Motor Carrier Safety: Preliminary Information on the Federal	 
Motor Carrier Safety Administration's Efforts to Identify and	 
Follow Up with High-risk Carriers (11-JUL-07, GAO-07-1074T).	 
                                                                 
The Federal Motor Carrier Safety Administration (FMCSA) has the  
primary federal responsibility for reducing crashes involving	 
large trucks and buses. FMCSA uses its "SafeStat" tool to select 
carriers for reviews for compliance with its safety regulations  
based on the carriers' crash rates and prior safety violations.  
FMCSA then conducts these compliance reviews and can place	 
carriers out of service if they are found to be operating	 
unsafely. This statement is based on a recent report (GAO-07-585)
and other nearly completed work. GAO assessed (1) the extent to  
which FMCSA identifies carriers that subsequently have high crash
rates, (2) how FMCSA ensures that its compliance reviews are	 
conducted thoroughly and consistently, and (3) the extent to	 
which FMCSA follows up with carriers with serious safety	 
violations. GAO's work was based on a review of laws, program	 
guidance, and analyses of data from 2004 through early 2006.	 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-07-1074T					        
    ACCNO:   A72507						        
  TITLE:     Motor Carrier Safety: Preliminary Information on the     
Federal Motor Carrier Safety Administration's Efforts to Identify
and Follow Up with High-risk Carriers				 
     DATE:   07/11/2007 
  SUBJECT:   Accident prevention				 
	     Accidents						 
	     Automated risk assessment				 
	     Comparative analysis				 
	     Data collection					 
	     Data integrity					 
	     Evaluation methods 				 
	     Internal controls					 
	     Motor carriers					 
	     Motor vehicle safety				 
	     Program evaluation 				 
	     Risk management					 
	     Safety regulation					 
	     Safety standards					 
	     Systems evaluation 				 
	     Traffic accidents					 
	     Policies and procedures				 
	     FMCSA Safety Status Measurement System		 

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GAO-07-1074T

   

     * [1]Background
     * [2]SafeStat Identifies Many High-risk Carriers, but Enhancement

          * [3]Using Either a Statistical Approach or Modifying Existing Sa
          * [4]FMCSA Is Considering Replacing SafeStat with a New Tool by 2

     * [5]FMCSA's Management of Its Compliance Reviews Promotes Thorou

          * [6]FMCSA Communicates Its Compliance Review Policies and Proced
          * [7]FMCSA Investigators Use an Information System to Document th
          * [8]FMCSA Monitors the Performance of Its Compliance Reviews and
          * [9]Each of the Major Applicable Areas of the Safety Regulations

     * [10]FMCSA Follows Up with Many Carriers with Serious Safety Viol

          * [11]FMCSA Followed Up with Almost All Carriers That Received a P
          * [12]FMCSA Monitors Carriers to Identify Those That Are Violating
          * [13]FMCSA Conducted Compliance Reviews on About Half of All High
          * [14]FMCSA Does Not Assess Maximum Fines for All the Violations R

     * [15]GAO Contacts and Staff Acknowledgement
     * [16]Related GAO Products

          * [17]Order by Mail or Phone

Testimony

Before the Subcommittee on Highways and Transit, Committee on
Transportation and Infrastructure, House of Representatives

United States Government Accountability Office
GAO

For Release on Delivery
Expected at 2:00 p.m. EDT
Wednesday, July 11, 2007

MOTOR CARRIER SAFETY

Preliminary Information on the Federal Motor Carrier Safety
Administration's Efforts to Identify and Follow Up with High-risk Carriers

Statement of Susan A. Fleming, Director
Physical Infrastructure Issues

GAO-07-1074T

Mr. Chairman and Members of the Subcommittee:

We appreciate the opportunity to participate in this hearing to discuss
the Federal Motor Carrier Safety Administration's (FMCSA) oversight of
motor carriers that pose high crash risks. This is an important issue
because each year about 5,500 people die as a result of crashes involving
large commercial trucks or buses,^1 and about 160,000 more people are
injured. These crashes may result from errors by truck, bus, or passenger
vehicle drivers; vehicle condition; and other factors. Effective oversight
is important because of the large size of the motor carrier industry (over
700,000 carriers are registered with FMCSA^2) compared to the number of
compliance reviews--reviews of carriers at their bases of operations for
compliance with FMCSA's safety regulations--that FMCSA and its state
partners are able to conduct each year (about 15,000 in 2006). As a
result, it is crucial that FMCSA identify the most unsafe carriers so that
the carriers either improve their operations or are put out of service.

My remarks are based on work we have recently completed for this
Subcommittee and the full committee^3 and on the preliminary results of
our ongoing work for the Chairman of the full committee. This latter work
is nearing completion, and we expect to report on our final results on
these and other topics later this summer. Specifically, we have been
assessing (1) the extent to which FMCSA identifies carriers that
subsequently have high crash rates, (2) how FMCSA ensures that its
compliance reviews are conducted thoroughly and consistently, and (3) the
extent to which FMCSA follows up with carriers with serious safety
violations.

Our work was based on a review of laws, regulations, program guidance,
analyses of data, and discussions with FMCSA. To determine the extent to
which FMCSA identifies carriers that subsequently have high crash rates,
we analyzed data from FMCSA's Motor Carrier Management Information System
for its June 2004 assessment of carriers and compared it to data on
crashes the carriers experienced over the subsequent 18 months (July 2004
through December 2005).^4 To assess how FMCSA ensures that its compliance
reviews are completed thoroughly and consistently, we identified our key
internal control standards related to the communication of policy,
documentation of results, and monitoring and reviewing of activities and
findings.^5 We gathered information on these key internal controls through
discussions with FMCSA officials in its headquarters as well as in 7 of
FMCSA's 52 field division offices and reviews of policy documents and
reports. To assess the extent to which FMCSA follows up with carriers with
serious violations and assesses maximum fines in certain situations, we
reviewed regulations and FMCSA policies directing how FMCSA must follow up
and track these violators, analyzed data to determine if FMCSA had met
these requirements, and held discussions with FMCSA officials. As part of
our review, we assessed internal controls and the reliability of FMCSA's
data on motor carriers' safety history and compliance review and
enforcement activities pertinent to this effort. While there are known
problems with the quality of the crash data reported to FMCSA, we
determined that the data were sufficiently reliable for our use, which was
to assess whether different approaches to categorizing carriers could lead
to better identification of carriers that subsequently have high rates of
crashes. We conducted our work from February 2006 through July 2007 in
accordance with generally accepted government auditing standards.

^1Large 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 8 people.

^2This figure includes an unidentified number of carriers that are
registered but are no longer in business. Carriers continually enter and
exit the industry. Since 1998, the industry has increased in size by an
average of about 29,000 interstate carriers per year.

^3GAO, Motor Carrier Safety: A Statistical Approach Will Better Identify
Commercial Carriers That Pose High Crash Risks Than Does the Current
Federal Approach, [18]GAO-07-585 (Washington, D.C.: June 11, 2007).

By and large, FMCSA does a good job of identifying carriers that pose high
crash risks for subsequent compliance reviews, ensuring the thoroughness
and consistency of those reviews, and following up with high-risk
carriers. That being said, we have identified areas that could be
improved. In summary:

^4FMCSA requires that states report crashes within 90 days. Sometimes
states report crashes late. To allow for this occurrence, we analyzed data
on crashes occurring from July 2004 through December 2005 that may have
been reported as late as June 2006.

^5GAO, Internal Control: Standards for Internal Control in the Federal
Government, [19]GAO/AIMD-00-21 .3.1 (Washington, D.C.: Nov. 1999). In
assessing the extent to which FMCSA's management of its compliance reviews
is consistent with our internal controls, we were not able to verify the
statements made by FMCSA and state officials and investigators about their
performance and management of compliance reviews because doing so was not
practicable given our time and resource constraints.

           o Overall, the data-driven model that FMCSA uses to identify
           carriers that pose high crash risks--the Motor Carrier Safety
           Status Measurement System (SafeStat)--does a good job of
           identifying carriers that pose high crash risks. In this regard,
           we found that it is nearly twice as effective (83 percent better)
           as random selection in identifying carriers that pose high crash
           risks. Thus, in our view, it has value for improving safety.
           However, we believe that its effectiveness could be improved
           through either of two enhancements that we analyzed. One
           enhancement entails applying a statistical approach, called the
           negative binomial regression model, to the four SafeStat safety
           evaluation areas (accidents and driver, vehicle, and safety
           management violations) instead of its current approach, which
           relies on expert judgment to assign weights to each of the four
           areas.^6 The other enhancement--the results of which are
           preliminary--uses the existing SafeStat overall design but places
           greater weight on carriers that scored among the worst in the
           accident safety evaluation area. Both enhancements performed
           better than the current SafeStat approach. For example, the
           regression approach identified carriers that had twice as many
           crashes in the subsequent 18 months as the carriers the current
           SafeStat approach identified. We believe that the negative
           binomial regression model approach offers a greater potential for
           improving safety over the other enhancement that we analyzed and
           the current SafeStat approach because it provides for a systematic
           assessment of the relative contributions of accidents and driver,
           vehicle, and safety management violations rather than the use of
           expert judgment to apply weights to these areas. FMCSA agreed that
           our approach looks promising but believes that placing more
           emphasis on crashes is counterproductive, in part, because it
           would have to place less emphasis on compliance with its safety
           management, vehicle, and driver regulations. We disagree because
           the ultimate purpose of compliance reviews is to reduce the number
           and severity of truck and bus crashes, and high crash rates are
           stronger predictors of future crashes than is poor compliance with
           safety regulations.
           o Our preliminary assessment showed that FMCSA's management of its
           compliance reviews meets our standards for internal controls,
           thereby promoting thoroughness and consistency. FMCSA records its
           compliance review policies and procedures in an electronic
           operations manual and distributes the manual to investigators and
           managers. FMCSA also trains investigators on these policies and
           procedures. Investigators we spoke with found both the electronic
           manual and the training to be effective means of communicating
           policies and procedures. FMCSA and state investigators use an
           information system to document the results of the compliance
           reviews. This information system supports thoroughness and
           consistency by alerting investigators if they are not following
           key policies or if data appears suspect; the system also provides
           managers readily available data to review. For the most part,
           FMCSA and state investigators cover the nine major applicable
           areas of the safety regulations (e.g., driver qualifications and
           vehicle repair and maintenance) in 95 percent or more of
           compliance reviews, demonstrating thoroughness and consistency.
			  
^6Negative binomial regression is often used to model count data (e.g.,
crashes).

           o Our preliminary assessment showed that FMCSA follows up with
           many carriers with serious safety violations, but it does not
           assess maximum fines against all serious violators, as we believe
           is required by law. FMCSA followed up with at least 1,189 of 1,196
           carriers (99 percent) that received a proposed safety rating of
           unsatisfactory following compliance reviews completed in fiscal
           year 2005. For example, FMCSA found that 873 of these carriers
           made safety improvements and it placed 306 other carriers out of
           service. FMCSA monitors carriers to identify those that are
           violating out-of-service orders, but in fiscal years 2005 and
           2006, it cited only 26 of 768 carriers that its monitoring showed
           had a roadside inspection or crash while subject to an
           out-of-service order. An FMCSA official told us that some of the
           768 carriers, such as carriers that were operating intrastate,^7
           may not have been violating the out-of-service order and that
           FMCSA did not have enough resources to determine whether each of
           the carriers was violating an out-of-service order. Finally, we
           found that while FMCSA assesses maximum fines against carriers
           that repeat a serious violation, it does not, as we believe
           federal law requires, assess maximum fines against carriers with a
           pattern of serious violations. In addition, FMCSA assesses maximum
           fines only for the third instance of a violation. We read the
           statute as requiring FMCSA to assess the maximum fine if a serious
           violation is repeated once--not only after it is repeated twice.

           In our June report we recommended that FMCSA use a negative
           binomial regression model approach to identify carriers that pose
           high crash risks. We are considering making several
           recommendations based on our ongoing work, including that FMCSA
           assess maximum fines, as discussed above, in circumstances that we
           believe the law requires it to do so. Finally, we have also
           reported on other aspects of FMCSA's operations within the past 18
           months. These products are listed at the end of this statement.
			  
^7Except for carriers of hazardous materials, FMCSA does not have the
authority to prohibit motor carriers from operating intrastate.

           Background

           In the United States, commercial motor carriers account for less
           than 5 percent of all highway crashes, but these crashes result in
           about 13 percent of all highway deaths, or about 5,500 of the
           approximately 43,000 nationwide highway fatalities that occur
           annually. In addition, about 160,000 of the approximately 3.2
           million highway injuries per year involve motor carriers. While
           the fatality rate for trucks has generally decreased over the past
           30 years, it has been fairly stable since 2002. (See fig. 1.) The
           fatality rate for buses decreased slightly from 1975 to 2005, but
           it has more annual variability than the fatality rate for trucks
           due to a much smaller total vehicle miles traveled.

           Figure 1: Commercial Motor Vehicle Fatality Rate, 1975 to 2005

           Notes: Fewer buses are involved in fatal or non-fatal accidents
           than large trucks, but they tend to involve more people. The
           latest year for which data were available was 2005.

           FMCSA's primary mission is to reduce the number and severity of
           crashes involving large trucks and buses. FMCSA relies heavily on
           the results of compliance reviews to determine whether carriers
           are operating safely and, if not, to take enforcement action
           against them. FMCSA conducts these on-site reviews to determine
           carriers' compliance with safety regulations that address areas
           such as alcohol and drug testing of drivers, driver
           qualifications, driver hours of service, vehicle maintenance and
           inspections, and transportation of hazardous materials.

           FMCSA uses a data-driven analysis model called SafeStat to assess
           carriers' risks relative to all other carriers based on safety
           indicators, such as their crash rates and safety violations
           identified during roadside inspections and prior compliance
           reviews. A carrier's score is calculated based on its performance
           in four safety evaluation areas: accidents and driver, vehicle,
           and safety management violations. (See fig. 2.)

Figure 2: FMCSA's Safety Oversight Approach

FMCSA assigns categories to carriers ranging from A to H according to
their performance in each of the safety evaluation areas. (See table 1.)
Although a carrier may receive a value in any of the four safety
evaluation areas, the carrier receives a SafeStat score only if it is
deficient in two or more safety evaluation areas. The calculation used to
determine a motor carrier's SafeStat score is:

SafeStat Score = 2 x accident value + 1.5 x driver value + vehicle value +
safety management value

Table 1: SafeStat Categories

                                                            Priority for      
Category Condition                                       compliance review 
Deficient in two or more areas
A        Deficient in all 4 safety evaluation areas or   High              
            deficient in 3 safety evaluation areas that                       
            result in a weighted SafeStat score of 350 or                     
            more                                                              
B        Deficient in 3 safety evaluation areas that     High              
            result in a weighted SafeStat score of less                       
            than 350 or deficient in 2 safety evaluation                      
            areas that result in a weighted SafeStat score                    
            of 225 or more                                                    
C        Deficient in 2 safety evaluation areas that     Medium            
            result in a weighted SafeStat score of less                       
            than 225                                                          
Deficient in one area only
D        Deficient in the accident safety evaluation     Low               
            area (area value between 75-100)                                  
E        Deficient in the driver safety evaluation area  Low               
            (area value between 75-100)                                       
F        Deficient in the vehicle safety evaluation area Low               
            (area value between 75-100)                                       
G        Deficient in the safety management safety       Low               
            evaluation area (area value between 75-100)                       
Not deficient in any area
H        Not deficient in any of the safety evaluation   Low               
            areas                                                             

Source: GAO summary of FMCSA data.

Based on the results of a compliance review, FMCSA assigns the carrier a
safety rating of satisfactory, conditional, or unsatisfactory. The safety
rating, which is distinct from a carrier's SafeStat category, reflects
FMCSA's determination of a carrier's fitness to operate safely. FMCSA
issues out-of-service orders to carriers rated unsatisfactory, and these
carriers are not allowed to resume operating until they make improvements
that result in an upgraded safety rating. Carriers rated conditional are
allowed to continue operating, but FMCSA aims to conduct follow-up
compliance reviews on these carriers. Regardless of a carrier's safety
rating, FMCSA can assess a fine against a carrier with violations, and it
is more likely to assess higher fines when these violations are serious.

SafeStat Identifies Many High-risk Carriers, but Enhancements Could Identify
Carriers with Even Higher Risks

SafeStat identifies many carriers that pose a high risk for crashes and is
about twice as effective (83 percent) as randomly selecting carriers for
compliance reviews. As a result, it has value for improving motor carrier
safety. However, two enhancements that we analyzed could lead to FMCSA
identifying carriers that pose greater crash risks overall. These
approaches entail giving more weight to crashes than the current SafeStat
model does. FMCSA has concerns about these approaches, in part, because
placing more emphasis on accidents would require it to place less emphasis
on other types of problems. FMCSA recognizes that SafeStat can be
improved, and as part of its Comprehensive Safety Analysis 2010 reform
initiative--which is aimed at improving its processes for identifying and
dealing with unsafe carriers and drivers--the agency is considering
replacing SafeStat by 2010.

Using Either a Statistical Approach or Modifying Existing SafeStat
Categorization Rules Could Improve Identification of High-risk Carriers

In June 2007, we reported that FMCSA could improve SafeStat's ability to
identify carriers that pose high crash risks if it applied a statistical
approach, called the negative binomial regression model, to the four
SafeStat safety evaluation areas instead of its current approach.^8 We
used this approach to determine whether systematic analyses of data
through regression modeling offered improved results in identifying
carriers that pose high crash risks over FMCSA's model, which uses expert
judgment and professional experience to apply weights to each of the
safety evaluation areas. The negative binomial model results in a rank
order listing of carriers by crash risk and the predicted number of
crashes. This differs from SafeStat's current approach, which gives the
highest priority to carriers that are deficient in three or more safety
evaluation areas or that score over a certain amount--SafeStat categories
A and B. (See table 1.)

The other enhancement that we analyzed--the results of which are
preliminary--utilized the existing SafeStat overall design but examined
the effect of providing greater priority to carriers that scored among the
worst 5 percent of carriers in the accident safety evaluation area
(SafeStat category D). We chose this approach because we found that while
the driver, vehicle, and safety management evaluation areas are correlated
with the future crash risk of a carrier, the accident evaluation area
correlates most with future crash risk.^9 This approach would retain the
overall SafeStat framework and categorization--categories A through G for
carriers with safety problems--but would substitute carriers in category D
(the accident category) for carriers in categories A and B that have
either (1) lower overall SafeStat scores or (2) lower accident area
scores.

^8 [20]GAO-07-585 .

We compared the performance of our regression model approach and placing
greater weight on carriers that scored among the worst 5 percent of
carriers in SafeStat category D to the current SafeStat model. The
comparison showed that both these approaches performed better than the
current SafeStat approach. (See table 2.) For example, the regression
model approach identified carriers with an average of 111 crashes per
1,000 vehicles over an 18-month period compared with the current SafeStat
approach, which identified carriers for compliance reviews with an average
of 102 crashes per 1,000 vehicles. This 9 percent improvement would have
enabled FMCSA to identify carriers with almost twice as many crashes in
the following 18 months as those carriers identified in its current
approach (19,580 v. 10,076).^10 Placing greater emphasis on carriers in
category D provided superior results to the current SafeStat approach both
in terms of identifying carriers with higher crash rates (from 6 to 9
percent higher) and greater numbers of crashes (from about 600 to 800
more). In addition, the regression approach performed at least as well as
placing greater emphasis on carriers in category D in terms of identifying
carriers with the highest crash rates and much better in identifying
carriers with the greatest number of crashes.

^9These results corroborate studies performed by the Volpe National
Transportation Systems Center and Oak Ridge National Laboratory. See
[21]GAO-07-585 .

^10On average, the negative binomial regression model approach identified
larger motor carriers than did SafeStat, which is how a 9 percent increase
in the crash rate translated into 9,500 additional crashes.

Table 2: Regression Model Approach Compared With Refined Categorizations
of SafeStat Results and with Current SafeStat Approach

                                                            Number of crashes 
Approach                                    Crash rate^a      in 18 months 
Regression model approach                          111.4            19,580 
Refined categorization alternative 1:                                      
substitute SafeStat category D (accident)                                  
carriers for category A and B carriers with                                
the lowest overall SafeStat scores                 111.0            10,682 
Refined categorization alternative 2:                                      
substitute SafeStat category D (accident)                                  
carriers for category A and B carriers with                                
the lowest accident area scores                    107.8            10,887 
Current SafeStat approach                          102.2            10,076 

Source: GAO analysis of FMCSA data.

aCrash rates are crashes per 1,000 vehicles in the 18 months following the
June 2004 SafeStat categorization.

Note: The relationship between number of crashes and the crash rate is not
linear because the different analyses identified carriers with different
fleet sizes as posing a high crash risk.

Because both the approaches that we analyzed would identify a larger
number of carriers that pose high crash risks, FMCSA would choose the
number of carriers to review based on the resources available to it, much
as it currently does.

We believe that our statistically based regression model is preferable to
placing greater weight on carriers in category D because it provides for a
systematic assessment of the relative contributions of accidents and
driver, vehicle, and safety management violations. We recommended that
FMCSA adopt such an approach. By its very nature the regression approach
looks for the "best fit" in identifying the degree to which prior
accidents and driver, vehicle, and safety management violations identify
the likelihood of carriers having crashes in the future, compared to the
current SafeStat approach, in which the relationship among the four
evaluation areas is based on expert judgment. In addition, because the
regression model could be run monthly--as is the current SafeStat
model--any change in the degree to which accidents and driver, vehicle,
and safety management violations better identify future crashes will be
automatically considered as different weights to the four evaluation areas
are assigned. This is not the case with the current SafeStat model, in
which the evaluation area weights generally remain constant over time.^11

FMCSA agreed that use of a negative binomial regression model looks
promising but officials said that the agency believes that placing more
emphasis on the accident area would be counterproductive. First, FMCSA is
concerned that this would require placing correspondingly less emphasis on
the types of problems the compliance review is designed to address so that
crashes can be reduced (i.e., the lack of compliance with safety
regulations related to drivers, vehicles, and safety management that is
captured in the other evaluation areas). Along this line, FMCSA said that
compliance reviews of carriers in SafeStat category D have historically
resulted in fewer serious violations than compliance reviews of carriers
in SafeStat category A or B. We agree with FMCSA that the use of the
approaches that we are discussing here today could tilt enforcement
heavily toward carriers with high crash rates and away from carriers with
compliance issues. We disagree, however, that this would be
counterproductive. We found that while driver, vehicle, and safety
management evaluation area scores are correlated with the future crash
risk of a carrier, high crash rates are a stronger predictor of future
crashes than poor compliance with safety regulations. FMCSA's mission--as
well as the ultimate purpose of compliance reviews--is to reduce the
number and severity of truck and bus crashes.

Second, FMCSA officials said that placing more emphasis on the accident
evaluation area would increase emphasis on the least reliable type of data
used by SafeStat--crash data--and in so doing, it would increase the
sensitivity of the results to crash data quality issues. However, in June
2007 we reported that FMCSA has made considerable efforts to improve the
reliability of crash data. The report also concluded that as FMCSA
continues its efforts to have states improve crash data, any sensitivity
of results from our statistically based model to crash data quality issues
should diminish.

FMCSA Is Considering Replacing SafeStat with a New Tool by 2010

As part of its Comprehensive Safety Analysis 2010, a reform initiative
aimed at improving its processes for identifying and dealing with unsafe
carriers and drivers, FMCSA is considering replacing SafeStat with a new
tool by 2010. The new tool could take on greater importance in FMCSA's
safety oversight framework because the agency is considering using the
tool's assessments of carriers' safety to determine whether carriers are
fit to continue operating. In contrast, SafeStat is primarily used now to
prioritize carriers for compliance reviews, and determinations of
operational fitness are made only after compliance reviews are completed.
FMCSA also plans to develop a tool to assess the safety status of
individual drivers, along with tools for dealing with unsafe drivers. Even
though FMCSA is considering replacing SafeStat, we believe that
implementing either of the approaches discussed in this statement would be
worthwhile because it would be relatively easy to do and result in
immediate safety benefits that could save lives.

^11The weights on the safety evaluation areas have remained unchanged
since September 1999, when the weight on the driver area was increased
from 1.0 to 1.5.

FMCSA's Management of Its Compliance Reviews Promotes Thoroughness and
Consistency

Our preliminary assessment is that FMCSA manages its compliance reviews in
a way that meets our standards for internal control, thereby promoting
thoroughness and consistency in the reviews.^12 It does so by establishing
compliance review policies and procedures through an electronic manual and
training, using an information system to document the results of its
compliance reviews, and monitoring performance. We also found that
compliance reviews cover most of the major areas of the agency's safety
regulations.

FMCSA Communicates Its Compliance Review Policies and Procedures through an
Electronic Manual and Training

FMCSA's communication of its policies and procedures related to conducting
compliance reviews meets our standards for internal control. These
standards state that an organization's policies and procedures should be
recorded and communicated to management and others within the entity who
need it and in a form (that is, for example, clearly written and provided
as a paper or electronic manual) and within a time frame that enables them
to carry out their responsibilities. FMCSA records and communicates its
policies and procedures electronically through its Field Operations
Training Manual, which it provides to all federal and state investigators
and their managers. The manual includes guidance on how to prepare for a
compliance review (for example, by reviewing information on the carrier's
accidents, drivers, and inspections), and it explains how this information
can help the investigator focus the compliance review. It also specifies
the minimum number of driver and vehicle maintenance records to be
examined and the minimum number of vehicle inspections to be conducted
during a compliance review. FMCSA posts updates to the manual that
automatically download to investigators and managers when they connect to
the Internet. In addition to the manual, FMCSA provides classroom training
to investigators and requires that investigators successfully complete
that training and examinations before they conduct a compliance review.
According to FMCSA officials, investigators then receive on-the-job
training, in which they accompany an experienced investigator during
compliance reviews. Investigators can also take additional classroom
training on specialized topics throughout their careers.

^12See [22]GAO/AIMD-00-21 .3.1.

FMCSA Investigators Use an Information System to Document the Results of
Compliance Reviews

FMCSA's documentation of compliance reviews meets our standards for
internal control. These standards state that all transactions and other
significant events should be clearly and promptly documented, and the
documentation should be readily available for examination. FMCSA and state
investigators use an information system to document the results of their
compliance reviews, including information on crashes and any violations of
the safety regulations that they identify. This documentation is readily
available to FMCSA managers, who told us that they review it to help
ensure completeness and accuracy. FMCSA officials told us that the
information system also helps ensure thoroughness and consistency by
prompting investigators to follow FMCSA's policies and procedures, such as
requirements to meet a minimum sample size. The information system also
includes checks for consistency and reasonableness and prompts
investigators when the information they enter appears to be inaccurate.
FMCSA said managers may assess an investigator's thoroughness by comparing
the rate of violations the investigator identified over the course of
several compliance reviews to the average rate for investigators in their
division office; a rate that is substantially below the average suggests
insufficient thoroughness.

FMCSA Monitors the Performance of Its Compliance Reviews and Has Taken Actions
to Address Identified Issues

FMCSA's performance measurement and monitoring of its compliance review
activities meet our standards for internal control. These standards state
that managers should compare actual performance to planned or expected
results and analyze significant differences. According to FMCSA and state
managers and investigators, the managers review all compliance reviews in
each division office and state to ensure thoroughness and consistency
across investigators and across compliance reviews. The investigators we
spoke with generally found these reviews to be helpful, and several
investigators said that the reviews helped them learn policies and
procedures and ultimately perform better compliance reviews.

In addition to assessing the performance of individual investigators,
FMCSA periodically assesses the performance of FMCSA division offices and
state agencies and conducted an agencywide review of its compliance review
program in 2002. According to officials at one of FMCSA's service centers,
the service centers lead triennial reviews of the compliance review and
enforcement activities of each division office and its state partner.
These reviews assess whether the division offices and state partners are
following FMCSA policies and procedures, and they include an assessment of
performance data for items such as the number of compliance reviews
conducted, rate of violations identified, and number of enforcement
actions taken. The officials said that some reviews identify instances in
which division offices have deviated from FMCSA's compliance review
policies but that only minor adjustments by the division offices are
needed. The officials also said that the service centers compile best
practices identified during the reviews and share these among the division
offices and state partners.

FMCSA's review also concluded that most investigators were not following
FMCSA's policy requiring them to perform vehicle inspections as part of a
compliance review if the carrier had not already received the required
number of roadside vehicle inspections.^13 Since conducting its 2002
review, FMCSA changed its policy so that inspecting a minimum number of
vehicles is no longer a strict requirement--if an investigator is unable
to inspect the minimum number of vehicles, he or she must explain why in
the compliance review report.^14

Each of the Major Applicable Areas of the Safety Regulations Is Consistently
Covered by Most Compliance Reviews

From fiscal year 2001 through fiscal year 2006, each of the nine major
applicable areas of the safety regulations was consistently covered by
most of the approximately 76,000 compliance reviews conducted by FMCSA and
the states. (See table 3.) For the most part, 95 percent or more of the
compliance reviews covered each major applicable area in the agency's
safety regulations.

^13The required number of inspections is based on the number of vehicles
operated by the carrier and subject to federal regulations.

^14An inspector would not be able to inspect the minimum number of
vehicles if, for example, fewer than the minimum number of vehicles were
available on-site for inspection.

Table 3: Percentage of Compliance Reviews for Fiscal Years 2001 through
2006 That Covered Each of the Major Applicable Areas of the Safety
Regulations

Regulatory area                                            Percent 
Procedures for handling and evaluating accidents                97 
Drivers' qualifications                                         96 
Drivers' hours of service                                       96 
Inspection, repair, and maintenance of vehicles                 96 
Drug and alcohol use and testing                                95 
Commercial driver's license standards                           95 
Driving of motor vehicles                                       94 
Minimum insurance coverage                                      90 
Vehicle parts and accessories necessary for safe operation      80 

Source: GAO analysis of FMCSA data.

An FMCSA official told us that not every compliance review is required to
cover these nine areas. For example, follow-up compliance reviews of
carriers rated unsatisfactory or conditional are sometimes streamlined to
cover only the one or a few areas of the regulations in which the carrier
had violations. As another example, minimum insurance coverage regulations
apply only to for-hire carriers and private carriers of hazardous
materials; they do not apply to private passenger and nonhazardous
materials carriers.

However, according to an FMCSA official, the area of these regulations
that had the lowest rate of coverage--vehicle parts and accessories
necessary for safe operation--is required for all compliance reviews
except streamlined reviews. Vehicle inspections are supposed to be a key
investigative technique for assessing compliance with this area, and an
FMCSA official said that the lower rate of coverage for the parts and
accessories area likely reflects the small number of vehicle inspections
that FMCSA and the states conduct during compliance reviews.

FMCSA Follows Up with Many Carriers with Serious Safety Violations but Does Not
Assess Maximum Fines for All of the Violations Required by Law

Our preliminary assessment is that FMCSA placed many carriers rated
unsatisfactory in fiscal year 2005 out of service and followed up with
nearly all of the rest to determine whether they had improved. In
addition, FMCSA monitors carriers to identify those that are violating
out-of-service orders. However, it does not take additional action against
many violators of out-of-service orders that it identifies. Furthermore,
FMCSA does not assess maximum fines against all carriers, as we believe
the law requires, partly because FMCSA does not distinguish between
carriers with a pattern of serious safety violations and those that repeat
a serious violation.^15

FMCSA Followed Up with Almost All Carriers That Received a Proposed Safety
Rating of Unsatisfactory

FMCSA followed up with at least 1,189 of 1,196 carriers (99 percent) that
received a proposed safety rating of unsatisfactory following compliance
reviews completed in fiscal year 2005. These follow-ups resulted in either
upgraded safety ratings or the carriers being placed out of service.
Specifically,

           o Based on follow-up compliance reviews, FMCSA upgraded the final
           safety ratings of 658 carriers (325 to satisfactory and 333 to
           conditional).
           o FMCSA assigned a final rating of unsatisfactory to 309 carriers.
           FMCSA issued out-of-service orders to 306 of these carriers. An
           FMCSA official told us that it did not issue out-of-service orders
           to the remaining three carriers either because the agency could
           not locate them or because the carrier was still subject to an
           out-of-service order that FMCSA issued several years prior to the
           2005 compliance review.
           o After FMCSA reviewed evidence of corrective action submitted by
           carriers, it upgraded the final safety ratings of 214 carriers (23
           to satisfactory and 191 to conditional).
           o Due to an error in assigning the proposed safety rating to one
           carrier, FMCSA upgraded its final safety rating to conditional.
			  
15In December 2005, we reported more fully on FMCSA's enforcement
activities. See GAO, Large Truck Safety: Federal Enforcement Efforts Have
Been Stronger Since 2000, but Oversight of State Grants Needs Improvement,
[23]GAO-06-156 (Washington, D.C.: Dec. 15, 2005).			  

           For the remaining 14 carriers, FMCSA did not (1) provide us
           information on whether and how it followed up with 7 carriers in
           time for us to incorporate it in this statement and (2) respond to
           our request to clarify its follow-up approach for another 7
           carriers in time for us to incorporate it in this statement.

           Under its policies, FMCSA is generally required to assign the
           carrier a final rating of unsatisfactory and to issue it an
           out-of-service order after either 45 or 60 days, depending on the
           nature of the carrier's business.^16 Of the about 300
           out-of-service orders that FMCSA issued to carriers rated
           unsatisfactory following compliance reviews conducted in fiscal
           year 2005, FMCSA told us that 89 percent were issued on time, 9
           percent were issued between 1 and 10 days late, and 2 percent were
           issued more than 10 days late. We are working with FMCSA to verify
           these numbers. An FMCSA official told us that in the few instances
           where an out-of-service order was issued more than 1 week late,
           the primary reason for the delay was that the responsible FMCSA
           division office had difficulty scheduling follow-up compliance
           reviews and thus held off on issuing the orders.
			  
FMCSA Monitors Carriers to Identify Those That Are Violating Out-of-Service
Orders, but It Does Not Take Additional Action against Many of the Violators It
Identifies

           FMCSA uses two primary means to try to ensure that carriers that
           have been placed out of service do not continue to operate. First,
           FMCSA partners with states to help them suspend, revoke, or deny
           vehicle registration to carriers that have been placed out of
           service. FMCSA refers to these partnerships as the Performance and
           Registration Information Systems Management program (PRISM). PRISM
           links FMCSA databases with state motor vehicle registration
           systems and roadside inspection personnel to help identify
           vehicles operated by carriers that have been issued out-of-service
           orders. As of January 2007, 45 states had been awarded PRISM
           grants and 27 states were operating with PRISM capabilities.
			  
^16Under certain circumstances (for example, if the carrier is making good
faith efforts to improve its safety), FMCSA may allow a carrier with a
proposed rating of unsatisfactory to continue to operate for a limited
time.

           Second, FMCSA monitors carriers for indicators--such as roadside
           inspections, moving violations, and crashes--that they may be
           violating an out-of-service order and visits some of the suspect
           carriers to examine their records to determine whether they did
           indeed violate the order. FMCSA told us it is difficult to detect
           carriers operating in violation of out-of-service orders because
           its resources do not allow it to visit each carrier or conduct
           roadside inspections on all vehicles, and we agree. In fiscal
           years 2005 and 2006, 768 of 1,996 carriers (38 percent) that were
           subject to an out-of-service order had a roadside inspection or
           crash; FMCSA cited only 26 of these 768 carriers for violating an
           out-of-service order. An FMCSA official told us that some of these
           carriers, such as carriers that were operating intrastate or that
           had leased its vehicles to other carriers, may not have been
           violating the out-of-service order. He said that FMCSA did not
           have enough resources to determine whether each of the carriers
           was violating an out-of-service order.
			  
FMCSA Conducted Compliance Reviews on About Half of All High-risk Carriers That
It Was Required to By Statute

           From August 2006 through February 2007, FMCSA data indicate that
           the agency performed compliance reviews on 1,136 of the 2,220 (51
           percent) carriers that were covered by its mandatory compliance
           review policy.^17 The Safe, Accountable, Flexible, Efficient
           Transportation Equity Act: A Legacy for Users act requires that
           FMCSA conduct compliance reviews on carriers rated as SafeStat
           category A or B for 2 consecutive months. In response to this
           requirement, FMCSA implemented a policy in June 2006 requiring a
           compliance review within 6 months for any such carrier unless the
           carrier had received a compliance review within the previous 12
           months. An FMCSA official told us that the agency did not have
           enough resources to conduct compliance reviews on all of the 2,220
           carriers within 6 months.

           In April 2007, FMCSA revised the policy because it believes that
           it required compliance reviews for some carriers that did not need
           them, leaving FMCSA with insufficient resources to conduct
           compliance reviews on other carriers that did need them.
           Specifically, FMCSA believes that carriers that had already had a
           compliance review were targeted unnecessarily after they had
           corrected identified violations, but these violations continued to
           adversely affect their SafeStat rating because SafeStat penalizes
           carriers for violations regardless of whether they have been
           corrected. The new policy requires compliance reviews within 6
           months for carriers that have been in SafeStat category A or B for
           2 consecutive months and received their last compliance 2 or more
           years ago (or have never received a compliance review) and offers
           some discretion to FMCSA division offices. For example, division
           offices can decide not to conduct a compliance review if its
           SafeStat score is based largely on violations that have been
           corrected or on accidents that occurred prior to the carrier's
           last compliance review. We believe that these changes are
           consistent with the act's requirement and give FMCSA appropriate
           discretion in allocating its compliance review resources.
			  
^17An FMCSA official told us that the agency believes that these data
overestimate the number of carriers that were required to but did not
receive a compliance review, primarily because FMCSA has indications that
some carriers are actually inactive.

           FMCSA Does Not Assess Maximum Fines for All the Violations Required
			  by Law

           FMCSA does not assess the maximum fines against all carriers as we
           believe the law requires. The law requires FMCSA to assess the
           maximum allowable fine for each serious violation by a carrier
           that is found (1) to have committed a pattern of such violations
           (pattern requirement) or (2) to have previously committed the same
           or a related serious violation (repeat requirement).^18 However,
           FMCSA's policy on maximum fines does not fully meet these
           requirements. FMCSA enforces both requirements using what is known
           as the "three-strikes rule," applying the maximum allowable fine
           when it finds that a motor carrier has violated the same
           regulation three times within a 6-year period. FMCSA officials
           said they interpret both parts of the act's requirements to refer
           to repeat violations, and because they believe that having two
           distinct policies on repeat violations would confuse motor
           carriers, it has chosen to address both requirements with its
           single three-strikes policy.

           FMCSA's interpretation does not carry out the statutory mandate to
           impose maximum fines in two different cases. In contrast to FMCSA,
           we read the statute's use of the distinct terms "a pattern of
           violations" and "previously committed the same or a related
           violation" as requiring FMCSA to implement two distinct policies.
           A basic principle of statutory interpretation is that distinct
           terms should be read as having distinct meanings. In this case,
           the statute not only uses different language to refer to the
           violations for which maximum fines must be imposed but also sets
           them out separately and makes either type of violation subject to
           the maximum penalties. Therefore, one carrier may commit a variety
           of serious violations and another carrier may commit the same or a
           substantially similar serious violation as a previous violation;
           the language on its face requires FMCSA to assess the maximum
           allowable fine in both situations--patterns of violations as well
           as repeat offenses.
			  
^18Motor Carrier Safety Improvement Act of 1999, Pub. L. 106-159, S
222(b)(2), 113 Stat. 1748, 1769 (49 U.S.C.A. S 521 Note).

           FMCSA could define a pattern of serious violations in numerous
           ways that are consistent with the act's pattern requirement. Our
           assessment of eight potential definitions shows that the number of
           carriers that would be subject to maximum fines depends greatly on
           the definition. (See table 4.) For example, a definition calling
           for two or more serious violations in each of at least four
           different regulatory areas during a compliance review would have
           made 38 carriers subject to maximum fines in fiscal year 2006. In
           contrast, a definition calling for one or more serious violations
           in each of at least three different regulatory areas would have
           made 1,529 carriers subject to maximum fines during that time.^19

Table 4: Number of Motor Carriers That Would Have Been Subject to Maximum
Fines under Various Definitions of a Pattern of Serious Violations, Fiscal
Years 2004 through 2006

             Number of carriers in  Number of carriers in  Number of carriers in
                   2004 with              2005 with              2006 with
 Regulatory   1 or more  2 or more   1 or more  2 or more   1 or more  2 or more 
 areas with     serious    serious     serious    serious     serious    serious 
 serious     violations violations  violations violations  violations violations 
 violations    per area   per area    per area   per area    per area   per area 
 2 or more        2,935        177       3,004        158       3,348        225 
 3 or more        1,372         64       1,430         58       1,529        114 
 4 or more          494         16         557         25         530         38 
 5 or more           83          2         115          9         115          7 

Source: GAO analysis of FMCSA data.

We also interpret the statutory language for the repeat requirement as
calling for a "two-strikes" rule as opposed to FMCSA's three-strikes rule
interpretation. FMCSA's interpretation imposes the maximum fine only after
a carrier has twice previously committed such violations. The language of
the statute does not allow FMCSA's interpretation; rather, it requires
FMCSA to assess the maximum allowable fine for each serious violation
against a carrier that has previously committed the same serious
violation.^20

^19Our definitions are for analysis purposes only. We are not suggesting
which, if any, of these pattern definitions FMCSA should adopt as its
policy, nor is our exclusive focus on patterns involving only violations
identified during a single compliance review meant to suggest that the
definition of pattern could not require that serious violations occur over
multiple compliance reviews.

In fiscal years 2004 through 2006, more than four times as many carriers
had a serious violation that constituted a second strike than carriers
that had a third strike. (See table 5.) For example, in fiscal year 2006,
1,320 carriers had a serious violation that constituted a second strike,
whereas 280 carriers had a third strike.

Table 5: Number of Motor Carriers That Would Have Been Subject to Maximum
Fines under Two-strikes and Three-strikes Repeat Violator Policies, Fiscal
Years 2004 through 2006

Policy           2004  2005  2006 Total 
Two strikes     1,251 1,292 1,320 3,863 
Three strikes^a   269   284   280   833 

Source: GAO analysis of FMCSA data.

aFMCSA's policy currently assesses the maximum fine for 3 violations in
the same regulatory area.

Carriers that commit a pattern of violations may also commit a second
strike violation. For example, three of the seven carriers that had two or
more serious violations in each of at least five different regulatory
areas also had a second strike in fiscal year 2006. Were FMCSA to make
policy changes along the lines discussed here, we believe that the new
policies should address how to deal with carriers with serious violations
that both are part of a pattern and repeat the same or similar previous
violations.

Mr. Chairman, this concludes my prepared statement. I would be pleased to
respond to any questions that you or other Members of the Subcommittee
might have.

^20The statute (section 222(c)) does allow the Secretary to determine and
document that extraordinary circumstances merit a lower than maximum fine
in a particular case, if for example a carrier can establish that
repetition was not a result of its failure to take appropriate remedial
action.

GAO Contacts and Staff Acknowledgement

For further information on this statement, please contact Susan Fleming at
(202) 512-2834 or [24][email protected] . Individuals making key
contributions to this testimony were David Goldstein, Eric Hudson, and
James Ratzenberger.

Related GAO Products

Motor Carrier Safety: A Statistical Approach Will Better Identify
Commercial Carriers That Pose High Crash Risks Than Does the Current
Federal Approach. [25]GAO-07-585 . Washington, D.C.: June 11, 2007.

Unified Motor Carrier Fee System: Progress Made but Challenges to
Implementing New System Remain. [26]GAO-07-771R . Washington, D.C.: May
25, 2007.

Consumer Protection: Some Improvements in Federal Oversight of Household
Goods Moving Industry Since 2001, but More Action Needed to Better Protect
Individual Consumers. [27]GAO-07-586 . Washington, D.C.: May 16, 2007.

Transportation Security: DHS Efforts to Eliminate Redundant Background
Check Investigations. [28]GAO-07-756 . Washington, D.C.: April 26, 2007.

Truck Safety: Share the Road Safely Pilot Initiative Showed Promise, but
the Program's Future Success Is Uncertain. [29]GAO-06-916 . Washington,
D.C.: September 8, 2006.

Federal Motor Carrier Safety Administration: Education and Outreach
Programs Target Safety and Consumer Issues, but Gaps in Planning and
Evaluation Remain. [30]GAO-06-103 . Washington, D.C.: December 19, 2005.

Large Truck Safety: Federal Enforcement Efforts Have Been Stronger Since
2000, but Oversight of State Grants Needs Improvement. [31]GAO-06-156 .
Washington, D.C.: December 15, 2005.

Highway Safety: Further Opportunities Exist to Improve Data on Crashes
Involving Commercial Motor Vehicles. [32]GAO-06-102 . Washington, D.C.:
November 18, 2005.

(541035)

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[39]www.gao.gov/cgi-bin/getrpt?GAO-07-1074T .

To view the full product, including the scope
and methodology, click on the link above.

For more information, contact Susan A. Fleming at (202) 512-2834 or
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Highlights of [40]GAO-07-1074T , a testimony before the Subcommittee on
Highways and Transit, Committee on Transportation and Infrastructure,
House of Representatives

July 11, 2007

MOTOR CARRIER SAFETY

Preliminary Information on the Federal Motor Carrier Safety
Administration's Efforts to Identify and Follow Up with High-risk Motor
Carriers

The Federal Motor Carrier Safety Administration (FMCSA) has the primary
federal responsibility for reducing crashes involving large trucks and
buses. FMCSA uses its "SafeStat" tool to select carriers for reviews for
compliance with its safety regulations based on the carriers' crash rates
and prior safety violations. FMCSA then conducts these compliance reviews
and can place carriers out of service if they are found to be operating
unsafely.

This statement is based on a recent report (GAO-07-585) and other nearly
completed work. GAO assessed (1) the extent to which FMCSA identifies
carriers that subsequently have high crash rates, (2) how FMCSA ensures
that its compliance reviews are conducted thoroughly and consistently, and
(3) the extent to which FMCSA follows up with carriers with serious safety
violations. GAO's work was based on a review of laws, program guidance,
and analyses of data from 2004 through early 2006.

[41]What GAO Recommends

In June, GAO recommended that FMCSA use a regression model approach to
identify high-risk carriers. FMCSA agreed that this approach looks
promising but is concerned that it results in less emphasis on other
regulatory areas. GAO is considering several recommendations, including
that FMCSA assess maximum penalties in situations which GAO believes the
law requires.

FMCSA generally does a good job in identifying carriers that pose high
crash risks for subsequent compliance reviews, ensuring the thoroughness
and consistency of those reviews, and following up with high-risk
carriers.

SafeStat is nearly twice as effective (83 percent) as random selection in
identifying carriers that pose high crash risks. However, its
effectiveness could be improved by using a statistical approach (negative
binomial regression), which provides for a systematic assessment to apply
weights to the four SafeStat safety evaluation areas (accidents and
driver, vehicle, and safety management violations) rather than FMCSA's
approach, which relies on expert judgment. The regression approach
identified carriers that had twice as many crashes in the subsequent 18
months as did the carriers identified by the current SafeStat approach.
FMCSA is concerned that adopting this approach would result in it placing
more emphasis on crashes and less emphasis on compliance with its safety
management, vehicle, and driver regulations. GAO believes that because (1)
the ultimate purpose of compliance reviews is to reduce the number and
severity of truck and bus crashes and (2) GAO's and others' research has
shown that crash rates are stronger predictors of future crashes than is
poor compliance with FMCSA's safety regulations, the regression approach
would improve safety.

GAO's preliminary assessment is that FMCSA promotes thoroughness and
consistency in its compliance reviews through its management processes,
which meet GAO's standards for internal controls. For example, FMCSA uses
an electronic manual to record and communicate its compliance review
policies and procedures and teaches proper compliance review procedures
through both classroom and on-the-job training. Furthermore, investigators
use an information system to document their compliance reviews, and
managers review these data, helping to ensure thoroughness and consistency
between investigators. For the most part, FMCSA and state investigators
cover the nine major applicable areas of the safety regulations (e.g.,
driver qualifications and vehicle condition) in 95 percent or more of
compliance reviews, demonstrating thoroughness and consistency.

GAO's preliminary assessment is that FMCSA follows up with almost all
carriers with serious safety violations, but it does not assess the
maximum fines against all serious violators that GAO believes the law
requires. FMCSA followed up with at least 1,189 of 1,196 carriers (99
percent) that received proposed unsatisfactory safety ratings from
compliance reviews completed in fiscal year 2005. For example, FMCSA found
that 873 of these carriers made safety improvements and it placed 306
other carriers out of service. GAO also found that FMCSA (1) assesses
maximum fines against carriers for the third instance of a violation,
whereas GAO reads the statute as requiring FMCSA to do so for the second
violation and (2) does not always assess maximum fines against carriers
with a pattern of varied serious violations, as GAO believes the law
requires.

References

Visible links
  18. http://www.gao.gov/cgi-bin/getrpt?GAO-07-585
  19. http://www.gao.gov/cgi-bin/getrpt?GAO/AIMD-00-21.3.1
  20. http://www.gao.gov/cgi-bin/getrpt?GAO-07-585
  21. http://www.gao.gov/cgi-bin/getrpt?GAO-07-585
  22. http://www.gao.gov/cgi-bin/getrpt?GAO/AIMD-00-21.3.1
  23. http://www.gao.gov/cgi-bin/getrpt?GAO-06-156
  24. mailto:[email protected]
  25. http://www.gao.gov/cgi-bin/getrpt?GAO-07-585
  26. http://www.gao.gov/cgi-bin/getrpt?GAO-07-771R
  27. http://www.gao.gov/cgi-bin/getrpt?GAO-07-586
  28. http://www.gao.gov/cgi-bin/getrpt?GAO-07-756
  29. http://www.gao.gov/cgi-bin/getrpt?GAO-06-916
  30. http://www.gao.gov/cgi-bin/getrpt?GAO-06-103
  31. http://www.gao.gov/cgi-bin/getrpt?GAO-06-156
  32. http://www.gao.gov/cgi-bin/getrpt?GAO-06-102
  33. http://www.gao.gov/
  34. http://www.gao.gov/
  35. http://www.gao.gov/fraudnet/fraudnet.htm
  36. mailto:[email protected]
  37. mailto:[email protected]
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  39. http://www.gao.gov/cgi-bin/getrpt?GAO-07-1074T
  40. http://www.gao.gov/cgi-bin/getrpt?GAO-07-1074T
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