division and state officials and staff in nonpilot states, as it 
had done in the pilot states. Instead, when FMCSA decided to roll out 
the interventions in a phased approach, FMCSA division management 
received 1 day of classroom training, while other FMCSA division and 
state investigators received a series of webinars on the first phase 
of the roll out. Additionally, FMCSA and state officials in pilot 
states are serving as mentors to assist their counterparts in nonpilot 

FMCSA and state officials we interviewed in nonpilot states had mixed 
opinions on the training. Six FMCSA and state officials in two of the 
nonpilot states we visited indicated that, because only certain 
interventions were implemented and pilot states were providing 
assistance, they felt the training prepared them to implement the 
interventions FMCSA initially rolled out. For example, officials in 
one state believed that, because the On-site Focused Investigations 
and Comprehensive Investigations were similar to the compliance 
reviews conducted in the past, they were comfortable with the training 
they have received. However, two of the FMCSA officials and one state 
official in the nonpilot states we visited felt the training lacked 
detail and was insufficient because CSA was still evolving. For 
example, officials in one state noted they were not yet conducting On- 
site Focused Investigations because they did not feel comfortable with 
the training they had received on this intervention. FMCSA officials 
indicated they were not aware of any other states that were not 
conducting On-site Focused Investigations. However, officials in two 
states said that while investigators were conducting On-site Focused 
Investigations, they were concerned about how effectively they were 
being conducted given limited training or because investigators were 
not yet comfortable with conducting focused reviews instead of 
comprehensive reviews. 

FMCSA is taking steps to improve training on interventions. FMCSA 
officials acknowledged that the training to date was insufficient and 
explained that when they decided to begin implementing CSA in the fall 
of 2010, they used the webinar approach to provide information quickly 
to FMCSA divisions and states. FMCSA provided 2 days of additional 
training during the summer of 2011 that consisted of classroom 
training in all 50 states and included both management and 
investigators in FMCSA divisions and state agencies. This training 
includes the Safety Management Cycle approach to interventions 
involving investigations which, as noted, FMCSA believes will allow 
investigators to determine why violations occur and offer 
recommendations for improvement. FMCSA expects that the Safety 
Management Cycle will be implemented by the end of 2011. FMCSA 
officials also indicated that, as they developed this training, they 
incorporated the suggestions from participant evaluations from earlier 
training classes and agency surveys from both pilot and nonpilot 

Determining Carrier's Fitness to Operate Based on SMS: 

FMCSA is roughly 2 years behind its original target date for issuing 
and completing the rulemaking required to use SMS to determine a 
carrier's fitness to operate. We reported in December 2007[Footnote 
33] that FMCSA planned to publish a NPRM for the carrier safety 
fitness determination in summer 2008 and expected the final rule to be 
in place in 2009. However, because of changes to SMS that arose during 
testing--such as the change in calculating crash rates--and a backlog 
of rulemakings for other FMCSA programs, officials now plan to issue 
the NPRM late in 2011 and finalize the rule in 2013. However, the date 
FMCSA can finalize the rule could also be delayed. FMCSA officials 
indicated they do not foresee any major challenges in meeting the 
current schedule because they have held public information sessions 
since 2008 to inform the motor carrier industry of the methodology 
they are considering for the safety fitness determination. On the 
other hand, others, such as the National Transportation Safety Board 
and the National Private Truck Council, noted that rulemakings could 
take much longer. Until the rulemaking is completed, FMCSA will not 
realize one of its most important goals for CSA--enhancing its ability 
to assign safety fitness determinations to a significantly greater 
portion of the motor carrier industry than it currently is able to do. 

FMCSA Has Had Mixed Success Managing CSA's Implementation and Has Not 
Communicated to Congress Its Strategy to Address Identified Weaknesses 
and Delays: 

In some areas, FMCSA performed well as it implemented CSA, most 
notably, in conducting extensive outreach to carriers. In December 
2007, we reported that communicating needed information to key 
stakeholders would be critical to implementing a successful program. 
According to trucking association representatives, FMCSA has made 
considerable effort to provide information to carriers and 
associations and, according to one state trucking association, has 
probably done as much outreach as possible, given its resources. 
FMCSA's efforts to reach out to carriers and make them aware of the 
program, if continued, could help FMCSA educate carriers about future 
developments in the program and forestall problems as it completes 
implementing the carrier component of CSA nationwide. Our interviews 
with 55 carriers indicated that 23 had learned about CSA from a 
variety of sources, including FMCSA's and states' outreach efforts and 
state trucking associations. However, 32 of the carriers indicated 
that they were not familiar with CSA. Of these carriers that had never 
heard of CSA, 12 were small carriers, 15 were medium and 5 were 
large.[Footnote 34] While the results of our interviews are not 
generalizable, they suggest that FMCSA should continue its outreach 

FMCSA has also been responsive to stakeholder concerns during CSA's 
implementation. In our December 2007[Footnote 35] report, we said that 
controlling the project by monitoring and providing feedback would be 
critical to CSA's success. Throughout the pilot and implementation, 
FMCSA has made changes to CSA based on feedback from carriers and 
states. As noted previously, in addition to deciding to not make the 
Crash Indicator and Cargo-Related BASIC data public, FMCSA also 
expanded its basis for calculating crash rates to include both power 
units (i.e., trucks) as well as vehicle miles traveled after 
stakeholders raised concerns. After studying the issue, FMCSA 
determined that including vehicle miles traveled in addition to power 
units was a more accurate measure. 

Although FMCSA has managed CSA implementation well in these areas, the 
agency has experienced some difficulties in others. 

FMCSA conducted a workforce analysis study in 2009 to determine the 
staffing levels and skill sets necessary to implement CSA. Based on 
this study, FMCSA planned to hire additional staff, including staff to 
support the expected increase in investigations. For fiscal year 2012, 
FMCSA has requested $78 million from Congress to fully implement and 
integrate CSA into its operations. Of this request, $61 million is for 
696 full time positions, including salary and benefits, which 
represents most of FMCSA's existing field staff as well as 98 new full-
time positions.[Footnote 36] These new positions include 30 
investigators and 51 program analysts who would assist intervention 
managers[Footnote 37] and investigators throughout FMCSA's divisions, 
among other staff.[Footnote 38] 

Notwithstanding the future of its funding request, FMCSA has not yet 
fully determined how it would allocate staff as it moves forward to 
implement CSA. FMCSA has not determined which divisions will receive 
the additional investigators and program analysts, although small 
states will likely share program analysts. FMCSA also has not 
performed a staffing analysis to determine how it would reallocate 
existing staff if it does not receive the funding in fiscal year 2012 
for the new positions. We have identified key practices for workforce 
planning, including developing a process to determine staffing needs 
and allocate staff among offices and taking the budgetary process into 
account.[Footnote 39] Given the current budgetary environment, FMCSA 
officials realize they may not receive all funding requested and plan 
to re-examine current staff allocations if FMCSA does not receive 
authority for these positions. FMCSA officials have stated that CSA's 
effectiveness would be impacted with less funding because 
investigators would not be able to conduct the same number of 
interventions and, consequently, FMCSA would not be able to reach as 
many carriers as originally expected. However, waiting to determine 
how to allocate a lesser number of staff could also delay FMCSA 
efforts to continue to implement CSA. 

In addition, FMCSA is still adapting to the changes required by the 
new interventions. CSA represents a shift to a new paradigm or way of 
thinking about safety that requires a cultural change among FMCSA 
Division and state staff, which can take time. CSA requires 
investigators to change from comprehensively investigating all aspects 
of a motor carrier's operations to focusing only on weaknesses that 
SMS identifies (i.e., the on-site focused investigation). During our 
site visits, FMCSA division and state staff often reported that they 
appreciated the efficiencies gained by using data to identify carriers 
and areas to focus on during investigations. However, they also 
reported that this shift has been difficult, with some investigators 
still preferring to conduct comprehensive investigations. FMCSA 
officials noted that investigators can expand a focused review if they 
see evidence of problems in other areas and that the efficiency gains 
FMCSA intends will be negated if investigators continue to take a 
comprehensive approach when focused reviews are warranted. We have 
reported that major change initiatives and cultural changes take time 
to fully implement and take effect. In our 2003 report on the 
Architect of the Capitol, for example, we reported that the 
experiences of successful major change management initiatives in large 
private and public sector organizations suggest that they can often 
take at least 5 to 7 years until they are fully implemented and the 
related cultures are transformed in a sustainable manner. 
Additionally, we reported that fundamental changes in the Architect of 
the Capitol's culture will require a long-term, concerted effort. 
[Footnote 40] The same may be true for CSA; much about CSA is new and, 
given the nature of this type of cultural transformation, it may 
simply take time for staff to adjust to the new paradigm. To address 
this issue, FMCSA, among other things, is using the pilot states as 
mentors for the states that did not participate in the pilot test, 
invited participants from pilot-test states to describe the new 
process to their peers in non-pilot states, and has put CSA on the 
agenda of annual in-service training sessions. Additionally, FMCSA 
plans to develop a systematic change management plan. 

As we have previously discussed, several steps and issues remain 
before FMCSA can fully implement CSA carrier oversight activities. 
Specifically, FMCSA has not: 

* completed a key technology to fully implement the interventions and 
provided training on interventions yet to be implemented, 

* developed and issued the NPRM to take action against unfit carriers 
based on CSA data, 

* addressed staffing issues and completed efforts to help staff shift 
to a new safety enforcement paradigm. 

FMCSA officials acknowledged delays in implementing CSA's carrier 
oversight activities and the need to complete key tasks and address 
certain issues. However, they maintain that delays are to be expected 
when implementing a major program such as CSA and that, in their 
opinion, FMCSA has implemented the bulk of CSA's oversight activities. 
They acknowledged that risks associated with FMCSA's ability to 
complete these items and address budgetary issues could affect their 
ability to fully implement CSA, as well as CSA's effectiveness, and 
noted that they track open issues and the associated risks and 
mitigation strategies. Although FMCSA officials indicated they have 
periodically briefed congressional staff of their progress in 
developing and implementing CSA, FMCSA has not developed any type of 
comprehensive document that specifically outlines its status, 
implementation delays, and other issues that need to be addressed, or 
identifies the risks associated with these problems and strategies to 
mitigate them. 

Our past work has shown that the early identification of risks and 
strategies to mitigate them can help avoid negative outcomes when 
implementing large-scale projects. For example, in our 2010 report 
examining the Federal Railroad Administration's (FRA) efforts to 
implement a Positive Train Control (PTC) system, we reported that 
uncertainties about tasks, such as potential delays in developing PTC 
components, software, and subsequent testing and implementation of PTC 
systems, raise certain risks to successfully completing PTC on time. 
[Footnote 41] Specifically, potential delays in developing PTC 
components, software, and subsequent testing and implementation of PTC 
systems, raise the risk that railroads will not meet the 
implementation deadline and that the safety benefits of PTC will be 
delayed. We noted that FRA officials were aware of some of these 
risks, but said it was too early to know whether they were significant 
enough to jeopardize successful implementation. However, we also noted 
that, as FRA moves forward with monitoring railroad's implementation 
of PTC, the agency will have more information regarding the risks to 
completing PTC on time and would thus be in a better position to 
inform Congress and other stakeholders of the risks and mitigation 
strategies associated with implementing the system. Similarly, our 
2004 report examining an Amtrak project to manage improvements to the 
Northeast Corridor noted that early identification and assessment of 
problems would allow for prompt intervention, increasing the 
likelihood that corrective action could be taken to get the project 
back on track.[Footnote 42] Risk identification and management are 
also essential in the case of CSA, which FMCSA developed with the goal 
of significantly improving motor carrier safety. Regularly reporting 
information on what steps FMCSA needs to complete in order to 
implement CSA--including a timetable--as well as the risks and 
mitigation strategies associated with not completing each step or 
addressing each issue, would put FMCSA in a better position to respond 
to problems when they occur and thus better ensure that FMCSA could 
complete CSA's implementation as planned. This would also provide 
Congress and other stakeholders with important information as to 
FMCSA's status in implementing CSA and the associated risks, which 
would help Congress make decisions about the program. 

FMCSA Has Made Little Progress on Driver Fitness Ratings: 

Although the implemented CSA oversight activities have provided FMCSA 
additional tools to provide information on drivers and assess their 
safety performance, FMCSA has only recently begun steps to develop the 
process to separately rate the safety fitness of all drivers under 
CSA. Since CSA's initiation, FMCSA has prioritized implementation of 
the carrier oversight activities. FMCSA is seeking to clarify its 
authority to prohibit individual drivers, if determined to be unfit 
based on ratings, from operating in interstate commerce. FMCSA 
officials believe that arguably the agency currently has this 
authority, but acknowledge that seeking clarification from Congress 
would be prudent. FMCSA is seeking this authority as part of the next 
surface transportation reauthorization and has provided committees of 
Congress technical legislative drafting assistance to this effect. 
[Footnote 43] 

FMCSA officials also explained they now have access to more 
information on drivers than they previously had so that implementing 
the driver component is not as critical to CSA's ability to improve 
safety as they believed when designing the program. For example, the 
Unsafe Driver BASIC provides additional oversight of drivers and 
allows FMCSA to address unsafe driver behaviors by intervening with 
carriers that employ unsafe drivers. Other systems also now allow 
FMCSA to evaluate drivers: 

* The Driver Safety Measurement System (DSMS) uses safety data from 
roadside inspections and crashes to measure drivers' safety in a 
manner similar to that used under SMS and allows FMCSA and state 
partners to identify unsafe, or "red flag," drivers. The red flag 
driver investigation process examines drivers receiving certain 
violations during the course of motor carrier investigations.[Footnote 
44] However, since FMCSA has not implemented driver safety fitness 
determinations, the agency only uses DSMS internally and for law 
enforcement purposes. 

* The Pre-Employment Screening Program (PSP)[Footnote 45] allows 
carriers to view 5 years of individual drivers' crash data from 
FMCSA's MCMIS as well as 3 years of roadside violation data from 
MCMIS. Although PSP provides useful information, it was not intended 
to be a comparative tool and thus does not allow carriers to determine 
how safe or unsafe a driver is compared to other drivers. Also, 
participation in PSP is voluntary; motor carriers must pay a 
subscription fee for this service. 

Nonetheless, including a fitness determination would expand FMCSA's 
oversight by measuring individual driver performance and 
systematically identifying unsafe commercial drivers for safety 
enforcement. It would allow carriers to determine an individual 
driver's safety relative to other drivers and increase the usage of 
driver safety data among the motor carrier industry. FMCSA's 2005 
study of large truck crashes found that driver behavior is the single 
largest cause of crashes.[Footnote 46] FMCSA officials indicated that 
they still plan to assess driver fitness as part of CSA but have not 
developed a plan or set any timetable for doing so. FMCSA has also not 
determined how driver safety determinations will be used or assessed 
the safety risk of delayed implementation of them. 

CSA has the Potential to Improve Safety by Identifying More At-Risk 
Carriers, but the Program's Full Impact Nationwide Is Unclear: 

CSA has the potential to identify higher-risk carriers under more 
precisely defined areas of safety performance, and FMCSA has an 
expanded range of interventions to follow up with them. Collectively, 
these changes offer the potential to improve safety. However, not all 
carriers are inspected, and larger sized motor carriers are likely to 
have more inspections and thus, more likely to be ranked under SMS 
than smaller sized motor carriers. Moreover, the technology FMCSA has 
developed to select carriers for inspection did not allow inspectors 
we observed to quickly determine if a carrier's past history warranted 
an inspection. Instead, they used it to identify what needed to be 
inspected once a carrier was already selected for inspection. As a 
result, some states use other technologies that incorporate FMCSA's 
system, or other methods to select carriers that may not be 
systematic. Furthermore, until FMCSA completes new performance 
metrics, gauging the extent to which CSA improves safety will be 

CSA Has Potential to Improve Safety through Better Use of Data and 
More Contact with Carriers: 

To improve safety, CSA makes better use of roadside inspection data in 
the following ways: 

* SMS makes greater use of the data available from roadside 
inspections than SafeStat did. Under SafeStat, only out-of-service 
violations and selected moving violations were used for estimating 
carriers' scores under the Driver and Vehicle safety evaluation areas. 
[Footnote 47] In SMS, any violation found is used in calculating a 
carrier BASIC score.[Footnote 48] This should help FMCSA to improve 
overall safety by allowing it to identify carriers with recurring 
types of safety violations that may have been missed under the prior 
SafeStat system. 

* SMS allows for more precision in the measurement of safety, since, 
as we discussed previously, the BASIC scores and Crash Indicator 
measure carrier performance in seven areas, rather than the four used 
under SafeStat. For example, CSA measures driver performance at the 
motor carrier company level in several categories, including unsafe 
driving, fatigued driving, driver fitness, and the use of controlled 
substances and alcohol, whereas SafeStat calculated an overall rating 
based on all these driver factors combined. This breakdown not only 
allows for a more precise determination of motor carrier safety 
performance overall but also allows FMCSA to better identify specific 
areas of safety shortcomings. For example, CSA can indicate if a 
carrier is having a problem with driver fatigue, whereas SafeStat 
could not provide this level of detail. Thus, interventions can be 
targeted to the specific area of safety concern. 

* SMS creates percentile ranks for carriers within each BASIC and in 
the Crash Indicator, rather than producing just one total summed 
score, as SafeStat did. Thus, SMS has the potential to improve safety 
by reporting scores on the separate areas of safety problems and 
making carriers' performance in this area explicit. For example, CSA 
can indicate that, although a carrier has a relatively poor ranking in 
the Cargo-Related BASIC, the carrier has a good ranking in the Unsafe 
Driving indicator, thereby enabling FMCSA to focus its interventions 
on carrier practices that have the greatest impact on safety. 

SMS also allows FMCSA to conduct interventions with a greater number 
of motor carriers. SMS identifies about 45,000 motor carriers each 
month that exceeded the thresholds in one or more BASICs or the Crash 
Indicator. By comparison, under SafeStat, a similar number of about 
45,000 carriers per month[Footnote 49] were identified as exceeding 
the threshold on one or more safety evaluation areas to varying 
degrees, on a scale of A to G.[Footnote 50] However, under SafeStat, 
only those carriers with a SafeStat rating of A, B, or C were 
prioritized for SafeStat's intervention--a full compliance review--
resulting in a smaller percentage of motor carriers with an identified 
safety problem receiving the intervention. For example, during all of 
fiscal year 2009, 16,512 compliance reviews were carried out by FMCSA 
and state partners on motor carriers rated under SafeStat. Under CSA, 
any carrier exceeding a threshold in even one BASIC or in the Crash 
Indicator will receive an intervention of some type. 

The reason FMCSA can contact carriers with a wider range of 
violations--including less severe violations--than it did under 
SafeStat is that CSA provides a wider range of intervention tools, 
some of them requiring few resources to implement. CSA's range of 
interventions--from the resource-intensive On-site Comprehensive 
Investigation to the relatively low-resource Warning Letter--provide 
FMCSA with more tools for contacting carriers, calibrating the 
intervention to the severity of the violation. Under CSA, all carriers 
newly identified as exceeding the threshold in one or more safety 
areas in a given month are subject to some type of safety intervention 
by FMCSA, most commonly a Warning Letter. During the first 6 months of 
fiscal year 2011, FMCSA sent 19,470 Warning Letters and, along with 
state partners, conducted 3,190 CSA On-site Focused Investigations in 
addition to completing 5,684 compliance reviews through May of 2011, 
for 28,344 total safety interventions.[Footnote 51] Preliminary 
evidence from the pilot test suggests that even the warning letters 
have an effect on safety. Twelve months after receiving only a Warning 
Letter, 17 percent of test carriers exceeded at least one SMS 
threshold as opposed to 45 percent of the control carriers who did not 
receive Warning Letters. Reaching more carriers with enforcement 
actions should enable FMCSA to improve safety.[Footnote 52] 

Not All Carriers Have Enough Inspections to Receive Safety Rankings: 

While the pilot test suggests that SMS has the potential to improve 
safety over the prior SafeStat system, SMS's ability to calculate 
BASIC scores for carriers is dependent upon sufficient roadside 
inspection data for that carrier, which are not always available for a 
significant segment of carriers. Analysis of the data from the pilot 
test states found that a substantial proportion of motor carriers lack 
sufficient data for ranking in the six BASICs and Crash Indicator: 
Specifically, the Fatigued Driving and Unsafe Driving BASIC both 
require a minimum of three relevant inspections and at least one 
relevant violation for a motor carrier over the past 24 months; the 
Vehicle Maintenance, Driver Fitness, and Cargo-Related BASICs each 
require a minimum of five relevant inspections and at least one 
relevant violation over the preceding 24 months.[Footnote 53] Table 5 
shows the percentage of carriers in the pilot test states that have 
sufficient data for ranking in a BASIC or the Crash Indicator. 

While most large motor carriers have enough data to be considered and 
rated under SMS, the majority of smaller carriers do not. For example, 
about 48 percent of carriers with 51 to 500 vehicles and about 71 
percent of carriers with 501 or more vehicles have sufficient ranking 
in the Unsafe Driving BASIC but only about 1 percent of carriers with 
5 or fewer vehicles do. The majority of companies in operation are 
small motor carriers with 5 or fewer vehicles; the lack of sufficient 
data for ranking on a BASIC is greatest in this segment of the carrier 
fleet. Those carriers with 2 or fewer roadside inspections are only 
potentially ranked by SMS through the Controlled Substances/Alcohol 
BASIC or the Crash Indicator.[Footnote 54] Those with 3 to 4 
inspections are below the minimum data sufficiency requirements for 
the Vehicle Maintenance and Driver Fitness BASICs. This data 
limitation will continue to prevent the SMS from functioning at full 
capability until efforts to expand roadside inspection measurement 
coverage across the motor carrier fleet succeed. In the meantime, the 
effect of this data sufficiency limitation is that safety ranking by 
SMS is more concentrated among the large sized motor carriers than it 
is among the more numerous smaller sized motor carriers. 

Table 5: Data Sufficiency Rates, by BASICs and Carrier Size, Test 

Carrier Size: 0-5 Vehicles; 
Unsafe Driving: 1.1%; 
Controlled Substances and Alcohol: 3.1%; 
Fatigued Driving: 0.2%; 
Driver Fitness: 0.1%; 
Vehicle Maintenance: 3.6%; 
Improper Loading/Cargo Securement: 0.4%; 
Crash Indicator: 0.3%; 
Any Basic: 5.7%. 

Carrier Size: 6-15 Vehicles; 
Unsafe Driving: 9.9%; 
Controlled Substances and Alcohol: 11.6%; 
Fatigued Driving: 2.2%; 
Driver Fitness: 0.4%; 
Vehicle Maintenance: 23.4%; 
Improper Loading/Cargo Securement: 5.5%; 
Crash Indicator: 4.0%; 
Any Basic: 28.3%. 

Carrier Size: 16-50 Vehicles; 
Unsafe Driving: 27.4%; 
Controlled Substances and Alcohol: 25.1%; 
Fatigued Driving: 6.1%; 
Driver Fitness: 1.3%; 
Vehicle Maintenance: 45.1%; 
Improper Loading/Cargo Securement: 17.2%; 
Crash Indicator: 17.7%; 
Any Basic: 50.2%. 

Carrier Size: 51-500 Vehicles; 
Unsafe Driving: 47.9%; 
Controlled Substances and Alcohol: 40.0%; 
Fatigued Driving: 22.9%; 
Driver Fitness: 4.3%; 
Vehicle Maintenance: 59.1%; 
Improper Loading/Cargo Securement: 37.2%; 
Crash Indicator: 46.7%; 
Any Basic: 65.7%. 

Carrier Size: 500+ Vehicles; 
Unsafe Driving: 71.4%; 
Controlled Substances and Alcohol: 55.1%; 
Fatigued Driving: 63.3%; 
Driver Fitness: 20.4%; 
Vehicle Maintenance: 79.6%; 
Improper Loading/Cargo Securement: 67.3%; 
Crash Indicator: 77.6%; 
Any Basic: 83.7%. 

Carrier Size: Total; 
Unsafe Driving: 4.8%; 
Controlled Substances and Alcohol: 6.4%; 
Fatigued Driving: 2.5%; 
Driver Fitness: 1.9%; 
Vehicle Maintenance: 8.7%; 
Improper Loading/Cargo Securement: 3.5%; 
Crash Indicator: 3.4%; 
Any Basic: 11.0%. 

Source: U.S. Department of Transportation, Paul E Green and Daniel 
Blower, Evaluation of the CSA 2010 Operational Model Test, University 
of Michigan Transportation Research Institute, FMCSA-RRA-11-019 
(Washington, D.C.: Aug. 2011), p. 27. 

Note: Data sufficiency rates for all carriers (the total) are 
calculated by accounting for the number of carriers in each size 
category prior to combining category rates. Due to their small 
numbers, the data sufficiency of large carriers is largely obscured 
after being averaged with the rates of smaller carriers. 

[End of table] 

Limitations in Methods Used to Select Vehicles for Roadside 
Inspections May Hinder CSA from Realizing Its Potential to Improve 
Highway Safety: 

Based on visits to inspection stations and interviews with inspection 
officials in eight states, we found that not all states use methods 
that systematically select trucks[Footnote 55] for roadside 
inspections, which can limit CSA's ability to improve motor carrier 
safety. FMCSA provides all states with its Inspection Selection System 
(ISS-2010) software, designed to systematically identify carriers with 
known poor safety performance. Vehicle selection methods that factor 
in safety performance offer more assurance that roadside inspections 
will ultimately prevent crashes by focusing resources on higher-risk 
carriers. The ISS-2010 software also systematically identifies 
carriers that have not been ranked in any of the BASICs by the SMS, 
[Footnote 56] so that inspectors can inspect those carriers' trucks to 
determine their compliance.[Footnote 57] Because of the pace at which 
trucks move through the scales at inspections stations, however, 
inspectors we observed rarely had time to access the ISS-2010 on 
FMCSA's website before deciding which trucks to inspect. Thus, 
inspectors mainly used ISS-2010 to obtain information about trucks 
that have already been selected for inspection by other means (see 

Many states use software that allows inspectors to bypass some low-
risk trucks from the inspection station, thus allowing them to select 
carriers for inspection from a group with a history of safety problems 
or unknown safety performance. These third-party software products 
incorporate the ISS-2010 algorithms to allow trucks belonging to 
carriers with good safety performance to bypass inspection stations. 
When these trucks are allowed to bypass the weigh station, inspection 
resources can be expended on carriers with riskier or unknown safety 
performance, according to the software. For example, in 30 states, 
inspectors rely on a product called PrePass.[Footnote 58] PrePass 
incorporates the ISS-2010 selection algorithms with other proprietary 
criteria to gauge a carrier's safety performance, including crash 
risk, before its truck enters an inspection station. Carriers that 
participate in PrePass receive transponders for their trucks; weigh 
stations are fitted with equipment that receives signals from the 
transponders. The transponder sends a signal to the inspection station 
that alerts inspectors as to whether the participating truck can 
bypass the inspection station or if it must come in for an 
inspection.[Footnote 59] All nonparticipating trucks must enter the 
station when it is open. Inspectors in states that use such software 
products then employ a combination of other methods, some noted below, 
to select trucks for inspection from among those that enter the weigh 
station. FMCSA officials stated that states are encouraged to use 
federal roadside inspection grant funds to purchase technology to 
assist their inspectors in systematically selecting trucks for 
inspection. FMCSA currently does not require states to use ISS-2010 
software or products like PrePass, although it encourages them to do 
so.[Footnote 60] 

While some of the selection methods we observed being used at 
inspection stations take some aspects of crash risk into account, none 
are as systematic as would be the case if inspectors were able to use 
the ISS-2010 algorithms for truck selection. Some also may, by chance, 
select for inspection the trucks of carriers previously unranked by 
CSA, thereby broadening the base of carriers the SMS can potentially 
rank. We observed the following selection methods: 

* Weight as an initial selection factor. All trucks entering a weigh 
station will be weighed. If the overall weight or individual weight on 
a particular axle exceeds the allowed weight, inspectors put the truck 
and driver out of service. This method addresses safety performance 
and may by chance select trucks of carriers previously unranked by the 
SMS because all trucks must cross the scales. The truck may not resume 
its journey until its weight issues are resolved,[Footnote 61] and the 
inspector has discretion to conduct further inspection. 

* Obvious problems. When inspectors notice obvious problems related to 
safety performance on a truck as it moves across the scale--such as a 
flat tire, unattached hoses, incorrect or damaged placards, etc.--they 
may pull the vehicle over for inspection. Many of these problems could 
involve safety performance issues and may result in selecting trucks 
of carriers previously unranked by the SMS. 

* Random selection. Inspectors choose trucks for inspection randomly 
from among those not put out of service for weight issues. This method 
does not gauge crash risk or other aspects of safety performance but 
could select trucks of carriers previously unranked by the SMS. 

* Local discretion. These methods may focus inspectors' efforts on 
particular types of inspections, carriers, trucks, or loads for a 
period of time. Local discretion selection methods can be guided by 
the certification level of inspectors available at the 
station,[Footnote 62] the training needs of those inspectors,[Footnote 
63] or news stories about crashes of particular types of vehicles or 
loads, among other things. In some cases, inspectors may focus their 
efforts on factors that influence safety, perhaps in response to 
public opinion about the safety performance of particular types of 
vehicles or loads. These methods could also result in selecting trucks 
of carriers previously unranked by the SMS. 

All of these methods are limited in identifying higher-risk trucks and 
carriers. For example, a truck belonging to a carrier with a history 
of driver fatigue issues would not be readily identifiable to an 
inspector unless a software product employing the ISS-2010 BASIC-
supported algorithm flagged it. 

No inspection selection method can assist weigh station inspectors in 
selecting trucks if drivers avoid the weigh station entirely. Our 
observations at state inspection stations and discussions with 
inspection officials revealed that some drivers attempt to evade 
roadside inspection in different ways, allowing some carriers to 
potentially operate entirely beyond the scope of CSA. For example, 
drivers may avoid driving past a weigh station during its regular 
hours of operation. Inspection facilities in many states are open 
limited hours, and state officials told us there is a significant 
level of truck traffic when stations are closed. Because of physical 
or staffing constraints at some weigh stations, we observed that staff 
may close a station periodically during its standard hours of 
operation to relieve crowding or avoid back ups of trucks that could 
present a safety hazard on the freeway. State police and other 
officials in a number of states also indicated that budgetary 
constraints may force them to reduce weigh stations' hours of 
operation, decreasing the number of trucks they can inspect and 
increasing the travel-time flexibility of drivers seeking to avoid 
inspection. State police officials also told us that some drivers seek 
to evade inspection by pulling over to the side of the road until a 
station closes or by altering their routes to drive around weigh 
stations, either on other highways or on smaller roads, sometimes 
within sight of staff at the weigh station. Depending on resources 
available at the station,[Footnote 64] troopers may or may not be able 
to leave the station to stop drivers whose trucks should be inspected. 
[Footnote 65] According to a number of state inspection officials, 
when inspectors do inspect trucks of drivers seeking to avoid 
inspection, they often find serious safety violations, reiterating the 
potential importance of appropriately targeting inspection resources 
to road safety. 

Until FMCSA Implements New Performance Measures, Gauging Extent of CSA-
related Safety Improvement Will Be Problematic: 

FMCSA has begun to develop performance measures to assess CSA's 
nationwide performance in improving safety, but has not yet set a 
timetable for their completion. Indications that CSA may improve 
safety exist. Specifically, the UMTRI evaluation of the pilot test 
indicates that CSA's SMS and new, expanded set of interventions 
increased FMCSA's ability to improve safety in the four pilot 
states.[Footnote 66] However, performance measures are needed to gauge 
the effectiveness of CSA in improving safety as it is implemented 

We have previously reported that agencies need to set quantifiable 
outcome-based performance measures for significant agency activities, 
such as CSA, to demonstrate how they intend to achieve their program 
goals and measure the extent to which they have done so.[Footnote 67] 
Performance measures allow an agency to track its progress in 
achieving intended results, which can be particularly important in the 
implementation stage of a new program. Performance measures can also 
help inform management decision making, such as the need to redirect 
resources or shift priorities. In some of our prior work we have 
recommended that agencies develop methods to accurately evaluate and 
measure the progress of implementation, and develop contingency plans 
if the agency does not meet its milestones to complete tasks.[Footnote 
68] In addition, performance measures can be used by stakeholders, 
such as state law enforcement partners, carrier associations, and the 
public who use the nation's highways, to hold FMCSA accountable for 
results. With performance measures, FMCSA Divisions and state partners 
will be able to set priorities and measure results by state or overall. 

FMCSA has been working on developing performance measures for CSA 
results and program implementation progress. FMCSA has proposed 
several performance measures for CSA, but they have not yet been 
approved within the agency. Two of the proposed measures would assess 
outcomes of CSA. The first would determine the number of carriers that 
received a specific CSA intervention in 1 year and then showed 
improvement in the next year. The second would measure the level of 
compliance from all inspections in a baseline year before CSA was 
implemented (e.g., 2007) and compare that level against compliance in 
subsequent years to quantify improvements in compliance across the 
entire industry. FMCSA is also considering output measures, such as 
the increase in the number of carriers reviewed once off-site and 
focused investigations are fully implemented. According to FMCSA 
officials, these proposed measures have not yet been approved by the 
Administrator, and implementation will depend on accumulating relevant 
CSA intervention data once the carrier oversight activities are fully 
deployed in 2012, as expected. Under this timeline, 2012 would become 
the baseline year, which means 2013 would become the first year in 
which FMCSA could begin to develop CSA performance targets such as the 
percentage of carriers that showed safety improvements after being 
subject to CSA interventions. 

FMCSA has also begun efforts to track its progress in implementing 
CSA. FMCSA has identified the specific steps it has taken to implement 
CSA, as well as the states in which the various CSA oversight 
activities have been implemented (i.e., pilot states vs. nonpilot 
states, and, for those oversight activities that have not been 
implemented, when FMCSA plans to implement them). When ultimately 
developed and implemented, such measures will help provide CSA 
managers with information on the status of CSA implementation and 
allow them to make adjustments, if necessary, to meet established 


FMCSA's CSA program has been partly implemented and shows the 
potential for improving motor carrier safety. However, key aspects of 
the initiative, including using safety data from the new SMS system to 
take unsafe carriers and drivers off the road and enforcing other 
safety regulations, are indefinitely delayed. In the case of drivers, 
the plan for when and how to determine a driver's fitness to operate 
vehicles based on the new measurement system has yet to be developed, 
and the safety implications of delayed implementation of drivers' 
fitness ratings for FMCSA's current goals to improve safety are 
unclear. FMCSA has also encountered several problems during 
implementation, including delays in developing technology needed for 
new interventions, and resistance from staff to shift to a new 
paradigm of more focused and less time-consuming reviews of carrier 
operations. Further, FMCSA has not established a process for regularly 
reporting to Congress and the public on CSA's status, problems it has 
encountered in implementing CSA, the risks they pose to full 
implementation and its strategy for mitigating these risks. This type 
of information is essential to assist Congress in making decisions 
about funding or authorizations for the program and assure Congress 
and stakeholders that CSA is being successfully implemented. To this 
end, FMCSA has made progress in developing performance measures for 
determining the extent to which investigative staff are using new CSA 
interventions and the safety outcomes of these interventions. However, 
until these measures are completed and are being implemented, the 
extent of CSA's effectiveness in improving safety will remain unclear 
to FMCSA management, Congress, and the public. 

Recommendations for Executive Action: 

We recommend that the Secretary of Transportation direct the FMCSA 
Administrator to take the following two actions: 

* develop a plan for implementing driver fitness ratings that 
prioritizes steps that need to be completed and includes a reasonable 
timeframe for completing them. The plan should also address the safety 
implications of delayed implementation of driver fitness ratings. 

* regularly report to Congress on CSA's status; the problems that 
FMCSA has encountered during the implementation of CSA and the risks 
they pose to full implementation of CSA; its strategy for mitigating 
these risks; and a timetable for fully implementing CSA and reporting 
the progress made in developing and implementing CSA performance 

Agency Comments: 

We provided a draft of this report to the Department of Transportation 
for review and comment. The Department did not agree or disagree with 
our recommendations but said it would consider them. The Department 
provided technical comments and clarifications, which we incorporated 
as appropriate. At a meeting on September 23, 2011, to discuss the 
Department's comments, FMCSA officials confirmed that they intend to 
continue implementing the driver fitness ratings. Previously, FMCSA 
officials indicated that they were considering implementing these 
ratings but had made no final decision. In response to this new 
information, we modified the language of our recommendation regarding 
driver fitness ratings. Our recommendation originally focused on 
having FMCSA determine the safety implications of not fully and 
expeditiously implementing the driver fitness ratings and, if it 
determined that full implementation was necessary, to then develop an 
implementation plan. To reflect that FMCSA has decided to proceed with 
implementing the driver fitness ratings, we modified our 
recommendation to focus instead on an implementation plan. 

We are sending copies of this report to the appropriate congressional 
committees; the Secretary of Transportation, the Administrator, 
Federal Motor Carrier Safety Administration; and the Director, Office 
of Management and Budget. In addition, the report will be available at 
no charge on the GAO Web site at [hyperlink,]. 

If you have any questions regarding this report, please contact me at 
(202) 512-2834 or at Contact points for our Offices 
of Congressional Relations and Public Affairs may be found on the last 
page of this report. GAO staff who made major contributions to this 
report are listed in appendix II. 

Signed by: 

Susan Fleming: 
Director, Physical Infrastructure Issues: 

List of Congressional Committees: 

The Honorable Patty Murray:
The Honorable Susan Collins:
Ranking Member:
Subcommittee on Transportation, Housing and Urban Development and 
Related Agencies:
Committee on Appropriations:
United States Senate: 

The Honorable Tom Latham:
The Honorable John W. Olver:
Ranking Member:
Subcommittee on Transportation, Housing and Urban Development and 
Related Agencies:
Committee on Appropriations:
House of Representatives: 

[End of section] 

Appendix I: Objectives, Scope, and Methodology: 

GAO was directed by a 2009 Senate Committee Report, adopted by the 
conference committee, to conduct a study as part of the continued 
monitoring of the Compliance, Safety, and Accountability program (CSA) 
implementation.[Footnote 69] Specifically, this report addresses (1) 
the status of the CSA rollout and what issues, if any, could affect 
the full and effective implementation of the program and (2) CSA's 
potential to improve safety. 

To determine the status of the CSA rollout and challenges that could 
affect the full implementation of the program, we analyzed Federal 
Motor Carrier Safety Administration (FMCSA) documentation, including 
information on FMCSA's website (, periodic outreach 
e-mails from CSA program officials, and CSA training materials. 
Additionally, we reviewed congressional testimony provided by FMCSA's 
Administrator. We also reviewed an evaluation of the pilot 
test[Footnote 70] conducted by the University of Michigan's 
Transportation Research Institute (UMTRI).[Footnote 71] We interviewed 
FMCSA and National Transportation Safety Board headquarters' officials 
as well as national representatives of carrier industry associations 
(see table 6): 

Table 6: Associations Interviewed: 

American Association of State Highway and Transportation Officials; 
American Bus Association; 
American Trucking Associations; 
Commercial Vehicle Safety Alliance; 
HELP Inc. 
National Private Truck Council; 
Owner-Operator Independent Drivers Association; 
National Tank Truck Carriers. 

Source: GAO. 

[End of table] 

We also attended the Commercial Vehicle Safety Alliance (CVSA) annual 
conference in September 2010 and interviewed representatives of 
several State Partners to discuss CSA implementation, as indicated in 
table 7. We also attended two FMCSA-sponsored outreach sessions 
discussing different aspects of CSA and carrier motor vehicle safety, 
one from the carrier's perspective. 

Table 7: State Partners Interviewed During CVSA Conference: 

State or province: Arkansas; 
Agency: Arkansas Highway Police. 

State or province: Colorado; 
Agency: Colorado State Patrol. 

State or province: Maryland; 
Agency: Maryland State Police. 

State or province: Missouri; 
Agency: Missouri Department of Transportation. 

State or province: Ohio; 
Agency: Public Utilities Commission of Ohio. 

State or province: Saskatchewan, Canada[A]; 
Agency: Saskatchewan Highways and Infrastructure. 

State or province: South Carolina; 
Agency: South Carolina State Police. 

Source: GAO. 

[A] An official from one Canadian province participated in the 

[End of table] 

Additionally, we visited eight states (four that participated in the 
pilot program: Georgia, Maryland, Minnesota, and Missouri, and four 
that did not: California, Mississippi, Texas, and Utah) to interview 
FMCSA Division and State Partner officials as well as industry groups 
and some carriers. (See table 8 for criteria we used to select these 
states.) We collected and reviewed other CSA implementation and 
background documentation during these visits. (See table 9 for agency 
and industry organizations we interviewed during state visits.) 

Table 8: Criteria for State Selection: 

Criterion: Participation in the CSA pilot; 
Application: Two states participated in the first phase of the pilot 
test, two states participated in the second phase, and four states did 
not participate in the pilot test; 
Reason: States could have different perspectives on CSA depending on 
whether they participated in the pilot. 

Criterion: Data quality; 
Application: All eight states had a crash data quality ranking from 
FMCSA of 0-3 (0 being the best ranking. UMTRI previously evaluated the 
crash data quality of seven of the eight states; four of these were 
conducted in 2006 or later. Data correlation between the Motor Carrier 
Management Information System (MCMIS) and the state, per UMTRI; 
Reason: The quality of a state's crash data could influence its 
implementation of CSA. 

Criterion: Use of FMCSA's Aspen software; 
Application: Seven of the eight states use FMCSA's Aspen software, 
which facilitates uploading of inspection data to the MCMIS database; 
Reason: Use of Aspen facilitates data sharing with FMCSA could 
influence a state's ability to implement CSA. 

Criterion: Level of truck activity; 
Application: Three states had higher truck activity in comparison with 
other states, two had similar truck activity, and two had lower truck 
Reason: Different levels of truck activity could impact CSA 

Criterion: Recommendations from industry associations; 
Application: Six states were recommended to us by various industry 
Reason: Industry associations recommended we visit particular states 
for a variety of reasons. 

Criterion: Use of Department of Transportation (USDOT) numbers to 
identify and track intrastate carriers; 
Application: Six states use USDOT numbers for intrastate carriers; 
Reason: States that use the USDOT number for intrastate carriers may 
coordinate better with FMCSA. 

Criterion: Geographic location; 
Application: States were dispersed across most of CVSA's five regions: 
one state in Region I, three in Region II, two in Region III, and two 
in Region IV; 
Reason: Geographic diversity. 

Source: GAO. 

[End of table] 

Table 9: Federal and State Agencies and Organizations Interviewed 
During State Visits: 

State: California; 
Agency or organization: 
FMCSA California Division;
California Highway Patrol;
California Trucking Association. 

State: Georgia; 
Agency or organization: 
FMCSA Georgia Division;
Georgia Department of Public Safety;
Georgia Motor Trucking Association. 

State: Maryland; 
Agency or organization: 
FMCSA Maryland Division;
Maryland State Police;
Maryland Department of Transportation;
Maryland Motor Truck Association. 

State: Minnesota; 
Agency or organization: 
FMCSA Minnesota Division;
Minnesota State Patrol;
Minnesota Department of Transportation;
Minnesota Trucking Association. 

State: Mississippi; 
Agency or organization: 
FMCSA Mississippi Division;
Mississippi Department of Public Safety;
Mississippi Trucking Association. 

State: Missouri; 
Agency or organization: 
FMCSA Missouri Division;
Missouri Department of Transportation;
Missouri State Highway Patrol;
Missouri Trucking Association. 

State: Texas; 
Agency or organization: 
FMCSA Texas Division;
Texas Department of Public Safety;
Texas Motor Transportation Association. 

State: Utah; 
Agency or organization: 
FMCSA Utah Division;
Utah Department of Transportation;
Utah Highway Patrol;
Utah Trucking Association. 

Source: GAO. 

[End of table] 

To obtain information on motor carriers' knowledge of and experiences 
with CSA, we selected a nongeneralizable random sample of motor 
carriers from the Motor Carrier Management Information System (MCMIS) 
carrier census file and conducted brief, structured telephone 
interviews. We screened the population from which we selected the 
sample to remove foreign carriers and those carriers that had not 
updated their census (MCS-150) forms with FMCSA in the prior 2 years. 
We divided the carriers into three size categories--small, medium, and 
large--based on the number of vehicles associated with the company and 
randomly selected a group of carriers within each size category to 
participate in the structured interviews. During the interviews, we 
asked about the interviewees' knowledge and understanding of CSA; 
interviewees were owners, safety managers, or others who would have 
knowledge of a carrier's safety practices and performance. We obtained 
responses from 55 motor carriers out of the 270 we attempted to 
contact.[Footnote 72] 

To determine CSA's potential to improve safety, we analyzed FMCSA 
documents describing the design and function of the Safety Measurement 
System (SMS), how the severity of violations were weighted, and other 
design documentation as it was released, particularly comparing the 
SMS with SafeStat. We also analyzed UMTRI's pilot test study findings. 
We reviewed UMTRI's statistical methodology and its reliability 
assessment of the FMCSA data used for the study and determined that 
the results of UMTRI's pilot evaluation study were sufficiently 
reliable for our purposes. We obtained a copy of the May 2011 MCMIS 
inspection data, upon which five publicly available Behavior Analysis 
and Safety Improvement Categories (BASIC) scores for carriers were 
based, and analyzed it to determine the extent to which motor carriers 
lacked a sufficient number of roadside inspections for measurement 
under the BASICs in SMS. We electronically tested the data for 
completeness and coding accuracy, and found it sufficiently reliable 
for the purposes of our engagement. 

We also analyzed the function of FMCSA's Inspection Selection System 
software, which is designed to select trucks for inspection and 
thereby guides data collection for the SMS. We did not model the SMS 
in order to test its function ourselves, as it was modified several 
times during the course of our review. During our state visits, we 
also visited weigh stations or other truck inspection sites to 
interview inspectors about how they select trucks for inspection and 
how CSA has affected their work, and the data they obtain during 
inspections. We observed truck inspections during these visits. We 
also obtained information on crash data quality by analyzing studies 
UMTRI conducted on states' MCMIS crash data reliability as well as 
FMCSA's publicly available crash data evaluation tools. 

We conducted this performance audit from June 2010 to September 2011, 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objectives. We believe 
that the evidence obtained provides a reasonable basis for our 
findings and conclusions based on our audit objectives. 

[End of section] 

Appendix II: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Susan Fleming (202 512-2834): 

Staff Acknowledgments: 

In addition to the individual named above, Ed Laughlin, Assistant 
Director; Lynn Filla-Clark, Analyst-in-Charge; Carl Barden; Lauren 
Calhoun; Alison Hoenk; Delwen Jones; Elke Kolodinski; Kirsten Lauber, 
Sara Ann Moessbauer; Rebecca Rygg, Amy Rosewarne; and Larry Thomas 
made key contributions to this report. 

[End of section] 


[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 10 passengers (not including the driver). 

[2] The number of fatalities ranged from 5,116 in 2007 to 3,619 in 
2009, the most recent years for which data are available. The number 
of injuries ranged from 124,000 in 2007 to 93,000 in 2009. 

[3] FMCSA was not created until 2000. However, its duties and 
activities were formerly part of the Federal Highway Administration, 
which implemented SafeStat in 1995 but began using it to track motor 
carriers in 1997. 

[4] See GAO, Motor Carrier Safety: A Statistical Approach Will Better 
Identify Commercial Carriers That Pose High Crash Risks Than Does the 
Current Federal Approach, [hyperlink,] (Washington, D.C.: June 11, 
2007), and Motor Carrier Safety: Federal Safety Agency Identifies Many 
High-Risk Carriers but Does Not Assess Maximum Fines as Often as 
Required by Law, [hyperlink,] 
(Washington, D.C.: Aug. 28, 2007). 

[5] Compliance reviews covered all aspects of a carrier's operations 
and, consequently, were very labor intensive. 

[6] FMCSA originally called the program the Comprehensive Safety 
Analysis 2010 but changed it to Compliance, Safety and Accountability 
effective December 2010. For purposes of this report, we will refer to 
it as Compliance, Safety and Accountability (CSA). 

[7] Obligations from fiscal year 2007 through 2010. 

[8] This direction is contained in the Senate Committee Report, S. 
Rep. No. 111-69, at 60 (2009), as approved by the conference committee 
in the Joint Explanatory Statement accompanying the Consolidated 
Appropriations Act, 2010, Pub. L. No. 111-117, Division A. 

[9] See GAO, Motor Carrier Safety: FMCSA Has Devoted a Small but 
Increasing Amount of Resources to Develop the Compliance, Safety, 
Accountability Program but Is Requesting a Significant Increase for 
Full Implementation, [hyperlink,] (Washington, D.C.: Feb. 25, 

[10] The size of motor carriers can vary widely, from very small, 
owner-operated motor carriers with only one vehicle to very large 
motor carriers with thousands of vehicles. 

[11] Only interstate motor carriers are within FMCSA's jurisdiction; 
intrastate motor carriers are not. 

[12] FMCSA employs full-time vehicle inspectors on the southern border 
of the United States. In addition, all FMCSA safety investigators, 
safety auditors, and inspectors must conduct a minimum number and 
certain types of inspections annually to maintain certification. 

[13] Under SafeStat, FMCSA used compliance reviews to assign motor 
carriers safety ratings of satisfactory, conditional, or 

[14] As discussed later in this report, the Crash Indicator and Cargo- 
Related BASICs are not publicly available. 

[15] FMCSA's MCMIS is composed of motor carrier and driver performance 
data including inspection and compliance review results, enforcement 
data, state-reported crashes, and motor carrier census data. 

[16] [hyperlink,], [hyperlink,]. 

[17] According to FMCSA, information technology systems have been 
modified and now provide the capacity to issue and track Notices of 

[18] As mentioned previously, FMCSA can currently issue a carrier 
safety fitness determination, but it must have conducted an On-site 
Comprehensive Investigation before doing so. However, FMCSA can 
propose an adverse safety rating based on a Focused On-site 

[19] FMCSA plans to issue a Notice of Proposed Rulemaking (NPRM) by 
the end of calendar year 2011 and hopes to have it finalized within 18 

[20] For this report, we will refer to the operational-model test as 
the "pilot test." 

[21] Under SafeStat, if a carrier was considered "good" it would have 
no rating at all. For carriers not considered as "good," "A" was 
considered the worst rating while "G" was considered the best rating. 
A and B rated carriers as well as a few other categories of carriers 
were automatically excluded from the test group eligible for the CSA 
monitoring and intervention protocols. 

[22] U.S. Department of Transportation, Paul E Green and Daniel 
Blower, Evaluation of the CSA 2010 Operational Model Test, University 
of Michigan Transportation Research Institute, FMCSA-RRA-11-019 
Washington, D.C.: August 2011. We discuss the results of the UMTRI 
evaluation later in this report. 

[23] [hyperlink,]. 

[24] For fiscal year 2011, FMCSA's other priority rulemakings include: 
(1) Restricting the Use of Cellular Phones, (2) Hours-of-Service, (3) 
Electronic On-Board Recorders and Hours of Service Supporting 
Documents, and (4) National Registry of Certified Medical Examiners. 

[25] See FMCSA, DataQs User Guide and Manual: Best Practices for State 
Agency Users, (Washington, D.C.: January 2011). 

[26] FMCSA has implemented all of the interventions in the nine pilot 
states and Alaska. We will refer to FMCSA's implementation in the 
remaining 40 states as implementing CSA "nationwide." 

[27] Additionally, FMCSA has begun investigating drivers, including 
drivers with potentially serious violations, known as Red Flag Driver 
Violations, and using the Driver Safety Measurement System (DSMS), 
which measures drivers on BASICs similar to those used to measure 
motor carries. Red Flag Drivers and DSMS are discussed in more detail 
later in this report. 

[28] FMCSA officials noted that, while the Notice of Violation was 
available prior to CSA, the agency rarely used it. They expect to use 
it much more frequently under CSA. 

[29] FMCSA used different technology, the Comprehensive Safety 
Information System (CSI), for these interventions in the pilot states. 
However, CSI was designed specifically for the pilot and does not have 
the capacity to serve all states. FMCSA plans to phase that technology 
out after its new technology, Sentri, is completed. 

[30] FMCSA intends for Sentri to ultimately combine the functionality 
from all of FMCSA's legacy field systems and streamline existing 
workflow processes by combining roadside inspection, investigative, 
and enforcement functions into a single interface. FMCSA expects that 
Sentri will replace all of its legacy field systems. 

[31] According to FMCSA, its information technology office has also 
adopted the Office of Management and Budget's TechStat model for more 
effective information technology portfolio management and FMCSA is 
finalizing a new information technology governance framework and 
policy to address programs such as CSA. 

[32] GAO, Census Bureau: Important Activities for Improving Management 
of Key 2010 Decennial Acquisitions Remain to be Done, [hyperlink,] (Washington, D.C.: Mar. 1, 

[33] GAO, Motor Carrier Safety: The Federal Motor Carrier Safety 
Administration Has Developed a Reasonable Framework for Managing and 
Testing Its Comprehensive Safety Analysis 2010 Initiative, [hyperlink,] (Washington, D.C.: Dec. 20, 

[34] We classified carriers with one power unit as small carriers, 2 
to 10 as medium carriers, and 11 or more as large carriers. See 
appendix I for additional information. 

[35] [hyperlink,]. 

[36] [hyperlink,]. According 
to FMSA, the 98 full-time positions equate to 49 full-time equivalent 
positions that are annualized at a rate of 50 percent since not all 
personnel will be on board at the beginning of the fiscal year and 
will instead be added incrementally. 

[37] Intervention managers analyze reports generated by CSA to 
determine the type of intervention warranted for specific carriers, 
and assign them to investigators. 

[38] The other staff FMCSA requested included six intervention 
managers, five investigative assistants, four litigation attorneys, 
one enforcement attorney, and one adjudication attorney. 

[39] GAO, Federal Aviation Administration: Agency Is Taking Steps to 
Plan for and Train Its Technician Workforce, but a More Strategic 
Approach Is Warranted, [hyperlink,] (Washington, D.C.: Oct. 22, 

[40] GAO, Architect of The Capitol: Management and Accountability 
Framework Needed for Organizational Transformation, [hyperlink,] (Washington, D.C.: Jan. 17, 

[41] GAO, Rail Safety: Federal Railroad Administration Should Report 
on Risks to the Successful Implementation of Mandated Safety 
Technology, [hyperlink,] 
(Washington, D.C.: Dec. 15, 2010). 

[42] GAO, Intercity Passenger Rail: Amtrak's Management of Northeast 
Corridor Improvements Demonstrates Need for Applying Best Practices, 
[hyperlink,] (Washington, D.C.: 
Feb. 27, 2004). The need to address risks early, particularly risks 
associated with a project's cost and schedule, has long been part of 
our work to assess efforts related to major capital investments. See 
GAO, Executive Guide: Leading Practices in Capital Decision-Making, 
[hyperlink,] (Washington, 
D.C.: December 1998). 

[43] The current reauthorization expired in 2009 but has been extended 
several times; the most recent extension will expire on March 31, 2012 
Pub. L. No.112-30, 125 Stat. 342 (2011). 

[44] Red Flag Driver Violations include violations such as: operating 
a commercial motor vehicle with more than one driver's license or 
without a valid commercial driver's license; unqualified driver; 
driver uses or is in possession of alcohol or drugs; and driving after 
being declared out of service or operating an out-of-service vehicle. 

[45] FMCSA implemented PSP in May 2010. PSP allows commercial motor 
carrier companies to electronically access driver inspection and crash 
records as a part of the hiring process. 

[46] FMCSA, Department of Transportation, Report to Congress on the 
Large Truck Causation Study, MC-R/MC-RIA, (Washington, D.C.: November 

[47] The SafeStat system measured carrier safety performance in four 
safety evaluation areas: Accident, Driver, Vehicle, and Safety 
Management. See [hyperlink,] 
for a more detailed evaluation of this methodology for identifying 
carriers which posed a high crash risk. 

[48] Provided the motor carrier has a sufficient minimum number of 
roadside inspections. The BASICs and Crash Indicator in SMS have 
minimum data requirements; carriers that do not meet them are not 
ranked for safety performance. 

[49] For SMS, UMTRI found 44,881 carriers that exceeded the threshold 
in one or more BASICs with February 2008 MCMIS data from a sample of 
473,847 carriers active in states not participating in the CSA field 
test. We found 44,685 carriers with a ranking of A to G when analyzing 
nationwide MCMIS data from June 2004. See GAO-07-585 for a description 
of how SafeStat assigned rankings of A to G to carriers with scores 
that exceeded the threshold in one or more of the four safety 
evaluation areas. 

[50] As stated, under SafeStat, if a carrier was considered "good," it 
would have no rating at all. "A" was considered the worst while "G" 
was considered the best. 

[51] Annualizing the total number of Warning Letters for the first 6 
months of 2011 and the 8-month totals for the On-site Focused and full 
compliance reviews gives a total estimate of over 52,000 motor carrier 
safety interventions for the fiscal year. By way of comparison, FMCSA 
and its state partners completed 16,512 full compliance reviews under 
SafeStat in all of fiscal year 2009. 

[52] In their evaluation of the CSA operational model, UMTRI 
determined that the full application of SMS would allow FMCSA to 
increase the number of carriers that received a safety intervention 
from 3.3 percent under SafeStat to over 9 percent of the active fleet. 

[53] The sixth BASIC that relies upon roadside inspection data is the 
Controlled Substances/Alcohol BASIC. However, the minimum data 
requirement for this BASIC is determined by number of safety 
violations. The minimum number of safety violations for a ranking 
under this BASIC is one. 

[54] The Controlled Substances/Alcohol BASIC is based upon the number 
of violations and has a minimum of only one inspection (albeit one 
with a violation). Motor carriers must have a minimum of two 
applicable crashes to be rated under the Crash Indicator. 

[55] Under federal law, buses cannot be ordered into an inspection 
station for an inspection except in the case of an imminent or obvious 
safety hazard. 49 U.S.C. § 31102(b)(1)(X). Trucks from Mexico and 
Canada operating in the United States are subject to inspection. See 
49 U.S.C. § 31144(a). See also 49 C.F.R. part 365, subpart E. 

[56] A carrier cannot be identified for intervention by CSA unless it 
is ranked in the BASICs by the SMS. 

[57] ISS is designed to review a carrier's past performance and make a 
specific recommendation of "inspect," "optional," or "pass." 

[58] Other similar products used in the United States are NorPass, 
Greenlight, and NCPass, covering nine more states. 

[59] Thirty states are registered with PrePass. When a carrier 
subscribes to PrePass, it allows PrePass access to all roadside 
inspection data as well as other proprietary safety data. Carriers 
equip their trucks and states equip their weigh stations with 
transponders. Based on the crash risk and safety performance of the 
subscribing carrier, inspectors in the weigh station receive 
notification of the inspection recommendation for the truck. A 
"bypass" recommendation enables the driver to proceed without entering 
the weigh station. 

[60] According to FMCSA officials, the agency has made significant 
investments in technologies that can help identify at-risk carriers 
such as license plate readers. 

[61] Sometimes drivers can fix the situation by shifting cargo 
themselves, releasing the truck from out of service status. Otherwise 
the driver must wait for assistance before the truck can resume its 

[62] State commercial motor vehicle inspectors take training to 
receive certifications to conduct inspections of different aspects of 
commercial motor vehicle safety. The certification level of the 
inspectors on hand dictates the types of inspections that may be 
conducted at an inspection station. 

[63] To maintain certification for a certain level of inspection, 
inspectors must perform a certain number of them in a 12-month period. 

[64] State officials must include mitigation measures used to prevent 
trucks from bypassing weigh stations in their annual Commercial 
Vehicle Safety Plans, which helps FMCSA determine states' Motor 
Carrier Safety Assistance Program (MCSAP) funding levels. 

[65] Unless a driver is instructed to bypass a weigh station, all 
trucks passing an open weigh station must enter for inspection. 

[66] Four states were evaluated for the full 30 months of the pilot 
program; results from five states that joined the pilot program later 
were only used for supplementary analysis. 

[67] GAO, The Results Act: An Evaluator's Guide to Assessing Agency 
Annual Performance Plans, [hyperlink,] (Washington, D.C.: April 
1998); VA Health Care: VA Should Better Monitor Implementation and 
Impact of Capital Asset Alignment Decisions, [hyperlink,] (Washington, D.C.: Mar. 21, 
2007); NextGenAir Transportation System: FAA's Metrics Can Be Used to 
Report on Status of Individual Programs, but Not of Overall NextGen 
Implementation or Outcomes, [hyperlink,] (Washington, D.C.: July 27, 

[68] GAO, FAA Airspace Redesign: An Analysis of the New York/New 
Jersey/Philadelphia Project, [hyperlink,] (Washington, D.C.: July 31, 

[69] This direction is contained in the Senate Committee Report, S. 
Rep. No. 111-69, at 60 (2009), as approved by the conference committee 
in the Joint Explanatory Statement accompanying the Consolidated 
Appropriations Act, 2010, Pub. L. No. 111-117, Division A. 

[70] U.S. Department of Transportation, Paul E Green and Daniel 
Blower, Evaluation of the CSA 2010 Operational Model Test, University 
of Michigan Transportation Research Institute, FMCSA-RRA-11-019 
Washington, D.C.: August 2011. FMCSA referred to this test as an 
operational model test. For purposes of this report, we use the term 
"pilot" test. The pilot test included two phases. Four states-- 
Colorado, Georgia, Missouri, and New Jersey--participated in the first 
phase; five states--Delaware, Kansas, Maryland, Minnesota, and Montana--
participated in the second phase. 

[71] GAO reviewed UMTRI's statistical methodology and its reliability 
assessment of the FMCSA data used for the study and determined that 
the results of UMTRI's pilot evaluation study were sufficiently 
reliable for our purposes. 

[72] Many of the carriers we contacted are relatively small businesses 
and, as a result, posed a greater chance that an appropriate official 
may not have been available when we called. Consequently, we increased 
the number of carriers selected to ensure that we completed a 
reasonable number of calls. If a call to a carrier was not answered, 
an appropriate official was not available, or a carrier declined to 
participate, we moved on to the next carrier on the list. 

[End of section] 

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