Motor Carrier Safety: The Federal Motor Carrier Safety		 
Administration Has Developed a Reasonable Framework for Managing 
and Testing Its Comprehensive Safety Analysis 2010 Initiative	 
(20-DEC-07, GAO-08-242R).					 
                                                                 
About 5,500 people die each year as a result of crashes involving
large commercial trucks or buses, and about 160,000 more are	 
injured. While the fatality rate for these crashes has generally 
decreased over the last 20 years, the decline has leveled off in 
the most recent years. The Federal Motor Carrier Safety 	 
Administration (FMCSA) within the U.S. Department of		 
Transportation shoulders the primary federal responsibility for  
reducing these crashes, fatalities, and injuries and recognizes  
the need to make improvements if it is to achieve further	 
substantial safety advancements. A key FMCSA effort to improve	 
motor carrier safety is implementing the agency's Comprehensive  
Safety Analysis 2010 (CSA 2010) initiative. Through CSA 2010,	 
FMCSA expects to reduce motor carrier crashes, fatalities, and	 
injuries by using better ways to identify unsafe carriers and	 
drivers; assessing a larger portion of the motor carrier industry
and holding carriers and drivers accountable for sustained	 
performance by regularly determining their safety fitness; and	 
expanding the range of interventions to be used with carriers and
drivers that fail to comply with safety requirements. Congress	 
asked us to conduct a broad assessment of FMCSA's progress in	 
planning and implementing CSA 2010. Because much of the detailed 
work to develop and implement CSA 2010 remains to be done, our	 
work has focused on how FMCSA has managed its initiative, rather 
than assessing safety benefits that might arise from it.	 
Specifically, we reviewed: (1) how FMCSA sees CSA 2010 increasing
safety, (2) whether FMCSA's overall framework for planning and	 
implementing CSA 2010 is reasonable, and (3) the extent to which 
the operational test of the CSA 2010 model will inform FMCSA of  
its ability to fully implement the initiative in 2010.		 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-08-242R					        
    ACCNO:   A79150						        
  TITLE:     Motor Carrier Safety: The Federal Motor Carrier Safety   
Administration Has Developed a Reasonable Framework for Managing 
and Testing Its Comprehensive Safety Analysis 2010 Initiative	 
     DATE:   12/20/2007 
  SUBJECT:   Accidents						 
	     Commercial motor vehicle operators 		 
	     Highway safety					 
	     Motor vehicle safety				 
	     Motor vehicles					 
	     Program evaluation 				 
	     Safety regulation					 
	     Safety standards					 
	     Traffic accidents					 
	     Transportation safety				 
	     Program goals or objectives			 
	     Program implementation				 

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GAO-08-242R

   

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December 20, 2007

The Honorable Frank R. Lautenberg
Chairman
The Honorable Gordon H. Smith
Ranking Member
Subcommittee on Surface Transportation and
Merchant Marine Infrastructure, Safety, and Security
Committee on Commerce, Science, and Transportation
United States Senate

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

About 5,500 people die each year as a result of crashes involving large
commercial trucks or buses,1 and about 160,000 more are injured. While the
fatality rate for these crashes has generally decreased over the last 20
years, the decline has leveled off in the most recent years. (See fig. 1.)
The Federal Motor Carrier Safety Administration (FMCSA) within the U.S.
Department of Transportation shoulders the primary federal responsibility
for reducing these crashes, fatalities, and injuries and recognizes the
need to make improvements if it is to achieve further substantial safety
advancements. A key FMCSA effort to improve motor carrier safety is
implementing the agency's Comprehensive Safety Analysis 2010 (CSA 2010)
initiative. Through CSA 2010, FMCSA expects to reduce motor carrier
crashes, fatalities, and injuries by using better ways to identify unsafe
carriers and drivers; assessing a larger portion of the motor carrier
industry and holding carriers and drivers accountable for sustained
performance by regularly determining their safety fitness; and expanding
the range of interventions to be used with carriers and drivers that fail
to comply with safety requirements.

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 eight
passengers (including the driver).

Figure 1: Commercial Motor Vehicle Fatality Rate, 1986 to 2005

Notes: Fewer buses are involved in fatal and nonfatal accidents than large
trucks, but they tend to involve more people.

The latest year for which data were available was 2005.

While the CSA 2010 initiative began in 2004, much remains to be done
before its implementation in 2010. Until now, FMCSA has developed its CSA
2010 operational concept into a prototype operational model and will take
a major step toward implementation next month (January 2008) when it
begins to test the CSA 2010 operating model in four states (Colorado,
Georgia, Missouri, and New Jersey).2

You asked us to conduct a broad assessment of FMCSA's progress in planning
and implementing CSA 2010. Because much of the detailed work to develop
and implement CSA 2010 remains to be done, our work has focused on how
FMCSA has managed its initiative, rather than assessing safety benefits
that might arise from it. Specifically, we reviewed

           o how FMCSA sees CSA 2010 increasing safety,

           o whether FMCSA's overall framework for planning and implementing
           CSA 2010 is reasonable, and

           o the extent to which the operational test of the CSA 2010 model
           will inform FMCSA of its ability to fully implement the initiative
           in 2010.

2The operational concept of CSA 2010 involves using a computer algorithm
to measure safety performance and an expanded set of interventions to
address safety problems. The computer algorithm will be used during the
operational test to identify carriers with safety problems and to prompt
FMCSA interventions. The operational test will enable FMCSA to determine
the impact of CSA 2010 on safety outcomes (such as effect on violation
rates) compared to its current approach to regulating safety.

We briefed your offices on December 7, 2007, and this report transmits the
results of our work. A copy of the briefing is enclosed.

Background

Currently, FMCSA conducts compliance reviews to determine, through what it
calls safety fitness determinations, whether motor carriers are safe
enough to continue operating. These comprehensive on-site reviews assess
carriers' compliance with safety regulations through interviews with
company officials and reviews of records that pertain to, as applicable,
alcohol and drug testing of drivers, insurance coverage, crashes, driver
qualifications, driver hours of service, vehicle maintenance and
inspections, and transportation of hazardous materials. While effective,
compliance reviews are resource-intensive and allow only a small
percentage of the motor carrier industry to be evaluated--each year FMCSA
and its state partners are able to conduct compliance reviews of only
about 2 percent of the estimated 724,000 motor carriers subject to the
federal safety and hazardous materials regulations.3 In addition, because
they focus on carriers, compliance reviews generally do not directly
result in compliance actions against drivers.

Since August 2004, FMCSA has been developing a new approach under its CSA
2010 initiative to measure safety and compliance, determine safety
fitness, recommend and apply interventions, and track and evaluate safety
improvements for both carriers and individual drivers. CSA 2010 is a
data-driven approach to determining safety fitness that is not contingent
on compliance reviews. Under this approach, a measurement system (computer
algorithm) will use safety data inputs to rate the safety performance of
carriers and individual drivers.4 Currently, FMCSA is focusing its efforts
on the carrier component of CSA 2010 and will turn its attention to the
driver component following the next highway statute reauthorization (the
current authorization expires in 2009), through which, according to FMCSA,
it intends to gain new authority to regulate drivers. Prior to
reauthorization, FMCSA plans to refine its driver measurement system to
use it to identify drivers with safety deficiencies and take enforcement
actions, as allowed under current authority, against them.

3According to FMCSA, this is the number of commercial motor carriers
registered in its Motor Carrier Management Information System (MCMIS) as
of September 2007. It includes an unidentified number of carriers that are
registered but are no longer in business.

4FMCSA has developed two separate measurement systems--one for carriers
and one for drivers--for use under CSA 2010.

To determine carrier safety fitness, FMCSA will use data it collects5 and
intends to collect--pertaining to such things as roadside inspection
violations, accidents,6 drivers' confirmed positive test results for
controlled substances and alcohol,7 and commercial driver's license
convictions8--arranged in seven Behavioral Analysis and Safety Improvement
Categories (BASIC) that, according to FMCSA's analysis of the data, are
associated with unsafe performance. (See table 1.)

5Data for CSA 2010 will primarily be drawn from MCMIS. Our previous work
assessed FMCSA data reliability and discussed problems with the quality of
the crash data reported to FMCSA. See GAO, Motor Carrier Safety: Federal
Safety Agency Identifies Many High-Risk Carriers but Does Not Assess
Maximum Fines as Often as Required by Law, GAO-07-584 (Washington, D.C.:
Aug. 28, 2007). Our current work does not examine the effect of these
problems on the operation of the CSA 2010 model.

6Police accident reports that are uploaded by states to MCMIS do not
always contain sections to document driver-related factors contributing to
a crash. FMCSA intends to redesign MCMIS and work with states to support
the redesign of police accident reports to allow for the collection and
reporting of driver-related factors contributing to a crash.

7FMCSA intends to collect, contingent upon rulemaking, all confirmed
positive tests for controlled substances and alcohol for commercial
drivers from medical officials via a Web portal and maintain the
information in a national database.

8FMCSA can currently access information on commercial driver's license
convictions using its Commercial Driver's License Information System
(CDLIS). However, the CDLIS database cannot be searched to identify all
drivers with a specific commercial driver's license violation. In other
words, CDLIS can be used to query an individual driver's records, but it
cannot produce a list of all drivers who have been convicted of a specific
violation. In conjunction with its CDLIS modernization effort, FMCSA is
developing a method that would allow it to use conviction data to identify
all drivers with unsafe driving records and the carriers they work for.

Table 1: CSA 2010 BASIC Definitions and Data Sources for Carriers

BASIC               Operational definition    Data sources                 
Driver fitness      Operation of commercial      o Roadside inspection     
                       motor vehicles by drivers    violations for failure to 
                       who are unfit to operate     have a valid commercial   
                       them because they lack       driver's license          
                       training, experience, or     o Crash reports citing a  
                       medical qualification.       lack of experience or     
                                                    medical reason as a cause 
                                                    or contributing factor    
                                                    o Compliance review       
                                                    violations for failure to 
                                                    maintain proper driver    
                                                    qualification files or    
                                                    use of unqualified        
                                                    drivers                   
Unsafe driving      Dangerous or careless        o Driver traffic          
                       operation of commercial      violations and            
                       motor vehicles.              convictions for speeding, 
                                                    reckless driving,         
                                                    improper lane change,     
                                                    inattention, and other    
                                                    unsafe driving behavior   
Fatigued driving    Driving commercial motor     o Hours-of-service        
                       vehicles while fatigued.     violations                
                                                    o Crash reports with      
                                                    driver fatigue cited as a 
                                                    contributing factor       
Controlled          Operation of a commercial    o Roadside inspection     
substances and      motor vehicle while          violations involving      
alcohol             impaired by or in            controlled substances or  
                       possession of alcohol,       alcohol                   
                       illegal drugs, or any        o Crash reports citing    
                       other substance that         driver impairment or      
                       renders the driver           intoxication as a cause   
                       incapable of safely          o Positive controlled     
                       operating a motor            substances or alcohol     
                       vehicle.                     test results on drivers   
Crash/incident      Histories or patterns of     o Law enforcement crash   
experience          high crash involvement,      reports                   
                       including frequency and      o Crashes reported by the 
                       severity.                    carrier that are          
                                                    discovered during on-site 
                                                    investigations            
Vehicle maintenance Failure of commercial        o Roadside inspection     
                       motor vehicle due to         violation for brakes,     
                       improper or inadequate       lights, and other         
                       maintenance.                 mechanical defects        
                                                    o Crash reports citing a  
                                                    mechanical failure as a   
                                                    contributing factor       
                                                    o Compliance review       
                                                    violations associated     
                                                    with pre-trip             
                                                    inspections, maintenance  
                                                    records, and repair       
                                                    records                   
Improper            Shifting loads, spilled      o Roadside inspection     
loading/cargo       or dropped cargo, and        violations pertaining to  
securement          unsafe handling of           load securement, cargo    
                       hazardous materials.         retention, and hazardous  
                                                    material handling         
                                                    o Crash reports citing    
                                                    shifting loads or         
                                                    spilled/dropped cargo as  
                                                    a cause or contributing   
                                                    factor                    

Source: FMCSA.

Note: Most of the BASICs deal with driver characteristics and behavior.
FMCSA will address these driver behaviors by intervening with carriers
that use unsafe drivers. FMCSA will also use these same BASICs and
underlying data sources to determine the safety fitness of individual
drivers.

The safety measurement system will score carriers in each BASIC and make a
safety fitness determination9 to indicate (1) whether a carrier should
continue to operate, (2) if operational deficiencies requiring FMCSA
intervention exist, or (3) if a carrier should be suspended from
operating.10 (See fig. 2.)

9FMCSA's ability to determine carrier safety fitness under CSA 2010 is
contingent upon completion of rulemaking. FMCSA plans to publish a notice
of proposed rulemaking on this issue by summer 2008 and expects that the
final rule will be in place approximately a year later.

Figure 2: CSA 2010 Operating Model for Carriers

When FMCSA finds indications of carrier safety problems through its
analysis of data--the safety measurement system will indicate if a carrier
is deficient in one or more BASICs--it plans to make flexible, progressive
interventions commensurate with both the behavior exhibited by carriers
and any safety intervention history.11 (See table 2.) While these
interventions are not new, FMCSA intends to apply them in a more
systematic manner under CSA 2010. For example, if a safety measurement
shows that a carrier is deficient in the driver fitness BASIC, the system
will automatically generate a warning letter and, depending on the
severity of the problem, may trigger an on-site investigation, during
which an inspector reviews the carrier's driver qualification files, among
other actions, to identify and correct the deficiency. If these
interventions do not remedy the problem, FMCSA may apply more stringent
actions, such as assessing penalties or, in the worst case, suspending the
carrier.

10Safety fitness determinations will be affected by the type of violation
a carrier makes. For example, FMCSA will evaluate violations found through
interventions to determine if they are from what the agency considers
areas of essential safety management. If essential safety management
violations are 10 percent or more of records checked, failure of the
corresponding BASIC will result. Additionally, FMCSA has identified 15
violations that it believes are so fundamental to ensuring safety, that a
carrier making any one of the violations will be deemed unfit.

11Interventions can also be initiated by other means such as a carrier
being the subject of a complaint or involved in a fatal crash. FMCSA has
not yet developed interventions for individual drivers. According to
FMCSA, development of these interventions is contingent upon it gaining
new authority to assess individual drivers' safety fitness through
reauthorization of the highway statute.

Table 2: Proposed CSA 2010 Carrier Interventions

Intervention            Description                                        
Warning letter          The safety measurement system will automatically   
                           generate a warning letter (to a carrier) when it   
                           detects that a carrier is deficient in one or more 
                           BASICs. The letter will describe the safety        
                           problem(s), offer suggestions for improvement, and 
                           explain how the carrier may challenge the accuracy 
                           of FMCSA's findings.                               
Targeted roadside       The issuance of a warning letter will prompt       
inspection              inspectors at permanent and temporary roadside     
                           inspection stations to inspect carriers that are   
                           known to have deficiencies in one or more BASICs.  
Off-site investigation  Carriers that continue to demonstrate BASIC        
                           deficiencies will be asked to voluntarily submit   
                           documents to help FMCSA evaluate carrier safety    
                           management practices, determine the root causes of 
                           a safety problem, and take corrective action. For  
                           example, FMCSA may ask a carrier that is deficient 
                           in the controlled substances and alcohol BASIC for 
                           records pertaining to its driver drug testing      
                           program. If a carrier does not comply with FMCSA's 
                           request, the agency may intervene through an       
                           on-site investigation.                             
On-site investigation   Carriers that continue to demonstrate BASIC        
                           deficiencies, that are involved in a fatal crash,  
                           or are the subject of a complaint will undergo a   
                           focused on-site investigation so that FMCSA can    
                           attempt to determine the root causes of a safety   
                           problem and take corrective action. In instances   
                           of broad or complex safety problems, a carrier     
                           will be subject to a comprehensive on-site         
                           investigation similar to that currently performed  
                           during a compliance review.                        
Cooperative safety plan Following an off-site or on-site investigation,    
                           the carrier and FMCSA will collaboratively create  
                           a safety plan that addresses the root causes of    
                           problems, which the carrier will voluntarily       
                           implement.                                         
Notice of violation     Carriers with regulatory violations that do not    
                           warrant fines and can be immediately corrected     
                           will receive a formal notice that requires a       
                           response.                                          
Notice of claim         Carriers with regulatory violations that are       
                           severe and warrant penalties will receive a legal  
                           notice.                                            
Consent agreement       To avoid further enforcement proceedings, a        
                           carrier may negotiate an agreement that will       
                           address the root causes of a safety problem and    
                           result in a deferral of or reduction in penalties. 
                           Nonregulatory solutions, such as the use of        
                           electronic onboard recordersa or collision         
                           avoidance systems, may be incorporated into the    
                           agreement.                                         
Unfit suspension        Carriers that do not comply with other             
                           interventions will be prevented from operating.    
                           The carrier has the right to due process.          

Source: FMCSA.

aElectronic onboard recorders are devices used to measure the amount of
time a driver operates a vehicle. Electronic onboard recorders may be
recommended, for example, for carriers that allow their drivers to operate
beyond hours of service limits set by law.

Results in Brief

FMCSA expects that CSA 2010 will provide safety benefits by enabling the
agency to (1) increase its reach by assessing whether most motor carriers
and drivers are safe and holding them accountable by regularly determining
their safety fitness; (2) enhance its investigative and enforcement
actions through the greater use of less resource-intensive interventions;
and (3) improve its ability to identify safety deficiencies through better
use of data. Under CSA 2010, all carriers--and eventually all
drivers--with sufficient safety data available will receive a safety
rating that is periodically updated. Currently, FMCSA is able to provide
safety ratings for relatively few carriers and for no drivers. As
described earlier, CSA 2010 will employ a progressive array of
interventions that can be tailored to match the severity of the safety
problems they are intended to correct. CSA 2010 intends to use new
data--such as information from police accident reports about
driver-related factors contributing to a crash--and improve existing data
sources--by, for example, using its database of licensed commercial
drivers to identify all drivers with convictions for unsafe driving
practices, as well as the carriers they work for--to enable a more precise
assessment of safety problems. CSA 2010 will support evolving and new
enforcement and compliance efforts. For example, (1) carriers from Canada
and Mexico that operate in the United States under open border agreements
will be rated under CSA 2010 in the same way as U.S. carriers; (2)
violations found through audits of new entrants12--a program that FMCSA is
working to strengthen--will be used in the CSA 2010 safety measurement
system; and (3) data sources related to drivers' health--such as drivers'
confirmed positive test results for controlled substances or alcohol--will
be developed to focus attention on driver physical qualifications, a key
FMCSA policy area.

FMCSA has established a reasonable framework to plan and implement CSA
2010. In its planning efforts to date, it has met three factors associated
with successful planning--set a clear project mission, established top
leadership support, and developed a detailed plan.13 As FMCSA transitions
from planning to implementing CSA 2010, it has met or is taking steps to
meet those factors--such as consulting with affected stakeholders and
providing needed technology and expertise to accomplish technical
tasks--critical to the project's successful implementation. However, since
some aspects of implementation are still being defined, we cannot yet
assess FMCSA's efforts to effectively meet the success factors for
implementation. For example, FMCSA has provided a range of technical
resources to, among other efforts, develop the CSA 2010 operating model,
initiate rulemaking, develop training instruments, and configure
supporting data and information technology systems. However, certain
efforts, such as rulemaking and data and information technology system
configuration, will continue as the operational test progresses and may
lead to
refinement of the CSA 2010 concept. Therefore, an assessment of FMCSA's
overall effort cannot be completed until these activities occur over the
course of the operational test (from January 2008 through June 2010).

12Carriers newly registered with the Department of Transportation are
subject to an 18-month safety monitoring period. During this
period--generally between 3 and 6 months after a new registration is
obtained--a carrier will receive a safety audit to determine if it has the
necessary systems in place to ensure basic safety management controls.
Failure to demonstrate basic safety management controls may result in the
revocation of the carrier's new-entrant registration.

13We reviewed project management literature and identified 10 factors
associated with the successful planning and implementation of projects.
Efforts associated with successful project planning are (1) setting a
clear project mission that establishes goals and sets direction; (2)
establishing top leadership support to allocate resources and confer
authority to project managers; and (3) developing a project plan that
details actions required for implementation. Efforts associated with
successful project implementation are (1) consulting with affected
stakeholders; (2) selecting and training members of the project team; (3)
providing needed technology and expertise to accomplish technical tasks;
(4) selling the project to its intended users; (5) controlling the project
by monitoring and providing timely feedback; (6) establishing a framework
for and communicating needed information to key stakeholders; and (7)
troubleshooting and managing unexpected problems and deviations from the
plan.

The CSA 2010 operational test will inform FMCSA of its ability to
implement the carrier component of its initiative by enabling the
real-time use of the safety measurement system and interventions that
constitute the operating model.14 However, according to FMCSA, the driver
component cannot be fully tested until the agency receives new authority
to regulate individual drivers that the department intends to seek as part
of the next highway statute reauthorization (the current authorization
expires in 2009). FMCSA has established a reasonable structure for and
approach to evaluating the test. Carriers in the four test states will be
divided into test and control groups (a conventional study method) to
enable FMCSA to (1) assess whether the CSA 2010 approach will yield better
safety outcomes than its current approach and (2) evaluate how resource
intensive it is to use the interventions. To determine whether CSA 2010
provides better safety outcomes, FMCSA will, for example, compare changes
to key safety indicators--such as violation rates and BASIC
scores--experienced by the test and control groups from the beginning to
the end of the test. To evaluate the approach's effect on resource needs,
FMCSA will look to quantify such factors as (1) the number of people
working on interventions, (2) the number of carriers being contacted, (3)
the types of interventions used, and (4) the number of labor hours each
intervention takes.

Agency Comments and Our Evaluation

In reviewing a draft of this report, the Department of Transportation
stated that it agreed with its contents. It offered a clarifying comment,
which we incorporated.

Scope and Methodology

To determine how FMCSA sees CSA 2010 increasing safety, we reviewed
documents and interviewed FMCSA officials to discuss the benefits the
agency expects from its new safety initiative. Additionally, we reviewed
transcripts of recent congressional hearings on FMCSA to identify (1)
concerns about the agency's performance and (2) topical issues affecting
the motor carrier industry in general. We used the broad findings from our
review of the transcripts to assess how, if at all, CSA 2010 addresses
concerns about FMCSA and is affected by topical industry issues. To assess
whether the overall framework for planning and implementing CSA 2010 is
reasonable, we reviewed our work pertaining to organizational
transformation and professional literature on project management topics.
We determined that our review of FMCSA's effort to plan and implement CSA
2010 fit within the construct of project management and focused our effort
on defining project management success factors. Once we defined a
framework of project management success factors appropriate to our level
of analysis, we reviewed CSA 2010 project management and planning
documents and interviewed agency officials to determine the extent to
which FMCSA meets the success factors. To determine the extent to which
the operational test will inform FMCSA of its ability to fully implement
CSA 2010, we reviewed operational test planning documents and held
discussions with FMCSA officials to examine which CSA 2010 components will
be tested and how the test will be evaluated. We then applied findings
from our review of the testing protocol to discuss the implications of
FMCSA's testing approach to its ability to implement the initiative. To
inform our overall analysis, we talked with a broad range of stakeholders
from industry and safety advocacy groups and discussed their views on CSA
2010. We conducted our review from April 2007 through December 2007 in
accordance with generally accepted government auditing standards.

14The CSA 2010 operational test will take place over 30 months, beginning
in January 2008 and concluding in June 2010. A 30-month test period is
planned to account for the sequential steps of (and time lags between)
identifying a problem, allowing the carrier to take remedial action, and
gathering data over a period of time to see if safety improvements have
been made.

                                   - - - - -

As agreed to with your offices, unless you publicly announce the contents
of this report earlier, we plan no further distribution until 30 days from
the report date. We will then send copies of this report to congressional
committees and subcommittees with responsibilities for commercial motor
vehicle safety issues, the Secretary of Transportation, the Administrator
of FMCSA, and the Director of Office of Management and Budget. We will
also make copies available to others upon request. In addition, the report
will be available at no charge on GAO's Web site at http://www.gao.gov.

Should you or your staff have any questions on matters discussed in this
report, please contact me at (202) 512-2834 or [email protected]. Contact
points for our Offices of Congressional Relations and Public Affairs may
be found on the last page of this report. Key contributors to this report
were James Ratzenberger, Assistant Director; Michael Armes; Joanie
Lofgren; Denise McCabe; and Walter Vance.

Susan A. Fleming
Director, Physical Infrastructure Issues

Enclosures

Enclosure I: 

Briefing for Congressional Staff: 

FMCSA Has Developed a Reasonable Framework for Managing and Testing Its 
CSA 2010 Initiative: 

Results: 

Objectives: 

CSA 2010 is a key FMCSA initiative to (1) assess whether most carriers 
and drivers are safe enough to continue operating and (2) deploy an 
expanded range of interventions to address safety problems. The CSA 
2010 safety measurement systems score carriers and drivers in seven 
Behavioral Analysis and Safety Improvement Categories (BASIC), and 
interventions are based on the severity of safety problems. 

We reviewed (1) how FMCSA sees CSA 2010 increasing safety, (2) whether 
FMCSAï¿½s overall framework for planning and implementing CSA 2010 is 
reasonable, and (3) the extent to which the operational test of the CSA 
2010 model will inform FMCSA of its ability to fully implement the 
initiative in 2010. 

Scope and Methodology: 

To carry out our work, we (1) reviewed FMCSA documents, interviewed 
agency officials, and reviewed transcripts of congressional hearings 
related to FMCSA; (2) reviewed our work on organizational 
transformation and professional literature on project management topics 
and developed a framework of project management success factors based 
on our reviews; and (3) reviewed FMCSA documents and interviewed agency 
officials about testing protocols and applied our findings to discuss 
implications of FMCSAï¿½s testing approach to its ability to implement 
its initiative. To inform our overall analysis, we talked to a broad 
range of stakeholders from industry and safety advocacy groups. 

Summary of Results: 

FMCSA expects CSA 2010 to provide increased safety benefits. 

* Increased reach by rating safety fitness of most carriers and drivers 
and holding them accountable for sustained performance through regular 
reassessments. 

* Enhanced investigative and enforcement ability through greater use of 
less resource-intensive interventions. 

* Improved ability to identify safety problems through better use of 
data. 

FMCSA is taking a reasonable approach to planning and implementing CSA 
2010. 

* Has met success factors related to project planning. 

* Has met or is taking steps to meet success factors related to project 
implementation; effectiveness of efforts will not be apparent until 
implementation progresses further. 

Operational test beginning January 2008 will partially inform FMCSA of 
its ability to implement CSA 2010. 

* Test will assess carrier component (and driver component to a lesser 
extent) of CSA 2010. 

* FMCSA has established a reasonable structure for and approach to 
evaluating the test. 

CASA 2010 Operational Concept: 

Figure : CSA 2010 Operational Concept: 

{See PDF for image] 

This figure is an illustration for the CSA 2010 Operational Concept. 
The following data is depicted: 

Start: 
* Crash Reports; 
* Driver traffic violations and convictions; 
* Hours-of-service violations; 
* Controlled substances and alcohol test results; 
* Roadside inspection violations. 

Safety data is collected from the above items, and sent to: 

Safety Measurement System: BASICS: 
* Driver fitness; 
* Unsafe driving; 
* Fatigued driving; 
* Controlled substance and alcohol; 
* Crash/incident experience; 
* Vehicle maintenance; 
* Improper loading/cargo securement. 

At this point, a Safety Evaluation is performed. Any of the following 
three situations can occur: 

Safety Evaluation: 
Continue to operate; 
Return to collection of safety data.

Safety Evaluation: 
Unfit; 
Unfit suspension; 
Suspend operation. 

Safety Evaluation: 
Marginal/Ongoing intervention; 
Interventions: 
* Warning letter; 
* Targeted roadside inspection; 
* Off-site investigation; 
* On-site investigation; 
* Cooperative safety plan; 
* Notice of violation; 
* Notice of claim; 
* Consent agreement; 
Return to collection of safety data. 

Sources: FMCSA and GAO. 

[End of figure] 

CSA 2010 Implementation Schedule: 

Date: Completed, as of December 2007; 
FMCSA Action: 
* Developed prototypes of safety measurement system algorithms for 
carriers and drivers. 
* Developed operational definitions and policies for using carrier 
interventions.[Footnote 15]; 
* Developed plans to operationally test carrier safety measurement 
system and interventions.

Date: January 2008; 
FMCSA Action: 
* Begin phase 1 of operational test of carrier safety measurement 
system and interventions in four states (Colorado, Georgia, Missouri, 
and New Jersey); three of seven BASICs and eight of nine interventions 
to be tested. [Footnote 16] 

Date: June 2008; 
FMCSA Action: 
* Begin phase 2 of operational test of carrier safety measurement 
system and interventions in same four states; all BASICs and 8 of 9 
interventions to be tested.

Date: 2008-2010; 
FMCSA Action: 
* Continue to develop data resources for carrier and driver safety 
measurement systems. 
* Develop and issue rules to (1) establish use of carrier safety 
measurement system in determining safety fitness and (2) enable FMCSA 
to collect individual driversï¿½ controlled substances and alcohol test 
results (in cases of positive test results indicating a driverï¿½s use of 
controlled substances or alcohol). 
* Evaluate operational test and report results to agency officials at 6-
month intervals beginning June 2008. 
* Propose legislation as part of highway statute reauthorization to 
provide FMCSA with new authority to determine safety fitness of and 
take interventions affecting individual drivers.

Date: To be determined; 
FMCSA Action: 
* Train staff in all states on CSA 2010 carrier safety measurement 
system and interventions. [Footnote 17] 

Date: June 2010: 
FMCSA Action: 
* Complete operational test of carrier safety measurement system and 
interventions. 
* Begin deploying CSA 2010 carrier safety measurement system and 
interventions to all states. [Footnote 18] 

Date: To be determined (post 2010); 
FMCSA Action: 
* Operationally test and deploy CSA 2010 driver safety measurement 
system and interventions in all states. 

[End of table] 

Expected Safety Benefits: 

Benefit: Increased reach by rating the safety fitness of most carriers 
and drivers and holding them accountable through regular reassessments; 
FMCSA Rationale: 
* Safety rating based on performance data, not tied to compliance 
review; 
- CSA 2010ï¿½Most carriers and drivers will receive a safety rating 
derived from BASIC scores; [Footnote 19] regular updates intended to 
sustain safety performance and promote accountability; 
- Current approachï¿½ Compliance review needed to make safety rating; 
FMCSA conducts compliance reviews and provides safety ratings on 
approximately 2% of the estimated 724,000 carriers registered with 
FMCSA. 

* Carriers from Canada and Mexico will be rated the same way as U.S. 
carriers. 

* New entrants will be rated, in part, on results of new entrant audits 
that FMCSA is planning to strengthen. 

Benefit: Enhanced investigative and enforcement ability through greater 
use of less resource-intensive interventions. Deploying CSA 2010 may 
require changes to FMCSAï¿½s legislative authority as interventions 
supplant compliance reviews. We did not assess the extent to which 
these changes may be necessary. 
FMCSA Rationale: 
* Flexible and progressive interventions will allow tailoring of 
investigative and enforcement actions to correct unsafe behavior; 
[Footnote 20] 
- CSA 2010ï¿½Interventions linked to BASIC scores: 
* Warning letter automatically sent when threshold exceeded on one or 
more BASICs; targeted roadside inspections, used to gain additional 
safety data, applied to carriers that received warning letters; 
* Off-site investigations used to address administrative discrepancies; 
for example, carriers could provide records missing from FMCSA files. 
* Focused on-site investigations, which are less resource-intensive 
than comprehensive on-site investigations, conducted to address 
specific problem identified by BASIC scores; 
- Current approachï¿½Compliance review, a resource-intensive action, is 
the primary intervention triggered by evaluation of Motor Carrier 
Safety Status Measurement System (SafeStat) scores. 
 
* More interventions will be made under CSA 2010. 

* Operational test will be used to develop qualitative and quantitative 
assessments of interventions to determine, for example; 
- whether interventions are clearly enough defined to enable their 
consistent application; 
- how different BASIC thresholds affect the number of interventions, 
or; 
- whether FMCSA and state partners will have sufficient resources to 
follow up on expected number of interventions. 

Benefit: Improved ability to identify safety problems through better 
use of data. Data in FMCSAï¿½s Motor Carrier Management Information 
System, which is currently used by SafeStat for rating carrier safety, 
will also be used to measure carrier safety under CSA 2010. While we 
have previously reported on problems with the quality of FMCSAï¿½s data, 
our current work does not examine the effect of these problems on the 
operation of the CSA 2010 model. 
FMCSA Rationale: 
* Expanded sources and improved quality of data will allow for more 
robust safety measurement; 
- CSA 2010ï¿½Divides data into seven BASICs to enable more precise safety 
measurement and targeted interventions. FMCSA plans to: 
* use new data on test results for driversï¿½ use of controlled 
substances and alcohol (contingent on rulemaking) and; 
* coordinate with states to (1) more accurately code reported traffic 
violations, (2) identify drivers convicted of traffic violations, (3) 
capture driver-related factors in crash reports, and (4) conduct more 
post-crash inspections; 
- Current approachï¿½ SafeStat uses data in four categories to identify 
high-risk carriers that are prioritized for compliance reviews. 

* Will include all violations in making a safety fitness determination, 
as recommended by the National Transportation Safety Board. 

* Developing data sources related to driver healthï¿½obtaining confirmed 
positive test results for use of controlled substances and 
alcoholï¿½focuses attention on driver physical qualifications, a key 
FMCSA policy area. 

[End of table] 

CSA 2010 Framework: 

Successful Projects: We identified a framework of 10 success factors 
related to project management; 
Overall Assessment: CSA 2010 is transitioning from the planning phase 
to the implementing phase(see enc. II). 
* FMCSA has met success factors associated with planning phaseï¿½setting 
clear project mission, establishing top leadership support, and 
developing project plan. 
* FMCSA has met or is taking steps to meet success factors associated 
with implementing phase. 

Success Factor: Set a clear project mission that establishes goals and 
sets direction; 
* Our assessment: FMCSA has met this success factor.
FMCSA Actions: 
* Established mission to implement more effective and efficient ways 
for FMCSA, its state partners, and industry to reduce commercial motor 
vehicle crashes, fatalities, and injuries. 
* Established overall goals to (1) assess more carriers and drivers, 
(2) apply a wider range of interventions to correct high-risk behavior, 
and (3) use improved data to better identify high-risk carriers and 
drivers. 
* Publicized intent to implement CSA 2010 to motor carrier community.

Success Factor: Establish top leadership support to allocate resources 
and delegate authority to project managers. 
* Our assessment: FMCSA has met this success factor.
FMCSA Actions: 
* Established a dedicated CSA 2010 team to manage planning and 
implementation under direction of the Chief Safety Officer, who has 
agencywide authority to assign tasks supporting CSA 2010. [Footnote 21] 
- For example, in June 2007, the Chief Safety Officer formally tasked 
Associate Administrators with 26 actions to support continued 
development of CSA 2010. 

* Contracted with the Volpe Center to provide technical assistance to 
the CSA 2010 team. 

* Requested $5.6 million in its fiscal year 2008 budget to support CSA 
2010. 

Success Factor: Develop a project plan that details actions required 
for implementation. 
* Our assessment: FMCSAï¿½s approach to project planning seems 
reasonable; new graphic format of plan shows relationships among and 
sequencing of tasks better than the format of the earlier master plan. 
We assessed FMCSAï¿½s approach to planning, but not the reasonableness of 
FMCSAï¿½s plan or the likelihood of the agencyï¿½s meeting interim 
milestone dates and the June 2010 deployment date. 
FMCSA Actions: 
* Developed a master planï¿½organized according to the structure of the 
technical subteams that make up the CSA 2010 teamï¿½in August 2006 
(updated June 2007) as a staff-level working document that details 
tasks, start and end dates, and responsible parties. 
- June 2007 update shows a longer time period (30 months) for 
conducting the operational test and evaluating results than was 
depicted in the August 2006 plan (17 months). 
- June 2007 update shows deployment of CSA 2010 beginning 5 months 
later (June 2010) than was depicted in the August 2006 plan (January 
2010). 

* Developed a new plan format in October 2007 that graphically 
illustrates the schedule. 
- Schedule shows intent to conduct 30-month operational test and begin 
deployment in June 2010 (same as June 2007 plan update). 
- Plan is to be used across the agency to convey schedule for 
implementing CSA 2010.

Success Factor: Consult with affected stakeholders. 
* Our assessment: FMCSA has met this success factor to this point; 
effectiveness of future stakeholder consultation will be evident as CSA 
2010 takes its final form prior to implementation.
FMCSA Actions: 
* Held public forums to obtain feedback from stakeholders and provide 
information on the conceptual direction and progress of CSA 2010. 
- Public listening sessions September/October 2004 (6 sessions), 
November 2006, and December 2007. 
- Motor Carrier Safety Advisory Committee meeting (May 2007). [Footnote 
22] 

* Participated in industry-sponsored events such as Commercial Vehicle 
Safety Alliance workshop (September 2007). 

* Included three state officials (from the Colorado State Patrol, South 
Carolina State Patrol, and the Missouri Department of Transportation) 
on the CSA 2010 team. 

* Conducted briefings with transportation officials and industry groups 
in states where CSA 2010 will be operationally tested (Colorado, 
Georgia, Missouri, and New Jersey). 

Success Factor: Select and train members of the project team. 
* Our assessment: FMCSA has met this success factor. We assessed 
FMCSAï¿½s effort to develop a project team, but not the qualifications of 
the FMCSA staff assigned to the team.
FMCSA Actions: 
* Established CSA 2010 team responsible for developing operational 
model (new safety measurement systems and interventions), planning 
operational test, and coordinating rule and policy changes among other 
efforts needed to implement the initiative. [Footnote 23] 
- Staffed full-time positions for Program Manager (reports to Chief 
Safety Officer), Assistant Program Manager, and Program Assistant. 
- Assigned headquarters (3 total), field (10 total), and state partner 
(3 total) staff collateral duty (up to 50%) to the team. 
- Contracted with Volpe Center and technical consultants for support. 
[Footnote 24] 

Success Factor: Provide needed technology and expertise to accomplish 
technical tasks. 
* Our assessment: FMCSA has taken steps to address various technical 
requirements; effectiveness of efforts will be seen in results of the 
operational test. We did not assess the qualifications of FMCSAï¿½s or 
its consultantsï¿½ personnel or the technical quality of their efforts.
FMCSA Actions: 
* Assembled staff with a range of skills and experienceï¿½enforcement, 
data analysis, information technology, training, legalï¿½to support 
technical aspects of CSA 2010 development and implementation. 
- Operational model development: 
* Enforcement and information technology specialists (supported by 
Volpe Center) developed data sources (BASICs) and the computer 
algorithm used to measure the safety fitness of carriers and drivers. 
* Enforcement and legal specialists developed interventions (for 
carriers) and operational definitions for their use. 
- Implementation: 
* Information technology specialists identified needs and continue to 
coordinate with FMCSAï¿½s Office of Information Technology to ensure 
information technology and data systems will be in place to operate CSA 
2010. 
* Data analysis specialists (supported by technical consultant) are 
developing plans for collecting data during the operational test and 
making measurements to assess effectiveness of test. 
* Legal specialists supported development of rules needed to (1) use 
the carrier safety measurement system as a means of determining carrier 
safety fitness and (2) obtain confirmed positive test results for 
individual driversï¿½ use of controlled substances and alcohol. 
* Training specialists (supported by technical consultant) are 
developing training materials and a plan for training investigators in 
the four states where CSA 2010 will be tested.

Success Factor: Sell project to its intended users (FMCSA and the state 
investigators who will use CSA 2010 within the scope of their safety 
enforcement duties). 
* Our assessment: FMCSA has taken initial steps to meet this success 
factor; effectiveness of efforts will be seen as CSA 2010 moves closer 
to deployment.
FMCSA Actions: 
* Developed a change management strategy and action plan that discusses 
ways to communicate the reasons for change and outlines steps for 
addressing usersï¿½ concerns and possible resistance to change. 

* Contracted with a technical consultant to build upon and implement 
portions of the change management strategy and action plan; the 
consultant will: 
- develop communications tools such as poster boards and a one-page 
briefing paper, 
- maintain an updated CSA 2010 Web site, 
- interview internal and external stakeholders, and, 
- train FMCSA and state staff on use of CSA 2010. [Footnote 25] 

Success Factor: Control project by monitoring and providing timely 
feedback. 
* Our assessment: FMCSA has met this success factor to this point; 
effectiveness of efforts will be determined as the initiative 
progresses and control becomes more complex. We assessed FMCSAï¿½s 
framework for monitoring CSA 2010 implementation, but not the 
effectiveness of FMCSAï¿½s monitoring efforts.
FMCSA Actions: 
* Senior officials: 
- FMCSA Administrator receives briefings and provides feedback at key 
decision points. 
* A January 2007 briefing resulted in taskings to Associate 
Administrators that engaged line staff in supporting implementation. 
* A June 2007 briefing resulted in approval to develop new 
rulesï¿½enabling FMCSA to (1) determine safety fitness of carriers using 
new safety measurement concept and (2) collect confirmed positive test 
results for individual driversï¿½ use of controlled substances and 
alcoholï¿½needed to support implementation. 
- Chief Safety Officer maintains oversight via biweekly meetings with 
CSA 2010 Program Manager. 

* CSA 2010 team: 
- Periodic meetings enable planning and coordination. 
- Assignment of staff to multiple technical subteams enhances cross-
team communication. 

Success Factor: Establish a network for and communicate needed 
information to key stakeholders. 
* Our assessment: FMCSA has met this success factor to this point; 
effectiveness of future efforts will be seen as CSA 2010 moves toward 
deployment.
FMCSA Actions: 
* FMCSAï¿½s efforts pertaining to this success factor are evident in 
elements of those previously discussed: 
- consult with affected stakeholders (p. 16), 
- sell project to its intended users (p. 18), and, 
- control project by monitoring and providing timely feedback (p. 18).

Success Factor: Troubleshoot and manage unexpected problems and 
deviations from plan. 
* Our assessment: FMCSA has yet to face a significant unexpected 
problem; effectiveness of future efforts will be seen as CSA 2010 
implementation progresses.
FMCSA Actions: 
* FMCSAï¿½s efforts pertaining to this success factor are evident in 
elements of one previously discussed: 
- control project by monitoring and providing timely feedback (p. 18). 

[End of table] 

Testing and Evaluating CSA 2010: 

Our Assessment: Use of test and control groups for evaluative purposes 
is a conventional practice; FMCSAï¿½s approach to structuring its 
operational test seems reasonable. 
Test Components: 
* The operational test will enable FMCSA to evaluate the carrier 
component of CSA 2010 by assessing: 
- whether the CSA 2010 approach will yield better safety outcomes than 
FMCSAï¿½s current approach and, 
- how carriers react to and how work of investigators is affected 
(qualitatively and quantitatively) by using the interventions. 

* The operational test will not evaluate the driver component of CSA 
2010 to the same extent as the carrier component. 
- Driver measurement system will be used to facilitate driver 
enforcement actions where needed. 
- Implementation of the driver component is contingent upon new 
legislative authorityï¿½that FMCSA intends to request as part of the 
highway statute reauthorizationï¿½for FMCSA to determine fitness of and 
make interventions affecting individual drivers. 
- FMCSA has not established a schedule for testing and deploying the 
driver component. 

* CSA 2010 operational model test will divide carriers from four states 
into test and control groups of about 37,000 carriers in each group. 
- Test group will be subject to CSA 2010 interventions. 
- Control group will be subject to existing enforcement interventions. 

* Operational test will be conducted over 30 months from January 2008 
to June 2010 in two phases. 
- Phase I (begins January 2008): 
* BASICs: unsafe driving, fatigued driving, vehicle maintenance. 
* Interventions to be tested: warning letter, targeted roadside 
inspection, off-site investigation, on-site investigation, cooperative 
safety plan, notice of violation, notice of claim, consent agreement. 
[Footnote 26] 
- Phase II (begins July 2008): 
* All BASICs. 
* Same interventions as Phase I. 

* FMCSA will make adjustments to operating modelï¿½may decide to use 
fewer interventions, for exampleï¿½as test results dictate and will 
proceed with implementation as long as safety benefits can be achieved. 

Our Assessment: Overall, FMCSAï¿½s approach to evaluating CSA 2010 seems 
reasonable. We did not assess evaluation measures or methodologies 
because they were being developed at the end of our fieldwork. 
Test Components: 
* Third-party consultant will develop plan to evaluate the operational 
test and will assist FMCSA in conducting the evaluation. 
- Evaluation reports will be provided at 6-month intervals beginning 
June 2008. 

* FMCSA is considering several methods to determine CSA 2010 safety 
benefits: 
- Evaluating whether CSA 2010 safety measurement system is better at 
identifying unsafe carriers than current methods (e.g., Does CSA 2010 
identify unsafe carriers that would be overlooked under current 
approach using SafeStat?). 
- Comparing changes to key safety indicators experienced by test and 
control groups, for example: 
* Violation rate (change from beginning to end of test). 
* BASIC scores (change from beginning to end of test). 
- Evaluating the effect of individual interventions on safety outcomes. 

* FMCSA intends to evaluate CSA 2010ï¿½s effects on carriers and on 
investigatorsï¿½ work through qualitative and quantitative assessments. 
- Qualitative evaluation will consider: 
* whether interventions are clearly enough defined to enable their 
consistent application, 
* how carriers perceive the interventions, and, 
* if unexpected obstacles to the application of a new intervention 
exist. 
- Quantitative evaluation will consider: 
* the number of people working on new interventions, 
* the number of carriers being contacted, and by which interventions, 
and, 
* how much time (labor hours) each intervention takes. 

[End of table] 

[End of enclosure] 

Enclosure II: 

Project Management Success Factors: 

{See PDF for image] 

This enclosure is an illustration of a timeline for Project Management 
Success Factors. 

The timeline depicts movement from planning to implementation along a 
period of time as follows: 

2004: Initiation; 
2008: Operational test; 
2010: Deploy; 
20XX: Closeout. 

The timeline also depicts planning factors and implementation factors. 
Factors are shown in logical order, but are not intended to represent 
discreet events. In practice, order may vary and steps should be 
examined in relation to each other as well as to their individual 
effect on the project over its life cycle. 

Several factors are a blend of planning and implementation as the 
project management moves through the timeline.

Provide network for and communicate information: 
2004: planning factor; 
2008: blended factor; 
Closeout: implementing factor. 

Monitor and provide feedback to control project: 
2004: planning factor; 
2008: blended factor; 
Closeout: implementing factor. 

Troubleshoot and manage problems: 
2004: planning factor; 
2008: blended factor; 
Closeout: implementing factor. 

Planning and implementation factors: 
Set clear project mission: planning factor; 
Establish top management support: planning factor; 
Develop project schedule and plans: planning factor; 
Consult with all stakeholders: implementation factor; 
Select and train necessary staff for project team: implementation 
factor; 
Provide expertise to address technical tasks: implementation factor; 
Sell project to stakeholders: implementation factor. 

Source: FMCSA and GAO adaptation of Dennis P. Sleven and Jeffrey K. 
Pinto, Balancing Strategy and Tactics in Project Implementation," Sloan 
Management Review (Fall 1987;29.1). 

[End of enclosure] 

Footnotes: 

[15] Operational definitions related to phase 2 of the operational test 
are scheduled to be completed in March 2008. 

[16] See page 20 for details. 

[17] FMCSA has yet to define plans for training safety investigators 
(FMCSA and state staff) in all states. The results of the operational 
test will be used to determine plans for rolling out training to all 
states. 

[18] Evaluation of the operational test may result in changes to the 
CSA 2010 operating modelï¿½for example, certain interventions may be 
altered or eliminated if the test reveals problems with their 
useï¿½however, FMCSA will still deploy CSA 2010 in some form as long as 
it expects to achieve safety benefits above its current approach. 

[19] Safety ratings are contingent upon sufficient data being available 
to determine BASIC scores. Carriers and drivers without sufficient data 
will not receive safety ratings. Rating safety fitness of individual 
drivers is contingent upon FMCSAï¿½s obtaining authority through 
reauthorization of the highway statute. 

[20] Interventions discussed are applicable to carriers. According to 
FMCSA, development of driver interventions depends on it receiving 
authority to regulate individual drivers through reauthorization of the 
highway statute. 

[21] The Chief Safety Officer is a senior administration official 
reporting directly to the FMCSA Deputy Administrator. 

[22] The Motor Carrier Safety Advisory Committee, established in 
September 2006, is a groupï¿½consisting of up to 20 members representing 
the motor carrier industry, safety advocates, and safety enforcement 
officials appointed by the FMCSA Administratorï¿½that provides advice and 
recommendations to the FMCSA Administrator on motor carrier safety 
programs and regulations. The committee is scheduled to conduct public 
meetings at least four times per year to address the agenda set by 
FMCSA. 

[23] Personnel assigned to the CSA 2010 team are staffed to one or more 
technical subteams (10 technical subteams were in place as of September 
2007) that are responsible for coordinating various aspects of 
developing and implementing CSA 2010. 

[24] FMCSA has contracted with a technical consultant to assist with 
training and change management and plans to contract with a second 
technical consultant to support evaluation of the operational test. 

[25] Training will initially be provided to FMCSA and state staff in 
the four states where CSA 2010 is to be operationally tested. 

[26] Currently, FMCSA can suspend a carrier only upon conducting a 
compliance review. To suspend carriers under CSA 2010, FMCSA must issue 
a rule that defines how safety fitness determinations will be made and 
protects carriersï¿½ due process rights. Because this rule will not be 
completed until the operational test is well underway, FMCSA will not 
be using this intervention in its test. If a poor-performing carrier in 
the test group is unresponsive to interventions, it will be removed 
from the test and subjected to a compliance review and related 
enforcement actions (including suspension). 

[End of section] 

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