Commercial Motor Carriers: DOT Is Shifting to Performance-Based Standards
to Assess Whether Carriers Operate Safely (Letter Report, 11/03/97,
GAO/RCED-98-8).

Pursuant to a congressional request, GAO examined the efficiency and
effectiveness of the Federal Highway Administration's Office of Motor
Carriers' commercial motor vehicle safety programs, focusing on the
efforts by the Office and the states to: (1) reduce serious accidents by
conducting roadside inspections and compliance reviews; (2) better
target motor carriers for compliance reviews; and (3) improve the
compliance review criteria for assessing and rating a carrier's safety
fitness.

GAO noted that: (1) federal, state, and industry officials told GAO that
federal and state initiatives to improve the safety of commercial
vehicles and actions taken by trucking firms to improve the safety of
their trucks and drivers were the most important factors behind the
42-percent reduction in the fatal accident rate for large trucks from
1983 to 1995; (2) effective in fiscal year 1998, the Office revised the
criteria for awarding funding from the Motor Carrier Safety Assistance
Program to provide each state with more flexibility in choosing the
combination of programs--including roadside inspections and compliance
reviews--that would best reduce accidents involving commercial vehicles;
(3) in April 1997, consistent with the Government Performance and
Results Act of 1993, the Office began using performance-based data
through its Safety Status Measurement System to identify carriers with
the worst highway safety records; (4) while many states have improved
the completeness and timeliness of their data submissions in recent
years, the Office found that: (a) the states, overall, reported only
about 74 percent of the recordable accidents in 1995; and (b) during
fiscal year 1997, five states submitted accident data more than 6
months, on average, after the accidents occurred; (5) without these
data, the Office and the states cannot effectively target their limited
compliance review resources on the motor carriers with safety problems;
(6) the Office is in the early stages of revising its criteria for
assessing and rating a commercial motor carrier's safety fitness; (7)
the Office rates carriers on the basis of compliance reviews that
examine a carrier's: (a) compliance with federal motor carrier safety
regulations (primarily those related to financial responsibility,
drivers' qualifications and operations, including hours-of-service,
vehicle inspection and maintenance, and any hazardous materials
handling); and (b) recordable, preventable accident rate; (8) while
compliance reviews will continue to be an important element of the
federal motor carrier safety program, the Office plans to publish an
advance notice of proposed rulemaking to solicit public comments on
alternatives for rating motor carriers' safety fitness; and (9) one
option under consideration is to rely on accident date, roadside
inspections, and other performance-based data for safety fitness
ratings.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-98-8
     TITLE:  Commercial Motor Carriers: DOT Is Shifting to 
             Performance-Based Standards to Assess Whether Carriers 
             Operate
             Safely
      DATE:  11/03/97
   SUBJECT:  Trucking operations
             Motor vehicle safety
             Inspection
             Public roads or highways
             Accident prevention
             Traffic accidents
             Safety regulation
             Federal/state relations
             Motor carrier operations
IDENTIFIER:  FHwA Motor Carrier Safety Assistance Program
             FHwA Safety Status Measurement System
             
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Cover
================================================================ COVER


Report to the Honorable Ray LaHood
House of Representatives

November 1997

COMMERCIAL MOTOR CARRIERS - DOT IS
SHIFTING TO PERFORMANCE-BASED
STANDARDS TO ASSESS WHETHER
CARRIERS OPERATE SAFELY

GAO/RCED-98-8

Commercial Motor Carriers

(348032)


Abbreviations
=============================================================== ABBREV

  DOT - Department of Transportation
  GAO - General Accounting Office
  ISS - Inspection Selection System
  MCSAP - Motor Carrier Safety Assistance Program
  OMC - Office of Motor Carriers
  SCE - Selective Compliance and Enforcement
  SEA - Safety Evaluation Area
  ASPEN -
  U.S.DOT

Letter
=============================================================== LETTER


B-277481

November 3, 1997

The Honorable Ray LaHood
House of Representatives

Dear Mr.  LaHood: 

About 5,000 people die annually in the United States in accidents
involving commercial motor vehicles (large trucks, commercial buses,
and hazardous materials vehicles).  To reduce serious accidents
involving these vehicles, the Office of Motor Carriers, within the
Department of Transportation's (DOT) Federal Highway Administration,
is responsible for implementing commercial motor vehicle safety
programs.  The Office of Motor Carriers' investigators conduct
on-site reviews of motor carriers' compliance with federal safety
regulations, known as compliance reviews, that are used to determine
whether each carrier is fit to operate safely on the nation's
highways, known as a safety fitness rating.  The Office of Motor
Carriers also provides matching grants under the Motor Carrier Safety
Assistance Program for states to perform roadside inspections of
commercial vehicles and drivers, compliance reviews, and other
commercial vehicle safety programs.  The reauthorization of the Motor
Carrier Safety Assistance Program is currently under consideration by
the Congress as part of the deliberations over reauthorizing the
Intermodal Surface Transportation Efficiency Act of 1991. 

You requested that we examine the efficiency and effectiveness of the
Office of Motor Carriers' commercial motor vehicle safety programs. 
Specifically, you asked us to report on the efforts by the Office of
Motor Carriers and the states to (1) reduce serious accidents by
conducting roadside inspections and compliance reviews, (2) better
target motor carriers for compliance reviews, and (3) improve the
compliance review criteria for assessing and rating a carrier's
safety fitness.  To obtain this information, we interviewed the Motor
Carrier Safety Assistance Program's coordinators for 16 states that
we selected to provide geographical diversity and a range of
compliance reviews performed.  We also contacted participants in the
five-state pilot program of the Office of Motor Carriers' new Safety
Status Measurement System, which uses accident data and the results
of roadside inspections and compliance reviews to identify motor
carriers with poor on-the-road performance for compliance reviews. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

Federal, state, and industry officials told us that federal and state
initiatives to improve the safety of commercial vehicles and actions
taken by trucking firms to improve the safety of their trucks and
drivers were the most important factors behind the 42-percent
reduction in the fatal accident rate for large trucks from 1983 to
1995.\1 In particular, the number of roadside inspections increased
from 25,000 performed by federal inspectors in fiscal year 1983 to
2.1 million performed predominantly by state inspectors in fiscal
1996.  Compliance reviews also increased from 6,211 in fiscal year
1989 to 8,952 in fiscal 1996, in part because the Office of Motor
Carriers encouraged the states to develop comprehensive safety
programs for commercial vehicles, including compliance reviews. 
Effective in fiscal year 1998, the Office of Motor Carriers revised
the criteria for awarding funding from the Motor Carrier Safety
Assistance Program to provide each state with more flexibility in
choosing the combination of programs--including roadside inspections
and compliance reviews--that would best reduce accidents involving
commercial vehicles. 

The Office of Motor Carriers has sought to target motor carriers that
pose the greatest potential risk to highway safety for compliance
reviews.  To do this, the Office of Motor Carriers often targeted
passenger carriers and hazardous materials carriers--because of the
potential serious consequences if their vehicles were involved in
accidents--rather than carriers with the worst highway safety
records.  As a result, 63 percent of the carriers that received a
compliance review in fiscal year 1996 had not had a recordable
accident\2 during the previous 12 months.  In April 1997, consistent
with the Government Performance and Results Act of 1993, the Office
of Motor Carriers began using performance-based data through its
Safety Status Measurement System to identify carriers with the worst
highway safety records.  Complete and timely data on accidents,
roadside inspections, and compliance reviews that the states submit
to the Office of Motor Carriers are key to implementing
performance-based criteria.  While many states have improved the
completeness and timeliness of their data submissions in recent
years, the Office of Motor Carriers found that (1) the states,
overall, reported only about 74 percent of the recordable accidents
in 1995 and (2) during fiscal year 1997, five states submitted
accident data more than 6 months, on average, after the accidents
occurred.  Without these data, the Office of Motor Carriers and the
states cannot effectively target their limited compliance review
resources on the motor carriers with safety problems. 

The Office of Motor Carriers is in the early stages of revising its
criteria for assessing and rating a commercial motor carrier's safety
fitness.  Currently, the Office of Motor Carriers rates carriers on
the basis of compliance reviews that examine a carrier's (1)
compliance with federal motor carrier safety regulations (primarily
those related to financial responsibility; drivers' qualifications
and operations, including hours-of-service; vehicle inspection and
maintenance; and any hazardous materials handling) and (2)
recordable, preventable accident rate.  Trucking industry
representatives favor revising the existing criteria for a safety
fitness rating because, in their opinion, these criteria give too
much weight to such record-keeping requirements as drivers'
hours-of-service records instead of on-the-road safety performance. 
While compliance reviews will continue to be an important element of
the federal motor carrier safety program, the Office of Motor
Carriers plans to publish an advance notice of proposed rule making
later this year to solicit public comments on alternatives for rating
motor carriers' safety fitness.  One option under consideration is to
rely on accident data, roadside inspections, and other
performance-based data for safety fitness ratings.  This approach
depends on the successful implementation of the Safety Status
Measurement System and improved reporting of safety data. 


--------------------
\1 Large trucks accounted for 99 percent of the fatal accidents
involving commercial motor vehicles in 1995. 

\2 A recordable accident is defined as one involving a commercial
vehicle operating on a public road that resulted in a fatality,
bodily injury that required medical treatment, or the towing of a
vehicle from the accident scene. 


   BACKGROUND
------------------------------------------------------------ Letter :2

Established in 1983, the Motor Carrier Safety Assistance Program
(MCSAP) provides grants to states to support commercial motor vehicle
safety programs aimed at (1) large trucks that have a gross vehicle
weight rating of at least 10,000 pounds, (2) vehicles used to
transport more than 10 passengers, and (3) vehicles used to transport
hazardous materials.  Under MCSAP, the federal government funds up to
80 percent of the costs of each state's motor carrier safety program. 
Federal funding for MCSAP has increased from $8 million in fiscal
year 1984 to $78.2 million in fiscal 1997.  The Intermodal Surface
Transportation Efficiency Act of 1991 required that by January 1994,
each of the 48 contiguous states participate in Safetynet, the Office
of Motor Carrier's (OMC) automated database system used to monitor
the safety performance of commercial motor carriers.  The act also
directed OMC to provide grants for states to develop a Commercial
Vehicle Information System\3 that would link OMC's motor carrier
safety information with states' motor vehicle registration systems. 
The Commercial Vehicle Information System project led to the
development of OMC's Safety Status Measurement System (SafeStat)
program. 

The Motor Carrier Safety Act of 1984 directed the Secretary of
Transportation to establish a procedure to determine the safety
fitness of owners and operators of commercial vehicles.  In response,
OMC modified its existing safety management audit program to
institute safety reviews\4 with follow-up compliance reviews.  During
a compliance review, OMC and/or state investigators perform an
on-site review of a motor carrier's compliance with federal safety
regulations by assessing its policies, management controls, and
operations.  Typically, investigators examine a sample of the
carrier's records, including drivers' hours-of-service logs,
commercial drivers' license requirements, alcohol- and drug-testing
records, vehicle maintenance and inspection records, and accident
records.  Investigators also may perform full vehicle inspections of
several of the carrier's vehicles.  The investigators give the
carrier a satisfactory, conditional, or unsatisfactory rating on the
basis of this review. 

From 1983 through 1995, the rate of fatal accidents involving large
trucks dropped by 42 percent--from 4.3 to 2.5 fatal accidents per 100
million vehicle miles traveled.\5 (See fig.  1.) The lower fatal
accident rate reflects a (1) 57-percent growth in total vehicle miles
driven by large trucks and (2) 9-percent drop in the number of large
trucks involved in fatal accidents.  However, almost all of this
decline occurred during MCSAP's first 10 years; since 1992, the fatal
accident rate has been relatively stable.  In contrast, the total
number of large trucks involved in fatal accidents increased from
4,035 in 1992 to 4,740 in 1996; 4,035 and 5,126 people died from
these accidents, respectively.  (See table I.1 in app.  I.)

   Figure 1:  Rate of Fatal
   Accidents Involving Large
   Trucks, 1983 Through 1995

   (See figure in printed
   edition.)

Source:  National Highway Traffic Safety Administration. 

The interstate trucking industry has grown rapidly in recent years
from about 213,000 firms in 1990 to about 379,000 in 1996. 


--------------------
\3 OMC recently changed the name of this program to Performance
Registration Information System Management. 

\4 Safety reviews were designed to teach motor carriers about safety
regulations and determine whether the carriers' safety management
controls complied with these regulations.  In 1994, OMC replaced
safety reviews with educational contacts performed only by states
that do not rate a carrier's operations. 

\5 DOT's traffic safety data track large trucks more carefully than
other commercial vehicles because the former are involved in
substantially more fatal accidents.  For example, only 23 intercity
buses were involved in fatal accidents in 1995. 


   MCSAP AND OTHER INITIATIVES
   HAVE CONTRIBUTED TO IMPROVED
   COMMERCIAL MOTOR VEHICLE SAFETY
------------------------------------------------------------ Letter :3

OMC and state officials and industry representatives told us that the
most important factors in reducing the rate of fatal accidents
involving commercial vehicles were federal and state initiatives to
improve safety for commercial vehicles and actions that trucking
firms have taken to improve the safety of their trucks and drivers. 
In particular, the states assumed the responsibility for conducting
roadside inspections of commercial vehicles under MCSAP, and OMC
expanded its compliance review program under the 1984 safety fitness
requirement.  OMC and the states also established drug- and
alcohol-testing requirements and a commercial driver's license
program designed to eliminate the opportunity for drivers to evade
law enforcement penalties by using commercial licenses from more than
one state.  As OMC and the states expanded their safety programs,
many trucking firms implemented safety programs and improved their
vehicles' maintenance.  OMC recently announced that it will work with
the states to develop performance-based Commercial Vehicle Safety
Plans that give each state more flexibility to decide the best
combination of programs for reducing truck accidents while
maintaining the current levels of roadside inspections. 


      STATES CONDUCT ALMOST ALL
      ROADSIDE INSPECTIONS
---------------------------------------------------------- Letter :3.1

With the establishment of MCSAP, the responsibility for conducting
roadside inspections of commercial vehicles shifted from OMC to the
states.  As a result, total inspections increased from 25,000
performed by OMC inspectors in 1983 to 2.1 million performed
predominantly by state inspectors in 1996.  (See table I.2 in app. 
I.) The use of state inspectors also expanded the program's coverage
because federal personnel are authorized to inspect only commercial
vehicles engaged in interstate and foreign commerce, while state
personnel can inspect vehicles operating in both intrastate and
interstate commerce.  In fiscal year 1996, 16 percent of the vehicles
inspected were engaged in intrastate commerce. 

State inspectors and enforcement officers can conduct any of five
levels of inspection that focus on the vehicle and/or the driver. 
Level 1 inspections,\6 the most rigorous, accounted for 46 percent of
the fiscal year 1996 inspections, ranging from 91 percent of the
inspections in California to 4 percent of the inspections in South
Dakota.  (See table I.3 in app.  I.) In comparison, level 2
inspections, which check the driver and readily observable vehicle
items--such as tires and lights but not the brakes--accounted for 30
percent of the inspections; level 3 inspections, which focus on such
driver-related items as hours of service and the commercial driver's
license, accounted for 22 percent of the inspections; and level 4 and
level 5 inspections (special purpose inspections) accounted for the
remaining 2 percent of the inspections in fiscal year 1996. 

An important measure of safety is the percentage of vehicles and
drivers that inspectors put out of service until violations are
corrected.  Out-of-service rates for vehicles have dropped from a
high of 39 percent, on average, in fiscal year 1986 to 21 percent, on
average, in fiscal 1996.\7 The out-of-service rate for drivers
generally has remained steady, ranging from 6 to 8 percent during
this period.  State police officials responsible for roadside
inspection programs in several states told us that the condition of
trucks on the road today is substantially better than that of trucks
at the beginning of MCSAP. 


--------------------
\6 A level 1 inspection involves a complete examination of the
vehicle, including (1) an examination of brakes, tires, lights, and
the load, to determine if it is properly secured, and (2) a review of
the driver, including hours-of-service logs. 

\7 The out-of-service rate for vehicles in fiscal year 1996 was 26.3
percent if level 3 and level 4 inspections, which primarily focus on
the driver, are excluded. 


      STATES ARE PERFORMING MORE
      COMPLIANCE REVIEWS
---------------------------------------------------------- Letter :3.2

While OMC has had the primary responsibility for conducting
compliance reviews since the inception of the safety fitness program,
many states have substantially increased their involvement in an
effort to develop comprehensive commercial vehicle safety programs. 
OMC performed 6,211 compliance reviews and the states performed 5 in
fiscal year 1989, the first year for which data are available.  In
fiscal year 1996, OMC performed 5,241 compliance reviews, and states
performed 3,711.\8 (See table I.4 in app.  I.) Figure 2 shows that 26
states performed at least 25 compliance reviews in fiscal year 1996;
11 states performed fewer than 25 compliance reviews; and 13 states,
the District of Columbia, and Puerto Rico did not perform any
compliance reviews. 

   Figure 2:  Compliance Reviews
   Performed by Each State, Fiscal
   Year 1996

   (See figure in printed
   edition.)

   Note:  Totals exclude
   California's terminal
   inspections as well as any
   compliance reviews of shippers,
   intrastate carriers,
   16-passenger vans, and school
   buses.

   (See figure in printed
   edition.)

   Source:  OMC.

   (See figure in printed
   edition.)

The 16 MCSAP state coordinators we contacted generally believe that
compliance reviews are an essential element of a comprehensive
commercial vehicle safety program.  Greater state involvement in
conducting compliance reviews would extend the program's coverage to
include intrastate motor carriers, which OMC has no authority to
audit.  During the past 3 years, about 26 percent of the commercial
vehicle accidents reported to Safetynet involved vehicles operated by
intrastate carriers, including dump trucks and garbage trucks. 
Maryland State Police officials noted that these trucks may rarely be
inspected because they operate within a metropolitan area and can
more readily bypass state weigh stations by using other routes.  In
fiscal year 1996, 24 states conducted compliance reviews of one or
more intrastate commercial motor carriers. 

OMC officials told us that their policy is to encourage, but not
require, states to develop compliance review programs.  While the OMC
officials support a greater state role in conducting compliance
reviews, they noted that OMC wants to give each state more
flexibility to decide the combination of programs that would best
reduce commercial vehicle accidents.  OMC also has offered states the
option to issue "U.S.  DOT numbers" to intrastate carriers and enter
them into OMC's motor carrier management information system to
provide a single set of identification numbers for tracking accidents
and the results of roadside inspections and compliance reviews.\9 OMC
requires, however, that states conduct a census of their intrastate
carriers to provide a complete and accurate list of carriers. 
Connecticut, Kentucky, Indiana, Utah, and Wyoming have completed
their census, and other states have expressed an interest in using
U.S.  DOT numbers. 

MCSAP coordinators for several states we contacted believe that their
state could assume lead responsibility for conducting compliance
reviews.  However, MCSAP coordinators in several other states
expressed concern about further expanding their state's role in the
compliance review program because of funding and personnel
constraints.  For example, one coordinator stated that, without
additional MCSAP funding, his state may have to reduce the number of
roadside inspections to conduct more compliance reviews.  Some MCSAP
coordinators also told us that their state laws do not provide them
with adequate legal authority to conduct compliance reviews of
intrastate carriers or to impose civil fines for the violations found
during a review. 


--------------------
\8 In addition, the California Highway Patrol performed 14,785
terminal inspections pursuant to California state law.  These
terminal inspections do not meet OMC's compliance review standards
because they do not include, for example, a review of a carrier's
policies and drivers' hours-of-service logs. 

\9 OMC requires that each interstate motor carrier obtain either a
U.S.  DOT number or an Interstate Commerce Commission number and
display it on each of its interstate vehicles.  DOT has initiated a
rule making to consolidate the two sets of carrier numbers in
response to the termination of the Interstate Commerce Commission in
1995. 


      OMC REQUIRES
      PERFORMANCE-BASED STATE
      SAFETY PLANS
---------------------------------------------------------- Letter :3.3

Effective in fiscal year 1998, OMC initiated performance-based
Commercial Vehicle Safety Plans to replace the State Enforcement Plan
that each state submits annually as a basis for receiving MCSAP
funds.  The new plan is intended to give each state more flexibility
in choosing the combination of programs that would best achieve the
goal of reducing motor carrier accidents in the state while retaining
minimum levels of effort for roadside inspections.  In contrast, the
State Enforcement Plan had established safety activity goals for the
forthcoming year, including the number of roadside inspections and
law enforcement activities. 

In fiscal year 1996, OMC provided the states with $54 million for
MCSAP's basic grant program and $22.6 million for designated program
activities, such as hazardous materials training and covert
operations.\10 (See table I.5 in app.  I.) Several MCSAP coordinators
suggested moving some of MCSAP's designated program funding to
MCSAP's basic grant funding because, in accordance with the new
Commercial Vehicle Safety Plans, the states should be given more
flexibility to determine the best use of funds for reducing motor
carrier accidents.  Some MCSAP coordinators said that using funds for
designated activities sometimes is not an efficient use of their
state's limited resources, adding that their state could use these
funds more productively in other motor carrier safety programs. 


--------------------
\10 The covert operations program is designed to catch out-of-service
vehicles that leave a roadside inspection area before repairs have
been made. 


   SAFESTAT IS DESIGNED TO BETTER
   TARGET COMPLIANCE REVIEWS
------------------------------------------------------------ Letter :4

OMC and the states have rated the safety fitness of about 34 percent
of the 379,000 commercial motor carriers currently engaged in
interstate and foreign commerce.  In 1989, OMC had announced its
intention to assess the safety fitness of each commercial motor
carrier.  However, because the number of interstate carriers has
grown rapidly in recent years and resources for conducting compliance
reviews are limited, OMC subsequently targeted compliance reviews on
carriers that pose the greatest potential risk to highway safety.  In
fiscal year 1996, OMC and the states conducted 8,952 compliance
reviews of commercial motor carriers, including about 4,324
first-time reviews and 4,628 follow-up reviews. 

In fiscal year 1996, OMC identified motor carriers for compliance
reviews primarily through its Selective Compliance and Enforcement
(SCE) list, which prioritized motor carriers on such factors as the
commodity being transported and the carrier's out-of-service rate for
vehicles, prior compliance reviews, and the written complaints that
it had received.  In April 1997, consistent with the Government
Performance and Results Act of 1993,\11 OMC began using SafeStat, a
computer program that uses performance-based data on accidents,
roadside inspections, and compliance reviews to identify problem
carriers.  OMC also is working with the states to improve the
completeness and timeliness of their safety data reporting to the
Safetynet database. 


--------------------
\11 The act required federal agencies to develop, by the end of
fiscal year 1997, 5-year strategic plans that are the starting point
for agencies to set annual goals for programs and measure their
performance in achieving these goals.  (See 5 U.S.C.  306.)


      OMC'S SCE LIST USED
      DESCRIPTIVE AND PERFORMANCE
      DATA
---------------------------------------------------------- Letter :4.1

As shown in table 1, OMC used the SCE list to select 46 percent of
the motor carriers for a compliance review in fiscal year 1996.  The
SCE list prioritized motor carriers on the basis of (1) the commodity
transported; (2) their annual mileage; (3) the months since the last
safety fitness rating; (4) their vehicles' out-of-service rate; (5)
their drivers' out-of-service rate; (6) their preventable, recordable
accident rate; and (7) their overall safety fitness rating.  (See
app.  II for a more detailed description of each factor.) Of the
remaining compliance reviews conducted, 14 percent were to follow up
prior enforcement cases, 14 percent were in response to
complaints,\12 9 percent were initial reviews of carriers'
operations; 4 percent were in response to carriers' requests for a
compliance review; and 12 percent were for other reasons.  Among the
other reasons for a compliance review is if a motor carrier's vehicle
was involved in a major accident that resulted in multiple fatalities
or closed down an interstate highway for several hours. 



                                Table 1
                
                 Source of Compliance Reviews in Fiscal
                               Year 1996

                                         Number of
Category                        compliance reviews             Percent
------------------------------  ------------------  ------------------
SCE rating                                   4,406                  46
Enforcement follow-up\a                      1,387                  14
Complaint\a                                  1,356                  14
Initial review\b                               910                   9
Carrier request                                369                   4
Other reasons                                1,159                  12
----------------------------------------------------------------------
\a In February 1997, OMC issued guidance that no longer requires that
a compliance review be conducted in response to an enforcement case
or a complaint about a carrier if its on-the-road performance meets
OMC's criteria. 

\b OMC has stopped citing this reason because it no longer seeks to
provide a safety fitness rating for each motor carrier. 

Source:  OMC. 

Compliance review investigators found that 63 percent of the carriers
examined in fiscal year 1996 did not have a recordable accident
during the previous 12 months.  OMC also calculated that the national
average accident rate for all carriers that had a compliance review
in fiscal year 1996 was 0.5 recordable, preventable accidents per
million miles driven.  About 77 percent of these carriers had an
accident rate below the average rate. 

In a March 1997 report,\13 the DOT Office of Inspector General found
that OMC's SCE list did not ensure that carriers with the worst
safety records were targeted for compliance reviews.  In particular,
the report stated that the SCE list did not define problem carriers
and used factors that did not sufficiently emphasize on-the-road
performance to prioritize carriers.  For example, a carrier that
transported passengers or hazardous materials was given more points
and, therefore, was more likely to be reviewed than one that
transported general freight, regardless of each carrier's actual
accident record.  The report also stated that a carrier's annual
mileage, the number of months since its last safety fitness rating,
and its overall safety fitness rating were descriptive factors not
directly related to the carrier's on-the-road performance.  The
Inspector General recommended that OMC replace its existing system
for prioritizing carriers for compliance reviews with one that uses
on-the-road performance and stated that the implementation of
SafeStat satisfied the recommendation's intent. 


--------------------
\12 The Motor Carrier Safety Act of 1984 requires OMC to investigate
any nonfrivolous written complaint alleging a substantial violation
of federal motor carrier safety regulations. 

\13 Motor Carrier Safety Program:  Federal Highway Administration,
DOT Office of Inspector General (AS-FH-7-006, Mar.  26, 1997). 


      SAFESTAT USES SAFETY DATA TO
      IMPROVE TARGETING
---------------------------------------------------------- Letter :4.2

To address the limitations associated with the SCE list in
identifying commercial motor carriers with poor on-the-road
performance, OMC has worked with the Volpe National Transportation
Systems Center, a DOT research laboratory, to develop the SafeStat
computer program.  SafeStat ranks motor carriers on the basis of
performance-based data in four safety evaluation areas (SEA):  (1)
accident rates; (2) driver factors, including out-of-service
violations from roadside inspections; (3) vehicle factors, including
out-of-service violations from roadside inspections; and (4) safety
management practices and policy, including the results of prior
compliance reviews and enforcement actions.  SafeStat also weights
these data on the basis of the severity and age of an event.  For
example, SafeStat gives more weight to a fatal or serious injury
accident than to a tow-away accident and to an accident that occurred
within 6 months than one that occurred more than 6 months previously. 
(See app.  III for a more detailed description of SafeStat.)

Table 2 shows the SafeStat categories for carriers ranked among the
worst 25 percent of all carriers in at least one SEA.  OMC will
conduct a compliance review of each carrier included in category A or
category B.  OMC also considers those carriers in category C to be
poor performers.  Each category A, B, and C motor carrier remains in
OMC's Motor Carrier Safety Improvement Process until its on-the-road
performance improves sufficiently for SafeStat not to subsequently
identify them. 



                                Table 2
                
                SafeStat Categories for Carriers Ranked
                   Among the Worst 25 Percent of All
                      Carriers in at Least One SEA

Category                        SEA ranking
------------------------------  --------------------------------------
A                               Carrier among the worst 25 percent of
                                all carriers in either all four SEAs
                                or the accident SEA plus two other
                                SEAs.

B                               Carrier among the worst 25 percent of
                                all carriers in either three SEAs,
                                excluding the accident SEA, or the
                                accident SEA plus one other SEA.

C                               Carrier among the worst 25 percent of
                                all carriers in two SEAs, excluding
                                the accident SEA.

D                               Carrier among the worst 25 percent of
                                all carriers in the accident SEA.

E                               Carrier among the worst 25 percent of
                                all carriers in the driver SEA.

F                               Carrier among the worst 25 percent of
                                all carriers in the vehicle SEA.

G                               Carrier among the worst 25 percent of
                                all carriers in the safety management
                                SEA.
----------------------------------------------------------------------
The Volpe National Transportation Systems Center tested SafeStat's
effectiveness in identifying problem carriers by using prior year
information and then comparing the subsequent accident rates of
carriers that SafeStat identified as being poor performers with those
for all other carriers.  The Volpe Center found, in particular, that
the subsequent accident rate for poor performers in the (1) accident
SEA was 259 percent higher than that for motor carriers not
identified and (2) driver SEA was 81 percent higher than that for
motor carriers not identified.  Many of the MCSAP coordinators we
interviewed believe that SafeStat will considerably improve the
targeting of problem carriers for compliance reviews as compared with
the SCE list's criteria.  OMC officials noted that if SafeStat
targets problem carriers better than the SCE list does, OMC and state
investigators could improve the program's effectiveness while
performing about the same number of compliance reviews.  However, OMC
officials noted that better targeting could reduce the total number
of compliance reviews performed because investigators may become
involved with more complex enforcement cases, increasing the staff
days spent per case. 

In April 1997, OMC used SafeStat to generate its first nationwide
list of problem carriers, which included 1,700 category A and B
carriers and 3,300 category C carriers.  OMC will generate a new list
of problem carriers every 6 months.  Beginning in October 1997, OMC
is sending letters to category C motor carriers notifying them of
their poor safety performance.  Each letter will identify the
carrier's accidents, out-of-service orders from roadside inspections,
and violations and enforcement actions from compliance reviews that
provide the basis for the SafeStat score.  The letters will give a
carrier the opportunity to correct any database mistakes, especially
if an accident or inspection was wrongly assigned to the carrier. 
The letters will advise category C carriers that they will be subject
to a compliance review unless their SafeStat score subsequently
improves. 

OMC's policy that a compliance review be performed of each category A
and B carrier includes a revisit to any carrier that remains in
either category A or B when a new SafeStat list is generated.  OMC
also plans to conduct a compliance review of any carrier listed in
category C after the carrier has been listed in category C for a
third time.  In addition to these motor carriers, OMC's regional
offices can target other motor carriers from (1) category D carriers
that were among the worst 25 percent of the carriers in the accident
category only and/or (2) hazardous materials carriers and bus
companies that the SCE list prioritized because of the potential
severity of an accident involving these carriers.  Roadside
inspection data may not be sufficient for a SafeStat ranking for bus
companies because buses often are allowed to bypass weigh stations so
that passengers are not inconvenienced. 

SafeStat is part of the larger Commercial Vehicle Information System
demonstration program.  The program links OMC's databases with
states' motor vehicle registration systems, which provide current
information on each vehicle that a carrier operates.  An OMC official
told us that the extension of the Commercial Vehicle Information
System demonstration program to all 50 states is essential to enable
SafeStat to effectively compare accident rates among carriers. 


      MANY STATES HAVE IMPROVED
      THE COMPLETENESS AND
      TIMELINESS OF THEIR
      SAFETYNET DATA
---------------------------------------------------------- Letter :4.3

A key element in implementing performance-based criteria for
selecting motor carriers is ensuring that the Safetynet database
contains complete, accurate, and timely data about each motor
carrier's safety performance.  The Intermodal Surface Transportation
Efficiency Act of 1991 took a first step toward developing a
comprehensive database by requiring that the 48 contiguous states
submit data to Safetynet on commercial vehicles' recordable accidents
and the results of roadside inspections and compliance reviews.  The
states have substantially improved the quantity and quality of the
safety data on commercial vehicles reported to Safetynet since 1991. 
(See app.  IV for three examples of innovative ways that the states
are collecting, analyzing, and using these data to improve traffic
enforcement.) OMC and the states increased the percentage of reported
accidents from about 14 percent in fiscal year 1992 to an estimated
74 percent in fiscal 1995. 

To improve the completeness, accuracy, and timeliness of roadside
inspection data, OMC has provided funding through MCSAP grants for
states to purchase laptop computers and special software, known as
ASPEN, that enable inspectors to upload inspection results directly
into Safetynet's electronic database.  Using ASPEN, instead of paper
forms, improves accuracy because the software alerts inspectors to
inconsistent information, particularly if the carrier's name and the
entered U.S.  DOT number do not match.  (Without the correct U.S. 
DOT number, SafeStat cannot attribute the inspection results to the
motor carrier.) The electronic entry of the inspection results also
substantially reduces the time needed to transmit data to Safetynet
because it eliminates the step of mailing paper forms to a central
office for entry into the computer's database. 

In addition, to better ensure that adequate inspection data are
collected on the drivers and vehicles of individual motor carriers,
OMC introduced the Inspection Selection System (ISS) software in
1995.  As of March 1997, 36 states were using ISS to help inspectors
select vehicles for inspection and focus the inspection on problems
identified in a carrier's previous inspections.  As a vehicle pulls
into an inspection station, its U.S.  DOT number is entered into ISS. 
The program assigns the vehicle a score on the basis of the number
and the results of the motor carrier's previous inspections and
compliance reviews.  Specifically, ISS recommends an inspection for a
motor carrier that has a poor safety record or has had very few
roadside inspections relative to its size in the prior 2 years. 
Alternatively, state inspectors may select vehicles for inspections
on the basis of either random sampling or judgmental factors,
including the type of commodity transported or observed safety
violations. 

Improving the completeness, accuracy, and timeliness of accident data
is more difficult than improving roadside inspection data primarily
because (1) accident reporting is decentralized, involving many more
state and local law enforcement officers, and (2) the officer at an
accident scene often has other more urgent concerns and gives low
priority to obtaining all of the necessary information and filing the
accident report with the state.  Several states told us that they are
taking actions to encourage their law enforcement officers to improve
the reporting of accidents involving commercial vehicles.  For
example, some states we contacted are providing officers with more
training in completing the 22-item supplemental form developed by the
National Governors' Association for reporting commercial vehicle
accidents.  Similarly, some states are incorporating the supplemental
form's items into their basic accident-reporting form to further
streamline the needed information.  An OMC official noted that
accident reporting is likely to improve as law enforcement officers
become aware that SafeStat is using their reports to identify poor
performers in their states. 

In December 1996, OMC provided the states with guidance that
tightened the time frames for uploading (1) roadside inspection and
compliance review data to within 7 days if the data are collected
electronically or within 21 days if paper forms are used and (2)
accident data to within 90 days from the date of the accident. 
Previously, the standards for uploading the information were 90 days
for inspections, 30 days for compliance reviews, and 180 days for
accidents.  OMC's data showed that the states, on average, had
reduced the time for uploading roadside inspection data to Safetynet
from 49 days in fiscal year 1996 to 42 days in fiscal 1997.  However,
42 states did not meet OMC's 21-day standard for paper forms, and
only Connecticut met OMC's 7-day standard for electronically
uploading inspection data.  OMC's data show that the states, on
average, reduced the time for uploading accident data to Safetynet
from 159 days in fiscal year 1996 to 98 days in fiscal 1997.  (This
improvement is somewhat overstated because no accident data for
Maryland were uploaded during fiscal year 1997.) Five states did not
meet OMC's former 180-day standard for uploading accident data during
fiscal year 1997. 

Eight of the 16 MCSAP coordinators we contacted do not believe that
their state will meet the tighter time frames for uploading
inspection and compliance review data.  Eight MCSAP coordinators also
do not believe that their state will meet the new accident-reporting
time frames.  For example, Ohio's MCSAP coordinator told us that Ohio
relies on the voluntary cooperation of local police departments to
report commercial vehicle accidents, unlike many states that require
state and local police to file traffic accident reports with a state
highway agency.  Ohio's MCSAP coordinator also noted that uploading
accident data into Safetynet has been delayed by a backlog in
electronically entering the data from paper forms in the state's
central office.  OMC officials acknowledged that if commercial motor
carriers' accidents were unreported, their SafeStat rankings would be
reduced for the accident SEA, possibly allowing some carriers to
avoid being listed among the worst 25 percent of the performers and
subsequently not receive a compliance review. 


   OMC HAS USED COMPLIANCE REVIEWS
   TO RATE A CARRIER'S SAFETY
   FITNESS
------------------------------------------------------------ Letter :5

OMC uses a compliance review to assess a commercial motor carrier's
management controls that results in a safety fitness rating. 
Trucking industry representatives have opposed using compliance
reviews to rate a carrier's safety fitness, stating that too much
weight is given to record-keeping requirements that may not correlate
with a firm's on-the-road safety performance.  While OMC will
continue to perform compliance reviews, especially to upgrade the
safety management of problem carriers, OMC plans to publish an
advance notice of proposed rule making later this year to solicit
public comments on alternatives for rating a carrier's safety
fitness, including the possible use of performance-based criteria. 


      DRIVERS' HOURS-OF-SERVICE
      REGULATIONS RESULT IN THE
      MOST SAFETY VIOLATIONS
---------------------------------------------------------- Letter :5.1

In a compliance review, trained investigators assess a motor
carrier's compliance with federal motor carrier safety regulations
that are divided into general, driver-related, operations-related,
vehicle-related, and hazardous materials-related rating factors.\14
The investigators also examine the carrier's recordable accidents. 
OMC distinguishes among its motor carrier safety regulations by
designating certain regulations as (1) acute, because violating one
of these regulations would create an immediate risk to persons or
property, or (2) critical, because violations, if occurring in
patterns,\15 would indicate a breakdown in the effective control over
essential safety functions.  Examples of acute regulations are
several related to controlled substances and alcohol use and testing. 
Examples of critical regulations are several driver's
hours-of-service regulations that specify the maximum working hours
and minimum hours off duty for drivers at selected times during an
8-day period. 

Each compliance rating factor is evaluated to determine whether the
carrier violated any of the acute and critical regulations.  A
carrier's rating factor is (1) satisfactory if no violations of acute
or critical regulations exist, (2) conditional if one violation of an
acute or critical regulation exists, and (3) unsatisfactory if two or
more violations of acute or critical regulations exist.  In addition,
each carrier is rated on the number of recordable, preventable
accidents per million miles that its vehicles traveled during the
past year.  (See table V.1 in app.  V.)

Of the motor carriers that received a compliance review in fiscal
year 1996, 35 percent were rated unsatisfactory for the operational
rating factor, which includes hours-of-service regulations, while 13
percent were rated unsatisfactory for the driver rating factor--the
second highest unsatisfactory category.  (See table V.2 in app.  V.)
A substantial number of carriers violated at least one critical
driver's hours-of-service regulation.  (See table V.3 in app.V.) OMC
gives double weight to the violation of these regulations because of
the link between hours-of-service violations and driver fatigue. 

OMC does not track the time that investigators spend evaluating each
rating factor.  Compliance review investigators told us that they
spend between 30 and 40 percent of their time examining the driver's
hours-of-service records during a typical compliance review, but they
added that this percentage could vary, depending on known problems,
available records, and whether it was a first visit or a follow-up. 
We did not identify any studies that specifically analyzed the
relationship between the accuracy of the driver's hours-of-service
logs and accidents; however, we found two studies that generally
examined these issues.  A 1995 study by the National Transportation
Safety Board on single-vehicle heavy truck crashes found that drivers
were more likely to have exceeded OMC's maximum allowable hours of
service in fatigue-related accidents.\16 A 1996 study by the
Northwestern University Traffic Institute examined the relationship
between a carrier's hours-of-service logs and accident rates, but the
study primarily relied on interviews with representatives of 26 motor
carriers that had received a compliance review.\17 The study stated
that the most frequent suggestion for modifying OMC's safety fitness
rating system was to give more weight to performance-based measures,
including accidents and roadside inspection results, and eliminate
the stringent emphasis on record keeping.  In November 1996, OMC
published an advance notice of proposed rule making in the Federal
Register to request comments on its hours-of-service regulation (49
C.F.R.  part 395), as required by the Interstate Commerce Commission
Termination Act of 1995 (P.L.  104-88). 


--------------------
\14 OMC's national training center provides a 6-week training course
for instructing investigators on how to conduct a compliance review,
including interpersonal skills and role playing for interviewing a
motor carrier's personnel and conducting a closeout with the
carrier's management. 

\15 A pattern is defined as at least two violations that also
constitute at least 10 percent of the occasions where like violations
could have occurred. 

\16 Factors That Affect Fatigue in Heavy Truck Accidents, National
Transportation Safety Board, NTSB/SS-95/01 (Jan.  1995). 

\17 "Evaluation of the US DOT Federal Highway Administration Motor
Carrier Safety Rating System," Northwestern University Traffic
Institute (July 1996).  The study was conducted for the American
Trucking Associations. 


      FEW MOTOR CARRIERS APPEALED
      THEIR SAFETY FITNESS RATINGS
      IN FISCAL YEAR 1996
---------------------------------------------------------- Letter :5.2

Of the 8,952 carriers that received a compliance review in fiscal
year 1996, 54 percent were rated satisfactory, 32 percent were rated
conditional, and 12 percent were rated unsatisfactory.  (See table
V.4 in app.  V.) A carrier's overall safety fitness rating is
satisfactory if none of the six rating factors are unsatisfactory and
at most two rating factors are conditional.  A carrier's rating is
conditional if either no rating factor is unsatisfactory and more
than two rating factors are conditional or one rating factor is
unsatisfactory and at most two rating factors are conditional.  A
carrier's rating is unsatisfactory if one rating factor is
unsatisfactory and more than two rating factors are conditional or if
at least two rating factors are unsatisfactory. 

A motor carrier that receives an unsatisfactory or conditional rating
may appeal its rating on either factual or procedural grounds within
90 days after the rating is received.  Of about 3,940 motor carriers
that received either a conditional or unsatisfactory rating in fiscal
year 1996, only 17 appealed their rating within 90 days.  After
reviewing each case, OMC (1) upgraded the ratings of eight carriers,
primarily on the basis of actions taken by the carrier; (2) denied
the appeal of eight carriers; and (3) did not act on one appeal
because a state had conducted the compliance review and had not
entered the results into OMC's Safetynet database. 

Alternatively, a carrier may request a new safety fitness rating on
the basis of operational improvements made.  This request usually
results in a new compliance review.  Officials in two OMC regional
offices told us that a request for a change of a carrier's rating is
relatively rare and that their regional offices typically try to
schedule a follow-up visit within 3 months.  Another OMC official
added that a follow-up compliance review usually results in an
upgraded rating because a carrier would not request one unless
previously cited violations had been addressed. 


      OMC PLANS TO REEXAMINE ITS
      CRITERIA FOR RATING SAFETY
      FITNESS
---------------------------------------------------------- Letter :5.3

In March 1997, the U.S.  Court of Appeals for the District of
Columbia ruled that OMC had failed to carry out its statutory
obligation to promulgate a regulation that establishes criteria for
determining whether a carrier has complied with the safety fitness
requirements of the Motor Carrier Safety Act of 1984.\18 While this
decision applied only to the safety fitness rating of a single
carrier, OMC has temporarily stopped issuing ratings.  To address the
court's concerns, OMC published a notice of proposed rule making in
the May 1997 Federal Register that would establish a safety fitness
rating methodology, including six rating factors, substantially
similar to the methodology that OMC had used to rate motor carriers. 
(OMC also published an interim final rule that applies only to
hazardous materials and passenger carriers.) The notice of proposed
rule making would revise the accident rating factor by (1)
eliminating the determination of whether each recordable accident was
preventable by the motor carrier or the driver, (2) increasing the
threshold for an unsatisfactory rating from 1 accident to 1.6
accidents per million miles driven, and (3) eliminating the
satisfactory and conditional ratings. 

The notice of proposed rule making states that the safety fitness
rating methodology is a short-term approach needed to address the
court of appeals' decision.  The notice further states that, in the
longer term, OMC plans to shift from using compliance reviews to
performance-based criteria for determining whether motor carriers are
fit to conduct commercial vehicle operations safely in interstate
commerce.  OMC believes that SafeStat can be successfully employed to
identify the worst performing carriers within the next 2 years.  As a
first step in this transition, OMC plans to publish an advance notice
of proposed rule making later this year to solicit public comments on
alternative approaches for rating the safety fitness of commercial
motor carriers. 


--------------------
\18 MST Express v.  Department of Transportation, 108 F.3d 401 (D.C. 
Cir.  1997). 


   CONCLUSIONS
------------------------------------------------------------ Letter :6

OMC's SCE list and other criteria for selecting motor carriers for
compliance reviews did not effectively target commercial motor
carriers with poor safety performance.  While OMC's new SafeStat
system is designed to better identify problem carriers by using
on-the-road performance data, it depends upon the states to submit
complete, accurate, and timely data on recordable accidents and the
results of roadside inspections and compliance reviews.  However,
some states currently lack adequate data, particularly for accidents. 
Substantial gaps in the reported data can change a carrier's score,
thus affecting SafeStat's reliability.  In addition, 14 states do not
use the Inspection Selection System for selecting vehicles for
roadside inspections, and small motor carriers may get no ranking or
a biased ranking by SafeStat if few roadside inspections are
performed on their vehicles and drivers. 

We agree in concept with OMC's announced plan to use
performance-based data for rating the safety fitness of commercial
motor carriers.  However, for this approach to succeed, the states
must provide substantially complete, accurate, and timely data to
Safetynet.  While OMC has taken steps to improve states' data
reporting by, for example, introducing the Inspection Selection
System and providing funding for the states to purchase laptop
computers to directly upload roadside inspection results, many states
have not provided complete and timely data that meet OMC's reporting
requirements. 


   RECOMMENDATIONS
------------------------------------------------------------ Letter :7

To better ensure that the safety fitness ratings of commercial motor
carriers accurately reflect their on-the-road performance, we
recommend that the Secretary of Transportation (1) identify the
barriers that prevent the states from providing complete and timely
data and work with the states to develop a strategy for addressing
each barrier and (2) develop alternative approaches to SafeStat, such
as consulting with state and local law enforcement officials to
identify problem motor carriers, in the states that have inadequate
data. 


   AGENCY COMMENTS AND OUR
   EVALUATION
------------------------------------------------------------ Letter :8

We provided the Department of Transportation with a draft of this
report for review and comment.  We met with officials in the Office
of Motor Carriers, including the Chief, Safety and Hazardous
Materials Division; the Chief, Information Division; and OMC's
National Field Coordinator, as well as with a senior analyst in the
Office of the Secretary.  DOT agreed with the overall message of the
report, stating that it was fair and accurate, and agreed with our
recommendation that it work with the states to develop a strategy for
addressing barriers that prevent the states from providing complete
and timely data.  However, DOT disagreed with our recommendation that
it develop alternative approaches to SafeStat in the states that have
inadequate data, stating that (1) its resources would be better spent
by working with the states to improve their data and (2) developing
separate processes for different states or individual populations of
carriers would not be practical or an effective use of resources
because an interstate carrier's performance is influenced by multiple
states. 

We continue to believe that DOT needs to develop alternative
approaches for the states that have inadequate data, especially on
recordable accidents, because of the importance of improving the
safety fitness of motor carriers with poor safety records.  An
alternative approach need not be labor intensive; for example, it
could involve asking a state to identify for compliance reviews any
motor carrier whose drivers or vehicles have multiple out-of-service
violations.  Alternatively, OMC could modify SafeStat for the states
that have inadequate accident data to rank carriers only on the basis
of the other three SEAs that use roadside inspection, compliance
review, and enforcement case results.  DOT also provided clarifying
information to improve the report's technical accuracy, which we
incorporated as appropriate. 


   SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :9

To obtain the information in this report, we interviewed officials
from OMC, the Volpe National Transportation Systems Center, the
Commercial Vehicle Safety Alliance, and the American Trucking
Associations and the MCSAP coordinators for Arizona, California,
Connecticut, Georgia, Illinois, Iowa, Maryland, Massachusetts,
Mississippi, Missouri, Ohio, Oregon, Pennsylvania, Texas, Utah, and
Wisconsin.  We selected these 16 states to provide geographical
diversity, a mix of large and small states, and a mix in the number
of compliance reviews that each state performed in fiscal year 1996. 
We also (1) made site visits to three of these states that have
strong programs for collecting and using commercial vehicle accident,
inspection, and enforcement data; (2) interviewed officials in each
of the five states that participated in the SafeStat pilot program;
and (3) accompanied OMC investigators as they performed a compliance
review. 

While we did not verify the accuracy of the data that the states
submitted to OMC's Safetynet database, OMC reviews these data for
accuracy and completeness before they are entered into its motor
carrier management information system, which OMC has used to generate
its SCE and SafeStat rankings.  We also did not examine the safety
performance of longer-combination vehicles, which are limited by
federal law to designated highways in 20 states.  DOT does not plan
to propose any revisions to the current federal restrictions until it
completes an ongoing major study on these trucks.  We conducted our
review from April through September 1997 in accordance with generally
accepted government auditing standards. 


---------------------------------------------------------- Letter :9.1

As arranged with your office, unless you publicly announce its
contents earlier, we plan no further distribution of this report
until 30 days after the date of this letter.  At that time, we will
send copies of the report to congressional committees and
subcommittees responsible for commercial motor vehicle safety issues;
the Secretary of Transportation; the Director, Office of Management
and Budget; and other interested parties.  We will make copies
available to others upon request. 

If you or your staff have any questions about this report, please
contact me at (202) 512-3650.  Major contributors to this report are
Jason Bromberg, Richard Cheston, and James Ratzenberger. 

Sincerely yours,

Phyllis F.  Scheinberg
Associate Director,
 Transportation Issues


COMMERCIAL VEHICLE SAFETY DATA
=========================================================== Appendix I



                               Table I.1
                
                Fatal Accidents Involving Large Trucks,
                           1983 Through 1996

                (Vehicle miles traveled per 100 million
                                 miles)

                                         Large
                                        trucks
                                      involved     Vehicle       Fatal
                                      in fatal       miles    accident
Year                    Fatalities   accidents    traveled      rate\a
----------------------  ----------  ----------  ----------  ----------
1983                         5,491       4,877     1,131.6         4.3
1984                         5,640       5,124     1,239.3         4.1
1985                         5,734       5,153     1,265.8         4.1
1986                         5,579       5,097     1,301.4         3.9
1987                         5,598       5,108     1,356.0         3.8
1988                         5,679       5,241     1,414.0         3.7
1989                         5,490       4,984     1,483.2         3.4
1990                         5,272       4,776     1,498.1         3.2
1991                         4,821       4,347     1,507.3         2.9
1992                         4,462       4,035     1,528.0         2.6
1993                         4,856       4,328     1,599.0         2.7
1994                         5,144       4,644     1,704.2         2.7
1995                         4,918       4,472     1,781.6         2.5
1996                         5,126       4,740          \b          \b
----------------------------------------------------------------------
Note:  Large trucks accounted for 99 percent of the fatal accidents
involving commercial motor vehicles in 1995. 

\a Fatal accidents per 100 million vehicle miles traveled. 

\b Data are not available. 

Source:  National Highway Traffic Safety Administration. 



                               Table I.2
                
                Roadside Inspections of Commercial Motor
                Vehicles Performed by Federal and State
                 Inspectors, Fiscal Years 1983 Through
                                  1996

                               Federal           State           Total
Fiscal year                inspections   inspections\a     inspections
----------------------  --------------  --------------  --------------
1983                            24,721               0          24,721
1984                            18,966         159,294         178,260
1985                            16,046         374,885         390,931
1986                            10,027         559,300         569,327
1987                               910       1,003,794       1,004,704
1988                               238       1,254,076       1,254,314
1989                             2,357       1,302,453       1,304,810
1990                             4,376       1,601,230       1,605,606
1991                             2,321       1,574,188       1,576,509
1992                             1,066       1,615,668       1,616,734
1993                             2,864       1,946,833       1,949,697
1994                             2,965       1,974,232       1,977,197
1995                               726       1,840,266       1,840,992
1996                          10,987\b       2,073,666       2,084,653
----------------------------------------------------------------------
\a State totals may exclude inspections of intrastate carriers or
inspections not funded by the Motor Carrier Safety Assistance Program
(MCSAP) and not centrally reported.  For example, Missouri did not
report inspections of intrastate carriers to Safetynet before March
1997.  Similarly, California reported only 32,000 of 400,000 roadside
inspections in fiscal year 1989. 

\b Federal inspections increased in fiscal year 1996 because the
Office of Motor Carriers (OMC) temporarily assigned personnel to help
states inspect commercial vehicles entering the United States from
Mexico as a result of the North American Free Trade Agreement. 

Source:  OMC. 



                               Table I.3
                
                Roadside Inspections of Commercial Motor
                Vehicles Performed by Each State, Fiscal
                               Year 1996

                                                   Out-of-     Out-of-
                           Level 1       Total     service     service
                        inspection  inspection    rate for    rate for
State                            s           s    vehicles     drivers
----------------------  ----------  ----------  ----------  ----------
Alabama                      2,359      19,713        17.0         6.4
Alaska                         640       1,636        30.1         4.5
Arizona                      6,623      34,365        19.8         9.2
Arkansas                    12,306      38,037        14.5        16.3
California                 325,345     356,423        25.0         3.6
Colorado                    23,065      46,616        18.5         6.4
Connecticut                  5,407      15,546        27.8        13.1
Delaware                     1,435       3,109        26.1        11.4
Florida                     27,618      67,602        25.8         8.8
Georgia                     10,174      32,870        23.0         8.0
Hawaii                       6,404       7,815        16.1         1.8
Idaho                        3,089       6,449        23.3        13.5
Illinois                    13,878      97,791        11.9         4.6
Indiana                     25,559      80,410        16.5         6.8
Iowa                        15,656      51,071        17.7        11.1
Kansas                       3,634      23,338        18.7        12.7
Kentucky                    62,985      77,159        20.5         8.6
Louisiana                   16,595      39,413        20.3        11.9
Maine                        4,245       5,043        31.3        13.9
Maryland                    25,496      91,760        14.4         6.2
Massachusetts               13,923      25,562        25.4         5.0
Michigan                    10,001      49,486        11.9         3.3
Minnesota                   13,268      27,250        23.1         9.8
Mississippi                 14,449      19,747        24.9         8.9
Missouri                    26,885      63,504        27.9        10.0
Montana                      7,470      26,916         8.6         8.3
Nebraska                     5,942      22,454        11.3        13.4
Nevada                       3,184      15,249        20.3         7.1
New Hampshire                1,475      11,065        12.4         6.4
New Jersey                  20,098      55,536        21.6         2.7
New Mexico                   7,610      24,685        21.0        15.5
New York                    30,823      37,839        32.2        11.4
North Carolina              16,831      39,527        19.8         6.0
North Dakota                 2,721      15,231         7.3         9.0
Ohio                        21,721      59,981        29.1        11.0
Oklahoma                     3,165      10,461        25.1         5.7
Oregon                      15,167      26,170        34.9        10.7
Pennsylvania                15,807      39,718        25.8         7.7
Rhode Island                 2,274       5,443        14.7         7.5
South Carolina               8,192      32,697        20.9         6.8
South Dakota                   633      14,373         3.3        11.2
Tennessee                   17,676      63,402        17.8         9.2
Texas                       19,872      82,056        29.4        13.7
Utah                         8,251      15,065        24.7         8.5
Vermont                      1,737       4,367        19.0        12.4
Virginia                    15,438      30,717        22.7         7.3
Washington                  27,963      81,250        17.5         8.8
West Virginia                8,227      14,511        23.1         8.5
Wisconsin                   10,791      29,806        23.0        10.4
Wyoming                      2,542      13,650         9.5        18.1
American Samoa               2,396       2,899        26.5         2.7
District of Columbia           964       3,505        11.7         0.9
Guam                         7,258       9,908        24.1           0
Northern Mariana
 Islands                       372         457           0           0
Puerto Rico                    535       3,013        29.0         3.4
======================================================================
Total                      958,174   2,073,666        21.0         7.8
----------------------------------------------------------------------
Source:  OMC's MCSAP Quarterly Report. 



                               Table I.4
                
                 Compliance Reviews of Commercial Motor
                Carriers Performed by Federal and State
                Investigators, Fiscal Years 1989 Through
                                  1996

                                   Federal         State         Total
                                compliance    compliance    compliance
Fiscal year                        reviews       reviews       reviews
----------------------------  ------------  ------------  ------------
1989                                 6,211             5         6,216
1990                                 6,764            87         6,851
1991                                 8,958           142         9,100
1992                                 7,733           225         7,958
1993                                 7,342           431         7,733
1994                                 6,924         1,258         8,182
1995                                 5,396         3,857         9,253
1996                                 5,241         3,711         8,952
----------------------------------------------------------------------
Note:  Excludes safety reviews, which OMC eliminated at the end of
fiscal year 1994. 

Source:  OMC. 



                               Table I.5
                
                 Federal MCSAP Grants to the States by
                       Category, Fiscal Year 1996

                         (Dollars in thousands)

Activity                                                       Funding
--------------------------------------------------  ------------------
Basic MCSAP grant                                              $53,968
Traffic enforcement                                              6,900
Hazardous materials training                                     1,500
Secondary grants\a                                               1,701
50 percent holding\b                                           (1,499)
National Governors' Association data elements for                1,403
 accident reporting
Drug interdiction assistance program                               464
Research and development                                         1,042
Covert activities                                                1,062
Public education                                                   850
Uniformity grants\c                                              3,097
North American Free Trade Agreement implementation               1,067
 assistance
Incentive grants\d                                               1,036
Reallocation                                                     1,517
Special grants                                                   2,483
======================================================================
Total                                                          $76,592
----------------------------------------------------------------------
\a Supplementary funding designed to encourage states with mature
safety programs to further enlarge their programs.  Funding was
phased out in fiscal year 1997. 

\b States whose intrastate regulations are incompatible with federal
regulations are eligible to receive only 50 percent of their basic
formula allocation. 

\c Funding for participation in the international registration plan
and the international fuel tax agreement. 

\d Supplemental funding derived from the 50-percent holding account
for states with comprehensive motor carrier safety programs. 

Source:  OMC. 


SELECTIVE COMPLIANCE AND
ENFORCEMENT CRITERIA FOR SELECTING
MOTOR CARRIERS FOR A COMPLIANCE
REVIEW
========================================================== Appendix II

Commodity transported (1 to 8 points): 

  -- 8 points for a passenger carrier

  -- 5 points for hazardous materials in a tank

  -- 2 points for hazardous materials in a package

  -- 1 point for everything else

Annual carrier mileage (1 to 4 points): 

  -- 4 points for at least 5 million miles

  -- 3 points for from 1 million to 4,999,999 miles

  -- 2 points for from 150,000 to 999,999 miles

  -- 1 point for less than 150,000 miles

If mileage is unavailable, then a driver census would be used

  -- 4 points for at least 72 drivers

  -- 3 points for from 16 to 71 drivers

  -- 2 points for from 6 to 15 drivers

  -- 1 point for from 1 to 5 drivers

If mileage and a driver census are unavailable, then the number of
power units (for semi-trailer trucks, the tractor unit that includes
the engine) would be used

  -- 4 points for at least 72 power units

  -- 3 points for from 16 to 71 power units

  -- 2 points for from 6 to 15 power units

  -- 1 point for from 1 to 5 power units

  -- Neutral value if 0, blank, or unknown

Months since last safety fitness rating (0 to 4 points): 

  -- 4 points for more than 36 months

  -- 3 points for from 25 to 36 months

  -- 2 points for from 13 to 24 months

  -- 1 point for from 7 to 12 months

  -- 0 points for from 0 to 6 months

  -- 2 points for an unrated carrier

Vehicle out-of-service rate (1 to 5 points): 

  -- 5 points for an out-of-service rate of at least 40 percent

  -- 4 points for an out-of-service rate from 33.34 to 39.99 percent

  -- 3 points for an out-of-service rate from 25 to 33.33 percent

  -- 2 points for an out-of-service rate from 16.67 to 24.99 percent

  -- 1 point for an out-of-service rate of from 0 to 16.66 percent

Driver out-of-service rate (2 to 10 points): 

  -- 10 points for an out-of-service rate of at least 15 percent

  -- 8 points for an out-of-service rate from 10 to 14.99 percent

  -- 6 points for an out-of-service rate from 7 to 9.99 percent

  -- 4 points for an out-of-service rate from 3.25 to 6.99 percent

  -- 2 points for an out-of-service rate of from 0 to 3.24 percent

Preventable, recordable accident rate (1 to 5 points): 

  -- 5 points for an accident rate of at least 1.0

  -- 4 points for an accident rate from 0.67 to 0.99

  -- 3 points for an accident rate from 0.34 to 0.66

  -- 2 points for an accident rate from 0.01 to 0.33

  -- 1 point for an accident rate of 0

  -- Neutral value for a blank or missing accident rate

Overall safety fitness rating (1 to 5 points): 

  -- 5 points for an unsatisfactory rating

  -- 3 points for a conditional rating

  -- 1 point for a satisfactory rating

  -- Neutral value for an unrated carrier

The Selective Compliance and Enforcement (SCE) selection formula
removes a neutral value for a factor from consideration because of a
lack of data.  To adjust for neutral values, the selection formula
multiplies the carrier's SCE score by seven (the total number of
factors) and divides by the number of factors for which data are
available.  A carrier's final SCE score is the total of its scores
for the seven factors. 

The SCE list used (1) inspections conducted within the previous 18
months and (2) accident rates calculated during a compliance review
within the previous 2 years.  OMC required that the out-of-service
rates for the vehicle and driver be calculated on the basis of at
least 10 valid inspections for trucks and 5 valid inspections for
passenger vehicles. 


SAFESTAT CRITERIA FOR SELECTING
MOTOR CARRIERS FOR A COMPLIANCE
REVIEW
========================================================= Appendix III

Accident Safety Evaluation Area (SEA)

1.  Motor carriers' accidents that states report to OMC's Safetynet
database.  (The accident must involve a fatality, an injury, or a
vehicle that was towed away from the scene.)

2.  Recordable, preventable accident rate from compliance reviews. 

Driver SEA

1.  Out-of-service violations for drivers from roadside inspections. 

2.  Violations of driver-related critical and acute regulations from
compliance reviews. 

Vehicle SEA

1.  Out-of-service violations for vehicles from roadside inspections. 

2.  Violations of vehicle-related critical and acute regulations from
compliance reviews. 

Safety management SEA

1.  Closed enforcement cases.  (An enforcement case is the result of
one or more major violations discovered by a safety investigator
during a compliance review.)

2.  Out-of-service violations for hazardous materials from roadside
inspections. 

3.  Violations of safety management-related critical and acute
regulations from compliance reviews. 

SafeStat time weights data by (1) giving more weight to events that
occurred during the past year than to events that are older and (2)
using only data that are less than 30 months old.  SafeStat also
weights accident data and compliance review violations by the
severity of the event.  For example, a fatal accident is given more
weight than an accident involving a vehicle that was towed from the
scene. 


SELECTED STATE INITIATIVES TO
IMPROVE THE COLLECTION AND USE OF
SAFETY DATA
========================================================== Appendix IV

States vary widely in the quality and completeness of their
commercial vehicle safety data and in the ways they make use of these
data in their commercial vehicle safety programs.  Several states
have initiated programs to improve their collection and use of safety
data for commercial vehicles.  Below are three state initiatives to
develop comprehensive data on accidents involving commercial motor
vehicles, targeting high-accident corridors for increased
enforcement, and using real-time wireless communications to provide
state police with electronic access to Safetynet data. 


   OREGON:  ACCIDENT REPORTING
-------------------------------------------------------- Appendix IV:1

The Motor Carrier Transportation Branch, within Oregon's Department
of Transportation (DOT) has a system for gathering data on commercial
vehicle accidents that differs from that of many other states.  In
particular, the branch employs an experienced accident analyst whose
sole job is to collect and check accident information, look for
inconsistencies in the data, and follow up with the police or the
carrier to make the accident report as accurate and complete as
possible.  The accident analyst also provides information that helps
decide whether the branch should get involved in the investigation of
a particular accident. 

Oregon uses several sources to acquire information on accidents
involving commercial vehicles, the most important of which is the
police accident report.  But unlike many states, Oregon also requires
motor carriers to file a report within 30 days if one of their
vehicles is involved in a serious accident.  The carrier's report
provides more information than the police report about the driver and
such things as the configuration of the vehicle and its load.  In
about one in six cases, the carrier's report is the only source of
information about an accident because local police departments do not
always file an accident report. 

Unlike many states, Oregon makes an effort to determine the cause of
a commercial vehicle accident and who was at fault.  Oregon's DOT
uses a list of about 50 different reasons (lane change, brake
failure, etc.) that can be identified as the primary or secondary
cause of an accident.  While Safetynet does not include data on cause
and fault, Oregon uses this information to develop its
performance-based standards and strategies.  For example, the
information allows Oregon's DOT to map out the location of accidents,
on the basis of their cause, showing problem spots for accidents
believed to be caused by such things as excessive speed or fatigue. 
Oregon's DOT can then respond to patterns by, for example, focusing
its resources on traffic enforcement efforts on speed-problem
corridors or targeting hours-of-service violations where fatigue is a
problem. 


   UTAH:  REDUCING FATIGUE-RELATED
   ACCIDENTS
-------------------------------------------------------- Appendix IV:2

Utah, like other states, is adopting performance-based standards to
implement its truck safety programs.  In 1996, Utah's DOT used its
basic MCSAP grant to participate in a pilot project to address a
78-percent increase in truck accidents on a stretch of Interstate
Route 80 west of Salt Lake City that is very straight, flat, and
monotonous.  Utah's DOT conducted an analysis of these accidents in
relation to the time of day, location, number of vehicles involved,
and other elements that found that a disproportionate number of the
accidents were single-vehicle events, such as a truck's running off
the road, suggesting that the accidents were related to driver
fatigue. 

Through the pilot, Utah has targeted resources on the driver-fatigue
problem on this corridor.  The truck unit of the state police has
increased level 3 (driver) inspections at targeted locations,
focusing on hours-of-service violations.  Where problems were found,
Utah's DOT focused on the carrier's operations by looking at the
carrier's collective driver records and conducting a full compliance
review, if warranted.  In addition, Utah's DOT initiated educational
activities to reduce the number of sleep-related crashes, such as
disseminating brochures outlining the warning signs of fatigue and
informational packets for drivers and carriers at ports of entry,
during compliance reviews, and at various driver-related events. 


   CONNECTICUT:  REAL-TIME
   WIRELESS COMMUNICATION
-------------------------------------------------------- Appendix IV:3

The Commercial Vehicle Safety Division, within the Connecticut
Department of Motor Vehicles, has begun to implement a real-time
wireless communication system that links an inspector performing a
truck inspection at a roadside stop with state and national motor
carrier information systems.  The system, known as the cellular
digital package data system, provides inspectors with the ability to
send and receive real-time data from the ASPEN vehicle inspection
system, OMC's commercial driver license information system, and other
related commercial vehicle and enforcement databases.  The system
substantially increases both the quantity and currency of the data
available to an inspector at a roadside stop about a vehicle, its
driver, and the motor carrier. 

Several police departments in Connecticut and nationwide already use
this basic technology, but Connecticut is using a special MCSAP
research and development grant to piggyback onto this existing
technology to incorporate ASPEN.  The communications are
double-encrypted before going over the airwaves, since they contain
sensitive information.  The operating costs are much less than those
for a cellular telephone, since the system sends out its data in
short bursts, rather than through a continuously open telephone line. 

By entering a truck's U.S.  DOT number at a roadside stop, an
inspector will be able to obtain a motor carrier's complete
inspection history and the results of compliance reviews.  Having
more up-to-date information will allow the inspector to make a better
determination about whether to inspect the truck.  In addition,
having more complete information allows the inspector to focus the
inspection more effectively; if the database shows a history of brake
violations, for example, the inspection may focus more on the
vehicle's brakes.  The inspector also can use the cellular system to
input the data collected during an inspection into the system
immediately, rather than have it entered at some future date, which
facilitates data processing and makes the databases more current. 


COMPLIANCE REVIEW RATING FACTORS
=========================================================== Appendix V



                               Table V.1
                
                Recordable, Preventable Accident-Rating
                                 Scale

                                                         Accidents per
                                     Accidents per       million miles
                                     million miles  traveled for urban
Rating                                    traveled          carriers\a
------------------------------  ------------------  ------------------
Satisfactory                         Less than 0.3       Less than 0.3
Conditional                        Between 0.3 and     Between 0.3 and
                                               1.0                 2.0
Unsatisfactory                    Greater than 1.0    Greater than 2.0
----------------------------------------------------------------------
Note:  A recordable accident is one involving a commercial vehicle
operating on a public road that results in a fatality, bodily injury
that requires medical treatment, or a vehicle being towed from the
accident scene.  A preventable accident is one that could have been
averted but for an act, or failure to act, by the motor carrier or
driver. 

\a An urban carrier is defined as one operating entirely within a
radius of less than 100 air miles (normally in urban areas). 



                               Table V.2
                
                  Compliance Review Ratings by Factor,
                            Fiscal Year 1996

                                                            Percentage
                        Satisfacto  Conditiona  Unsatisfac  unsatisfac
Rating factor                   ry           l        tory        tory
----------------------  ----------  ----------  ----------  ----------
General\a                    8,569         272          13         0.1
Driver\b                     5,522       2,154       1,178        13.3
Operational\c                5,731          45       3,078        34.8
Vehicle\d                    5,879       2,390         584         6.6
Hazardous materials\e        2,518         245          33         1.2
Accident\f                   7,578       1,041         234         2.6
----------------------------------------------------------------------
\a Assesses compliance with regulations for financial responsibility
and general safety (49 C.F.R.  parts 387 and 390). 

\b Assesses compliance with regulations for the use and testing of
controlled substances and alcohol, the commercial driver's license,
and drivers' qualifications (49 C.F.R.  parts 382, 383, and 391). 

\c Assesses compliance with regulations for motor vehicle driving and
hours of service (49 C.F.R.  parts 392 and 395). 

\d Assesses compliance with regulations for vehicle parts and
accessories and vehicles' inspection, repair, and maintenance (49
C.F.R.  parts 393 and 396). 

\e Assesses compliance with regulations for transporting hazardous
materials (49 C.F.R.  parts 397, 171, 177, and 180). 

\f Assesses a motor carrier's recordable, preventable accident rate. 

Source:  OMC. 



                               Table V.3
                
                Violations of Critical Hours-of-Service
                Regulations Cited in Compliance Reviews,
                            Fiscal Year 1996

Critical regulation                                   Total violations
--------------------------------------------------  ------------------
Requiring or permitting driver to drive more than                3,322
 10 hours.
Requiring or permitting driver to drive after                    1,955
 having been on duty 15 hours.
Requiring or permitting driver to drive after                    3,311
 having been on duty more than (1) 60 hours in 7
 consecutive days or (2) 70 hours in 8 consecutive
 days.
Failing to require driver to make a record of duty               3,042
 status.
False reports of records of duty status.                         4,332
Failing to require driver to forward, within 13
 days of completion, the original of the record of                 501
 duty status.
Failing to preserve driver's records of duty
 status and supporting documents for 6 months.                     984
----------------------------------------------------------------------
Note:  Excludes four critical hours-of-service regulations that apply
only to Alaska. 

Source:  OMC. 



                               Table V.4
                
                  Federal and State Compliance Review
                 Ratings of Commercial Motor Carriers'
                 Operations by State, Fiscal Year 1996

                              Percenta  Percenta  Percentage  Percenta
                              ge rated  ge rated       rated        ge
                              satisfac  conditio  unsatisfac       not
State                  Total      tory       nal        tory    rated\
------------------  --------  --------  --------  ----------  --------
Alabama                  133        46        37          17         1
Alaska                    11        36        55           0         9
Arizona                   88        57        33          10         0
Arkansas                 124        48        40          10         2
California\a             185        48        29          15         8
Colorado                 193        49        38          11         3
Connecticut              111        38        26          21        15
Delaware                  43        44        44          12         0
Florida                   73        40        40          19         1
Georgia                  246        36        36          28         0
Hawaii                     1       100         0           0         0
Idaho                     72        63        18          19         0
Illinois                 414        55        38           7         0
Indiana                  291        58        35           7         0
Iowa                      58        22        41          36         0
Kansas                    40        40        28          33         0
Kentucky                 408        39        36          22         4
Louisiana                126        51        46           3         0
Maine                     24        29        42          29         0
Maryland                 161        49        30          20         0
Massachusetts            197        59        31           8         2
Michigan                 426        62        27           7         4
Minnesota                658        65        27           6         3
Mississippi              107        23        51          25         0
Missouri                 416        49        36          14         0
Montana                   43        44        44          12         0
Nebraska                  68        41        43          16         0
Nevada                    78        54        32           6         8
New Hampshire              3         0        33          67         0
New Jersey               256        56        33          10         1
New Mexico               112        64        22          11         3
New York                 230        50        33          16         1
North Carolina           139        40        45          14         1
North Dakota              49        18        57          24         0
Ohio                     979        71        22           4         3
Oklahoma                  92        39        50          11         0
Oregon                   206        46        31          20         3
Pennsylvania             294        70        21          10         0
Rhode Island              50        62        22          14         2
South Carolina            60        52        33          15         0
South Dakota              14        43        29          29         0
Tennessee                171        77        22           1         0
Texas                    307        50        36          10         4
Utah                      74        62        27           8         3
Vermont                   12        58        25          17         0
Virginia                 120        41        41          18         0
Washington               276        34        42          20         4
West Virginia             84        65        25          10         0
Wisconsin                464        67        24           5         5
Wyoming                   60        45        48           7         0
District of                9        56        33          11         0
 Columbia
Puerto Rico                3         0         0           0       100
======================================================================
Total                  8,952        54        32          12         2
----------------------------------------------------------------------
Note:  Totals exclude any compliance reviews of shippers, shippers'
terminals, and intrastate carriers, as well as 16-passenger vans and
school buses. 

\a California performed 14,785 terminal inspections during 1996. 

Source:  OMC. 


*** End of document. ***