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High-Risk Carriers but Does Not Assess Maximum Fines as Often as 
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Report to the Chairman, Committee on Transportation and Infrastructure, 
House of Representatives: 

United States Government Accountability Office: 

GAO: 

August 2007: 

Motor Carrier Safety: 

Federal Safety Agency Identifies Many High-Risk Carriers but Does Not 
Assess Maximum Fines as Often as Required by Law: 

Motor Carrier Safety Oversight: 

GAO-07-584: 

GAO Highlights: 

Highlights of GAO-07-584, a report to the Chairman, Committee on 
Transportation and Infrastructure, House of Representatives. 

Why GAO Did This Study: 

The Federal Motor Carrier Safety Administration (FMCSA) has the primary 
federal responsibility for reducing crashes involving large trucks and 
buses. FMCSA uses its “SafeStat” tool to target carriers for reviews of 
their compliance with the agency’s safety regulations based on their 
crash rates and safety violations. 

As requested, this study reports on (1) the extent to which FMCSA’s 
policy for prioritizing compliance reviews targets carriers with a high 
risk of crashes, (2) how FMCSA ensures compliance reviews are thorough 
and consistent, and (3) the extent to which FMCSA follows up with 
carriers with serious safety violations. To complete this work, GAO 
reviewed FMCSA’s regulations, policies, and safety data and contacted 
FMCSA officials in headquarters and nine field offices. 

What GAO Found: 

By and large, FMCSA does a good job of identifying carriers that pose 
high crash risks for subsequent compliance reviews, ensuring the 
thoroughness and consistency of those reviews, and following up with 
high-risk carriers. FMCSA’s policy for prioritizing compliance reviews 
targets many high-risk carriers but not other higher risk ones. 
Carriers must score among the worst 25 percent of carriers in at least 
two of SafeStat’s four evaluation areas (accident, driver, vehicle, and 
safety management) to receive high priority for a compliance review. 
Using data from 2004, GAO found that 492 carriers that performed very 
poorly in only the accident evaluation area (i.e., those carriers that 
scored among the worst 5 percent of carriers in this area) subsequently 
had an aggregate crash rate that was more than twice as high as that of 
the 4,989 carriers to which FMCSA gave high priority. FMCSA told GAO 
that the agency plans to assess whether giving high priority to 
carriers that perform very poorly in only the accident evaluation area 
would be an effective use of its resources. 

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

FMCSA follows up with many carriers with serious safety violations, but 
it does not assess maximum fines against all of the serious violators 
that GAO believes the law requires. FMCSA followed up with more than 99 
percent of the 1,196 carriers that received proposed unsatisfactory 
safety ratings from compliance reviews completed in fiscal year 2005, 
finding that 881 of these carriers made safety improvements and placing 
309 others out of service. However, GAO found that FMCSA (1) does not 
assess maximum fines against carriers with a pattern of varied serious 
violations as GAO believes the law requires and (2) assesses maximum 
fines against carriers for the third instance of a violation, whereas 
GAO reads the statute as requiring FMCSA to assess the maximum fine for 
the second. 

What GAO Recommends: 

GAO is making several recommendations, including that FMCSA (1) select 
certain high-risk carriers in the accident safety evaluation area for 
compliance reviews and (2) revise its policy for assessing maximum 
fines. The Department of Transportation said that it would assess the 
efficacy of the first recommendation, but it did not comment on the 
other recommendations. 

[hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-07-584]. 

To view the full product, including the scope and methodology, click on 
the link above. For more information, contact Susan A. Fleming at (202) 
512-2834. 

[End of section] 

Contents: 

Letter: 

Results in Brief: 

Background: 

FMCSA's Policy for Prioritizing Compliance Reviews Targets Many High- 
Risk Carriers, but Changes to the Policy Could Target Carriers with 
Even Higher Risk: 

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

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

Conclusions: 

Recommendations for Executive Action: 

Agency Comments: 

Appendix I: Other Assessments of SafeStat's Ability to Identify High-
Risk Motor Carriers: 

Appendix II: FMCSA's Crash Data Used to Compare Methods for Identifying 
High-Risk Carriers: 

Appendix III: Review of Studies on Predictors of Motor Carrier and 
Driver Crash Risk: 

Appendix IV: Scope and Methodology: 

Appendix V: GAO Contact and Staff Acknowledgments: 

Tables: 

Table 1: SafeStat Categories: 

Table 2: How FMCSA Determines Carrier Safety Ratings Based on Ratings 
in Six Safety Areas: 

Table 3: Crash Rates of Motor Carriers in Various SafeStat Categories 
in the 18 Months following the June 2004 SafeStat Categorization: 

Table 4: Regression Model Approach Compared with Refined Prioritization 
Approach and with Current SafeStat Approach: 

Table 5: Percentages of Compliance Reviews for Fiscal Years 2001 
through 2006 That Covered Each of the Major Applicable Areas of the 
Safety Regulations: 

Table 6: Time Elapsed before Carriers Rated Conditional Received Follow-
up Compliance Reviews, Fiscal Years 2002 through 2004, as of September 
2006: 

Table 7: Number of Motor Carriers That Would Have Been Subject to 
Maximum Fines under Various Definitions of a Pattern of Serious 
Violations, Fiscal Years 2004 through 2006: 

Table 8: Number of Motor Carriers That Would Have Been Subject to 
Maximum Fines under Two Strikes and Three Strikes Repeat Violator 
Policies, Fiscal Years 2004 through 2006: 

Figures: 

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

Figure 2: FMCSA's Safety Oversight Approach: 

Figure 3: Percentage of Crashes Submitted to MCMIS within 90 Days of 
Occurrence, Fiscal Years 2000 through 2006: 

Abbreviations: 

FMCSA: Federal Motor Carrier Safety Administration: 
MCMIS: Motor Carrier Management Information System: 
PRISM: Performance Registration and Information System Management: 
SafeStat: Motor Carrier Safety Status Measurement System: 

United States Government Accountability Office: 

Washington, DC 20548: 

August 28, 2007: 

The Honorable James L. Oberstar: 
Chairman: 
Committee on Transportation and Infrastructure: 
House of Representatives: 

Dear Mr. Chairman: 

About 5,500 people die each year as a result of crashes involving large 
commercial trucks or buses,[Footnote 1] and about 160,000 more people 
are injured. These crashes may result from errors by truck, bus, or 
passenger vehicle drivers, vehicle condition, and other factors. The 
Federal Motor Carrier Safety Administration (FMCSA) within the U.S. 
Department of Transportation shoulders the primary federal 
responsibility for reducing crashes, injuries, and fatalities involving 
large trucks and buses. FMCSA's primary means of preventing these 
crashes is to develop and enforce regulations to help ensure that 
drivers and motor carriers are operating safely. FMCSA uses several 
enforcement activities to ensure compliance with its safety 
regulations, including detailed inspections of motor carriers' 
operations at their places of business, called compliance reviews. 
FMCSA also funds and oversees similar enforcement activities at the 
state level. 

Because of resource constraints, each year FMCSA and its state partners 
are able to conduct compliance reviews of only about 2 percent of the 
nation's estimated 711,000 motor carriers that are subject to the 
federal safety and hazardous materials regulations.[Footnote 2] FMCSA 
targets these reviews toward those carriers that its Motor Carrier 
Safety Status Measurement System (SafeStat) identifies as having the 
greatest potential for being involved in crashes and assigns these 
carriers to its two highest priority categories--SafeStat categories A 
and B. SafeStat's assessments are based on indicators such as crash 
rates and safety violations identified during roadside inspections of 
vehicles and drivers and during prior compliance reviews. To be given 
high priority for a compliance review, a carrier must score among the 
worst 25 percent of carriers[Footnote 3] in at least two of SafeStat's 
four evaluation areas (the four areas are accident, driver, vehicle, 
and safety management; the scores for the last three of these are based 
on a carrier's violations). As a result, carriers that score poorly in 
a single area often do not necessarily receive a compliance review. 

Federal law requires FMCSA to determine whether carriers are fit to 
operate safely and to place those carriers that it finds unfit out of 
service. Out-of-service carriers cannot come back into service until 
FMCSA determines that they have corrected the conditions that rendered 
them unfit. FMCSA determines safety fitness by conducting compliance 
reviews, and it assigns unfit carriers a rating of "unsatisfactory." It 
also requires follow-up compliance reviews on carriers that it rates 
"conditional."[Footnote 4] FMCSA can assess fines against carriers for 
violations of the safety regulations, and federal law requires FMCSA to 
assess the maximum allowable fine[Footnote 5] for each serious 
violation[Footnote 6] for those carriers whose performance demonstrates 
a pattern of serious violations or violations that are the same as or 
related to a previous serious violation (we call these "repeat" 
violations). 

You asked us to examine how FMCSA identifies and takes action against 
the freight and passenger commercial motor carriers that are the most 
egregious offenders of federal motor carrier safety regulations. 
Accordingly, this report focuses on: 

* the extent to which FMCSA's policy for prioritizing compliance 
reviews targets carriers that subsequently have high crash rates, 

* how FMCSA ensures that its compliance reviews are conducted 
thoroughly and consistently, and: 

* the extent to which FMCSA follows up with carriers with serious 
safety violations. 

You also asked us to review other studies on SafeStat's ability to 
identify motor carriers with high crash risks and the impact of data 
quality on SafeStat's predictive ability. This report presents the 
findings on those issues from our June 2007 report.[Footnote 7] (See 
apps. I and II.) Finally, as you requested, this report discusses 
studies on predictors of motor carrier and driver crash risk. (See app. 
III.) 

In our June 2007 report, we assessed the extent to which changes in the 
SafeStat model, by using regression modeling techniques, could improve 
FMCSA's ability to identify commercial motor carriers that pose high 
crash risks. In contrast, this report assesses whether changes in how 
FMCSA prioritizes carriers for compliance reviews based on their scores 
in SafeStat's four evaluation areas could target carriers with higher 
aggregate crash risks. 

To determine the extent to which FMCSA's policy for prioritizing 
compliance reviews targets carriers that subsequently have high crash 
rates, we analyzed data from FMCSA's Motor Carrier Management 
Information System (MCMIS) on the June 2004 SafeStat assessment of 
carriers and on the assessed carriers' crashes in the 18 months (July 
2004 through December 2005) following the SafeStat assessment.[Footnote 
8] We defined various groups of carriers for analysis, including those 
to which FMCSA gave high priority, as well as those based on 
alternatives to FMCSA's prioritization policy. We then calculated the 
aggregate crash rate in the 18 months following the SafeStat assessment 
for each of these groups and compared crash rates among the various 
groups to determine whether there were any groups with substantially 
higher rates than the carriers in SafeStat categories A or B. We also 
talked to FMCSA officials about how FMCSA developed SafeStat, their 
views on other evaluations of SafeStat, and FMCSA's plans to replace 
SafeStat with a new tool. 

To assess how FMCSA ensures that its compliance reviews are completed 
thoroughly and consistently, we identified our key internal control 
standards related to the communication of policy, documentation of 
results, and monitoring and reviewing of activities and 
findings.[Footnote 9] In our view, these standards are critical to 
maintaining the thoroughness and consistency of compliance reviews. We 
gathered information on these key internal controls through discussions 
with FMCSA officials, reviews of policy documents and reports, and 
reviews of FMCSA information systems used to communicate policy, 
document findings, and review findings. We interviewed investigators 
who conduct compliance reviews and their managers in FMCSA's 
headquarters office, as well as in 7 of FMCSA's 52 field division 
offices that work with states, two of its four regional service centers 
that support division offices, and three state offices that partner 
with 3 of the FMCSA division offices in which we did our work.[Footnote 
10] The division offices we reviewed partner with states that received 
30 percent of the grant funds that FMCSA awarded to all states in 
fiscal year 2005 (the latest year for which data were available) 
through its primary grant program, the Motor Carrier Safety Assistance 
Program. Because we chose the seven states judgmentally (representing 
the largest grantees), we cannot project our findings nationwide. 
Reviewing a larger number of grantees would not have been practical due 
to resource constraints. We assessed the extent to which FMCSA conducts 
vehicle inspections and covers applicable safety regulations during 
compliance reviews by analyzing FMCSA data. 

To assess the extent to which FMCSA follows up with carriers with 
serious violations, we reviewed regulations and FMCSA policies 
directing how FMCSA must follow up and track these violators, analyzed 
data to determine if FMCSA had met these requirements, and held 
discussions with FMCSA officials. We also used data from MCMIS to 
assess the timeliness of FMCSA's follow-up compliance reviews. To 
assess FMCSA's implementation of the requirement to assess the maximum 
fine in certain cases, we compared FMCSA's policy with the language of 
the act, held discussions with FMCSA officials, estimated the number of 
carriers that could have been assessed the maximum fine based on 
different definitions of a "pattern" of violations, and reviewed the 
Department of Transportation Inspector General's report on the 
implementation of the policy.[Footnote 11] In assessing these various 
areas, we used the most recent data available at the time we conducted 
our fieldwork. The period of analysis varies depending on the time 
permitted by law, policy, or our judgment for FMCSA's follow-up. 

As part of our review, we assessed internal controls and the 
reliability of FMCSA's data on motor carriers' safety history and its 
compliance review and enforcement activities that were pertinent to 
this effort. While there are known problems with the quality of the 
crash data reported to FMCSA for use in SafeStat, we determined that 
the data were sufficiently reliable for our use, which was to assess 
whether different approaches to prioritizing carriers could lead to 
better targeting of carriers that subsequently have high crash rates. 
We conducted our work from February 2006 through August 2007 in 
accordance with generally accepted government auditing standards. (See 
app. IV for additional information on our scope and methodology.) 

Results in Brief: 

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

FMCSA's policy for prioritizing carriers for compliance reviews based 
on their SafeStat scores leads FMCSA to conduct compliance reviews on 
many high-risk carriers but not on other higher risk ones. Our analysis 
indicates that modifications to the policy could result in the 
selection of carriers with a higher aggregate crash risk than are 
selected using the current policy. Currently, carriers must score among 
the worst 25 percent of carriers in at least two of SafeStat's four 
evaluation areas to receive high priority for a compliance review. 
Using data from FMCSA's June 2004 SafeStat categorization, we found 
that the 492 carriers that scored among the worst 5 percent of carriers 
in the accident safety evaluation area--an area that, by itself, FMCSA 
gives low priority for compliance reviews--had an aggregate rate of 
subsequent crashes that was more than twice as high as that of the 
4,989 carriers to which FMCSA gave high priority.[Footnote 12] This 
suggests that FMCSA could target a higher risk group of carriers for 
compliance reviews by changing its prioritization policy so that high 
priority is also assigned to carriers that score among the worst 5 
percent of carriers in the accident area. We recognize that giving such 
carriers high priority for a compliance review would increase FMCSA's 
and the states' compliance review workloads unless FMCSA were to make 
another change to its prioritization rules that resulted in removing 
the same number of carriers from the high-priority categories A and B 
that had lower crash rates than the ones added. FMCSA officials told us 
that the agency plans to assess whether giving high priority to 
carriers that perform very poorly in the accident evaluation area alone 
would be an effective use of its resources. Furthermore, as part of a 
reform initiative aimed at improving how the agency identifies and 
deals with unsafe carriers, called the Comprehensive Safety Analysis 
2010, FMCSA is considering replacing SafeStat with a new tool by 2010. 
While the new tool may use some of the same data included in SafeStat, 
such as carriers' crash rates and driver and vehicle violations 
identified during compliance reviews and roadside inspections, it may 
also consider additional information from crash reports, such as 
whether driver fatigue or a lack of driver experience was cited as a 
causal or contributing factor. 

FMCSA's management of its compliance reviews meets our standards for 
internal controls, thereby promoting thoroughness and consistency. 
FMCSA records its compliance review policies and procedures in an 
electronic operations manual and distributes the manual to 
investigators and managers in FMCSA's 52 division offices and in the 
offices of its 56 state and territorial partners (hereafter called 
state partners).[Footnote 13] FMCSA also provides training to 
investigators on these policies and procedures, including initial 
classroom training, on-the-job training, and ad hoc training on new 
policies and procedures. Many investigators we spoke with generally 
found both the electronic manual and the training to be effective means 
of communicating policies and procedures. FMCSA and state investigators 
use an information system to document the results of the compliance 
reviews. This information system supports thoroughness and consistency 
by alerting investigators if they are not following key policies or if 
data appear suspect; the system also provides managers with readily 
available data to review. Managers in the division offices, states, and 
FMCSA's service centers use monthly activity reports to monitor 
performance at the investigator level, including the number of reviews 
completed and the number and types of violations identified. The 
service centers also conduct triennial reviews of the compliance review 
activities of each division and state office. In 2002, FMCSA performed 
an agencywide review of its compliance review program and made several 
improvements based on the findings of this review. One such improvement 
was to discourage repeat visits to high-risk motor carriers that had 
received an unsatisfactory rating during their last compliance review 
within the past 12 months because the agency believed that not enough 
time had elapsed to show whether safety improvements had taken effect. 
For the most part, FMCSA and state investigators cover the nine major 
applicable areas of the safety regulations (e.g., driver qualifications 
and vehicle repair and maintenance) in 95 percent or more of compliance 
reviews, demonstrating thoroughness and consistency. 

FMCSA follows up with many carriers with serious safety violations, but 
it does not assess maximum fines against all of the serious violators 
that we believe the law requires. FMCSA followed up with almost all the 
1,196 carriers that received a proposed safety rating of unsatisfactory 
following a compliance review that was completed in fiscal year 2005 to 
ensure that these carriers either made safety improvements that 
resulted in an upgraded final safety rating or were placed out of 
service. For example, FMCSA upgraded the safety ratings of 881 carriers 
primarily on the basis of safety improvements it identified during 
follow-up compliance reviews and reviews of documentary evidence of 
improvements submitted by carriers. FMCSA assigned a final rating of 
unsatisfactory to 312 of the remaining carriers, and placed 309 of them 
out of service. FMCSA monitors carriers to identify those that are 
violating out-of-service orders, but in fiscal years 2005 and 2006, it 
cited only 36 of 677 carriers that its monitoring showed had a roadside 
inspection or crash while subject to an out-of-service order. An FMCSA 
official told us that some of the 677 carriers, such as carriers that 
were operating intrastate,[Footnote 14] may not have been violating the 
out-of-service order, and that FMCSA did not have enough resources to 
determine whether each of the carriers was violating the out-of-service 
order. With regard to fines against carriers, we found that while FMCSA 
assesses maximum fines against carriers that repeat a serious 
violation, it does not, as we believe federal law requires, assess 
maximum fines against carriers with a pattern of serious violations. 
The law requires FMCSA to assess maximum fines against carriers in both 
situations. The annual number of carriers that would be subject to 
maximum fines under a definition of pattern that is consistent with the 
law varies greatly depending on the definition--for the eight 
definitions that we assessed, the number of such carriers in fiscal 
year 2006 varied from 7 to 3,348.[Footnote 15] In addition, FMCSA 
assesses maximum fines only for the third instance of a violation. We 
read the statute as requiring FMCSA to assess the maximum fine if a 
serious violation is repeated once--not only after it is repeated 
twice. 

We are recommending that FMCSA (1) select carriers with very poor 
scores in the accident safety evaluation area for compliance reviews, 
regardless of their scores in the other areas; (2) establish reasonable 
time frames within which it conducts follow-up compliance reviews on 
carriers rated conditional; and (3) revise its implementation of the 
requirement to assess maximum fines to meet our interpretation of the 
applicable law. We provided a draft of this report to the Department of 
Transportation for its review and comment. The department did not offer 
overall comments on the draft report. It said that it would assess the 
efficacy of the first recommendation, but it did not comment on the 
other recommendations. It offered several technical comments, which we 
incorporated where appropriate. 

Background: 

The interstate commercial motor carrier industry, primarily the 
trucking industry, is an important part of the nation's economy. Trucks 
transport over 11 billion tons of goods, or about 60 percent of the 
total domestic tonnage shipped.[Footnote 16] Buses also play an 
important role, transporting an estimated 860 million passengers in 
2005. FMCSA estimates that there are 711,000 interstate commercial 
motor carriers, about 9 million trucks and buses, and about 10 million 
drivers. Most motor carriers are small; about 51 percent operate one 
vehicle, and another 31 percent operate two to four vehicles. Carrier 
operations vary widely in size, however, and some of the largest motor 
carriers operate upwards of 58,000 vehicles. Carriers continually enter 
and exit the industry. Since 1998, the industry has increased in size 
by an average of about 29,000 interstate carriers per year. 

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

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

[See PDF for image] 

Source: GAO analysis of Department of Transportation data. 

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

The latest year for which data were available was 2005. 

[End of figure] 

In an attempt to reduce the number and severity of crashes involving 
large trucks, FMCSA was established by the Motor Carrier Safety 
Improvement Act of 1999. FMCSA assumed almost all of the 
responsibilities and personnel of the Federal Highway Administration's 
Office of Motor Carriers. The agency's primary mission is to reduce the 
number and severity of crashes involving large trucks and buses. It 
carries out this mission by (1) issuing, administering, and enforcing 
federal motor carrier safety regulations and hazardous materials 
regulations; (2) providing education and outreach for motor carriers 
and drivers on the safety regulations and hazardous materials 
regulations; (3) gathering and analyzing data on motor carriers, 
drivers, and vehicles; (4) developing information systems to improve 
the transfer of data; and (5) researching new methods and technologies 
to enhance motor carrier safety. 

FMCSA relies heavily on the results of compliance reviews to determine 
whether carriers are operating safely and, if not, to take enforcement 
action against them. (See fig. 2.) FMCSA conducts these on-site reviews 
to determine carriers' compliance with safety regulations that address 
areas such as testing drivers for alcohol and drugs, insurance 
coverage, crashes, driver qualifications, driver hours of service, 
vehicle maintenance and inspections, and transportation of hazardous 
materials. Due to resource constraints, FMCSA and its state partners 
are able to conduct compliance reviews on only about 2 percent of the 
nation's estimated 711,000 interstate motor carriers each year. It is 
FMCSA's policy to target these reviews at carriers that have been 
assessed by SafeStat as having the highest risk of crashes, have been 
the subject of a safety-related complaint submitted to FMCSA, have been 
involved in a fatal accident, have requested an upgraded safety rating 
based on safety improvements, or have been assigned a safety rating of 
conditional following a previous compliance review. 

Figure 2: FMCSA's Safety Oversight Approach: 

[See PDF for image] 

Source: GAO and FMCSA. 

[End of figure] 

Based largely on the number and severity of violations that it 
identifies during compliance reviews, FMCSA assigns carriers safety 
ratings that determine whether they are allowed to continue operating. 
FMCSA can take a range of enforcement actions against carriers with 
violations, including: 

* issuing notices of violation informing carriers of identified 
violations and indicating that additional enforcement action may be 
taken if the violations are not corrected; 

* issuing compliance orders directing carriers to perform certain 
actions that FMCSA considers necessary to bring the carrier into 
compliance with regulations; 

* assessing fines for violations of the safety regulations; fines 
require carriers to pay a specific dollar amount to FMCSA; 

* placing carriers or drivers out of service for unsatisfactory safety 
performance, failure to pay a fine, or imminently hazardous conditions 
or operations; 

* revoking the operating authority of carriers for failure to carry the 
required amount of insurance coverage; 

* pursuing criminal penalties in some instances when knowing and 
willful violations can be proved; and: 

* seeking injunctions from a court for violations of a final order such 
as an out-of-service order. 

FMCSA has 52 division offices that partner with the 56 recipients of 
its Motor Carrier Safety Assistance Program grants. FMCSA also funds 
and oversees enforcement activities, including compliance reviews, at 
the state level through this grant program. The program was 
appropriated $188 million, or about 38 percent, of FMCSA's $501 million 
appropriation for fiscal year 2006. In fiscal year 2006, FMCSA 
conducted 9,719 compliance reviews, and its state partners conducted 
5,463 compliance reviews. 

SafeStat assesses carriers' risks relative to all other carriers based 
on safety indicators such as their crash rates and safety violations 
identified during roadside inspections and during prior compliance 
reviews. A carrier's score is calculated on the basis of its 
performance in the following four safety evaluation areas: 

* The accident area reflects a carrier's crash history relative to 
other motor carriers based on data from states and MCMIS. 

* The driver area reflects a carrier's driver-related safety 
performance and compliance relative to other motor carriers based on 
driver violations identified during roadside inspections and compliance 
reviews. 

* The vehicle area reflects a carrier's vehicle-related safety 
performance and compliance relative to other motor carriers based on 
vehicle-related violations identified during roadside inspections and 
compliance reviews. 

* The safety management area reflects the carrier's safety management 
performance relative to other motor carriers based on safety-management-
related violations (such as failing to implement a drug or alcohol 
testing program) and hazardous-materials-related violations identified 
during compliance reviews and on closed enforcement cases resulting 
from compliance reviews. 

A motor carrier's score is based on the carrier's relative ranking, 
indicated as a value, in each of the four safety evaluation areas. This 
value can range from 0 to 100 in each area, and any value of 75 or 
greater is considered deficient. Any value of less than 75 is not 
considered deficient and is not used in calculating a SafeStat score. 
FMCSA assigns categories to carriers ranging from A to H according to 
their performance in each of the safety evaluation areas. (See table 
1.) Although a carrier may receive a value in any of the four safety 
evaluation areas, the carrier receives a SafeStat score only if it is 
deficient in two or more safety evaluation areas. The calculation used 
to determine a motor carrier's SafeStat score is: 

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

As shown in the formula, the accident and driver areas have 2.0 and 1.5 
times the weight, respectively, of the vehicle and safety management 
areas. FMCSA assigned more weight to these areas because accidents and 
driver violations correlate relatively better with future crash risk. 
In consultation with state transportation officials, insurance industry 
representatives, safety advocates, and the motor carrier industry, 
FMCSA used its expert judgment and professional knowledge to assign 
these weights, rather than determining them through a statistical 
approach, such as regression modeling. 

Table 1: SafeStat Categories: 

Category: Deficient in two or more areas: A; 
Condition: Deficient in two or more areas: Deficient in all four safety 
evaluation areas or deficient in three safety evaluation areas that 
result in a weighted SafeStat score of 350 or more; 
Priority for compliance review: Deficient in two or more areas: High. 

Category: Deficient in two or more areas: B; 
Condition: Deficient in two or more areas: Deficient in three safety 
evaluation areas that result in a weighted SafeStat score of less than 
350 or deficient in two safety evaluation areas that result in a 
weighted SafeStat score of 225 or more; 
Priority for compliance review: Deficient in two or more areas: High. 

Category: Deficient in two or more areas: C; 
Condition: Deficient in two or more areas: Deficient in two safety 
evaluation areas that result in a weighted SafeStat score of less than 
225; 
Priority for compliance review: Deficient in two or more areas: Medium. 

Category: Deficient in one area only: D; 
Condition: Deficient in one area only: Deficient in the accident safety 
evaluation area (area value between 75-100); 
Priority for compliance review: Deficient in one area only: Low. 

Category: Deficient in one area only: E; 
Condition: Deficient in one area only: Deficient in the driver safety 
evaluation area (area value between 75-100); 
Priority for compliance review: Deficient in one area only: Low. 

Category: Deficient in one area only: F; 
Condition: Deficient in one area only: Deficient in the vehicle safety 
evaluation area (area value between 75-100); 
Priority for compliance review: Deficient in one area only: Low. 

Category: Deficient in one area only: G; 
Condition: Deficient in one area only: Deficient in the safety 
management safety evaluation area (area value between 75- 100); 
Priority for compliance review: Deficient in one area only: Low. 

Category: Not deficient in any area: H; 
Condition: Not deficient in any area: Not deficient in any of the 
safety evaluation areas; 
Priority for compliance review: Not deficient in any area: Low. 

Source: GAO summary of FMCSA data. 

[End of table] 

Based on the results of a compliance review, FMCSA assigns the carrier 
a safety rating of satisfactory, conditional, or unsatisfactory. The 
safety rating, which is distinct from a carrier's SafeStat category, 
reflects FMCSA's determination of a carrier's fitness to operate 
safely. FMCSA issues out-of-service orders to carriers rated 
unsatisfactory, and these carriers are not allowed to resume operating 
until they make improvements that result in an upgraded safety rating. 
Carriers rated conditional are allowed to continue operating, but FMCSA 
aims to conduct follow-up compliance reviews on these carriers. FMCSA 
assigns safety ratings based on a carrier's performance in six areas. 
(See table 2.) One area is the carrier's accident rate, and the other 
five areas involve its compliance with regulations. The five regulation-
based areas are (1) minimum insurance coverage and procedures for 
handling and evaluating accidents; (2) drug and alcohol use and 
testing, commercial driver's license standards, and driver 
qualifications; (3) driver hours of service; (4) vehicle parts and 
accessories necessary for safe operation; inspection, repair, and 
maintenance of vehicles; and (5) transportation of hazardous materials. 

Table 2: How FMCSA Determines Carrier Safety Ratings Based on Ratings 
in Six Safety Areas: 

A carrier receives a safety rating of: Satisfactory; 
if it receives this number of unsatisfactory safety area ratings: 0; 
and this number of conditional safety area ratings: 2 or fewer. 

A carrier receives a safety rating of: Conditional; 
if it receives this number of unsatisfactory safety area ratings: 0; 
and this number of conditional safety area ratings: more than 2. 

A carrier receives a safety rating of: Conditional; 
if it receives this number of unsatisfactory safety area ratings: 0; 
and this number of conditional safety area ratings: 2 or fewer. 

A carrier receives a safety rating of: Unsatisfactory; 
if it receives this number of unsatisfactory safety area ratings: 1; 
and this number of conditional safety area ratings: more than 2. 

A carrier receives a safety rating of: Unsatisfactory; 
if it receives this number of unsatisfactory safety area ratings: 2 or 
more; 
and this number of conditional safety area ratings: 0 or more. 

Source: GAO presentation of FMCSA information. 

[End of table] 

Regardless of a carrier's safety rating, FMCSA can assess a fine 
against a carrier with violations, and it is more likely to assess 
higher fines when these violations are serious. FMCSA uses a tool to 
help it determine the dollar amounts of its fines. Federal law requires 
FMCSA to assess the maximum allowable fine against a carrier for each 
serious violation of federal motor carrier safety and commercial 
driver's license laws if the carrier is found to have a pattern of such 
violations or a record of previously committing the same or a related 
serious violation. 

FMCSA's Policy for Prioritizing Compliance Reviews Targets Many High- 
Risk Carriers, but Changes to the Policy Could Target Carriers with 
Even Higher Risk: 

SafeStat identifies many carriers that pose high crash risks.[Footnote 
17] However, modifications to FMCSA's policy that carriers have to 
score among the worst 25 percent of carriers in two or more safety 
evaluation areas to receive high priority for a compliance review and 
focusing more on crash risk could result in the selection of carriers 
with a higher aggregate crash risk.[Footnote 18] FMCSA recognizes that 
SafeStat can be improved, and as part of its Comprehensive Safety 
Analysis 2010 reform initiative, which is aimed at improving its 
processes for identifying and dealing with unsafe carriers, the agency 
is considering replacing SafeStat with a new tool by 2010. 

FMCSA's Policy for Prioritizing Compliance Reviews Leads the Agency to 
Conduct Compliance Reviews on Many High-Risk Carriers but Not on Other 
Higher Risk Ones: 

FMCSA's policy for prioritizing carriers for compliance reviews based 
on their SafeStat scores results in FMCSA's conducting compliance 
reviews on carriers with a higher aggregate crash risk than carriers 
that are not selected. As a result, FMCSA's prioritization policy has 
value as a method for targeting high-risk carriers. But changes to the 
policy could result in targeting carriers with an even higher aggregate 
crash risk. According to our analysis of SafeStat's June 2004 
categorization of carriers, the 4,989 carriers that received high 
priority for a compliance review (SafeStat categories A or B) had a 
higher aggregate crash risk (102 crashes per 1,000 vehicles in the 18 
months following the SafeStat categorization) than the remaining 
617,034 carriers (27 crashes per 1,000 vehicles). (See table 3.) 
However, the 2,464 carriers that scored among the worst 25 percent of 
carriers in the accident evaluation area alone (SafeStat category D) 
had a slightly higher aggregate crash risk (112 crashes per 1,000 
vehicles) than did the carriers in SafeStat categories A or B. 
Furthermore, the 1,090 carriers that scored among the worst 10 percent 
and the 492 carriers that scored among the worst 5 percent of carriers 
in the accident area (and did not score among the worst 25 percent of 
carriers in any other area) had even higher aggregate rates of 148 and 
213 crashes per 1,000 vehicles, respectively. 

Table 3: Crash Rates of Motor Carriers in Various SafeStat Categories 
in the 18 Months following the June 2004 SafeStat Categorization: 

SafeStat category(ies): A; 
Description: Deficient in three or four safety evaluation areas: 
SafeStat score 350 or more; 
Crash rate[A]: 107; 
Priority for compliance review: High; 
Number of motor carriers[B]: 631. 

SafeStat category(ies): B; 
Description: Deficient in two or three safety evaluation areas: 
SafeStat score 225 or more, and less than 350; 
Crash rate[A]: 101; 
Priority for compliance review: High; 
Number of motor carriers[B]: 4,358. 

SafeStat category(ies): Subtotal A+B; 
Description: See above; 
Crash rate[A]: 102; 
Priority for compliance review: High; 
Number of motor carriers[B]: 4,989. 

SafeStat category(ies): C; 
Description: Deficient in two safety evaluation areas; 
Crash rate[A]: 48; 
Priority for compliance review: Medium; 
Number of motor carriers[B]: 3,683. 

SafeStat category(ies): D; 
Description: Accident safety evaluation area value 75 or more; 
Crash rate[A]: 112; 
Priority for compliance review: Low; 
Number of motor carriers[B]: 2,464. 

SafeStat category(ies): Subset of D; 
Description: Accident safety evaluation area value 90 or more; 
Crash rate[A]: 148; 
Priority for compliance review: Low; 
Number of motor carriers[B]: 1,090. 

SafeStat category(ies): Subset of D; 
Description: Accident safety evaluation area value 95 or more; 
Crash rate[A]: 213; 
Priority for compliance review: Low; 
Number of motor carriers[B]: 492. 

SafeStat category(ies): All categories other than A and B; 
Description: [Empty]; 
Crash rate[A]: 27; 
Priority for compliance review: Medium or low; 
Number of motor carriers[B]: 617,034. 

Source: GAO analysis of FMCSA data. 

[A] Crash rates are crashes per 1,000 vehicles in the 18 months 
following the June 2004 SafeStat categorization. As discussed in 
appendix IV, we used data from FMCSA's June 2004 SafeStat 
categorization because these were the latest available data that we 
could use at the time of our analysis to obtain relatively complete 
data on carriers' numbers of crashes in the 18 months following the 
categorization. 

[B] The table includes only those carriers listed as having one or more 
vehicles. 

[End of table] 

Our analysis suggests that FMCSA's targeting of high-risk carriers 
could be enhanced by giving high priority for a compliance review to 
carriers that score among the worst 25, 10, or 5 percent of carriers in 
the accident evaluation area alone. We recognize that giving such 
carriers high priority for a compliance review would increase FMCSA's 
and the states' compliance review workloads unless FMCSA were to make 
another change to its prioritization policy that resulted in removing 
the same number of carriers from the high-priority categories A and 
B.[Footnote 19] For example, if FMCSA had given high priority to the 
492 carriers that scored among the worst 5 percent of carriers in the 
accident evaluation area in June 2004, it could have removed the 492 
carriers in categories A or B with the lowest SafeStat score in order 
to hold its and the states' compliance review workloads constant. The 
lowest-scoring carriers in categories A and B had an aggregate crash 
risk of 65 crashes per 1,000 vehicles, less than one-third the crash 
risk of the carriers that could have replaced them (214 crashes per 
1,000 vehicles). 

We also found that carriers that scored among the worst 25 percent, 10 
percent, or 5 percent of carriers in either the driver, vehicle, or 
safety management areas (and did not score among the worst 25 percent 
of carriers in any other area) had a lower aggregate crash risk than 
carriers in SafeStat categories A or B. Of these various groups of 
carriers with poor performance in a single area, the carriers that 
scored among the worst 10 percent of carriers in the driver area had 
the highest aggregate crash risk (70 crashes per 1,000 vehicles). 

A Regression Model Performs Better Than Current SafeStat Model and the 
Prioritization Approach We Developed: 

In our June 2007 report, we estimated that FMCSA could improve 
SafeStat's performance by about 9 percent by using a statistical 
regression model approach to weight the accident, driver, vehicle, and 
safety management evaluation areas instead of its current approach, 
which is based on expert judgment.[Footnote 20] Employing this approach 
would have allowed FMCSA to identify carriers with almost twice as many 
crashes in the following 18 months as those carriers identified under 
its current approach. We found that although the driver, vehicle, and 
safety management evaluation area scores are correlated with the future 
crash risk of a carrier, the accident evaluation area correlates the 
most with future crash risk and should be weighted more heavily than 
the current SafeStat formula weights this area. These results 
corroborate studies performed by the Volpe National Transportation 
Systems Center and Oak Ridge National Laboratory, the latter of which 
also employed statistical approaches. (See app. I for a discussion of 
these studies.) 

We believe that our regression model approach from our June 2007 report 
is preferable to the prioritization approach we developed in this 
report because it provides for a systematic assessment of the relative 
contributions of accidents and driver, vehicle, and safety management 
violations. That is, by its very nature, the regression model approach 
looks for the "best fit" in identifying the degree to which prior 
accidents and driver, vehicle, and safety management violations 
identify the likelihood of carriers having crashes in the future, 
compared with the current SafeStat approach and the prioritization 
approach we developed for this report, both of which use expert 
judgment to establish the relationship among the four evaluation areas. 
In addition, because the regression model could be run monthly--as is 
the current SafeStat model--any change in the degree to which accidents 
and driver, vehicle, and safety management violations better identify 
future crashes will be automatically considered as different weights 
are assigned to the four evaluation areas. This is not the case with 
the current SafeStat model, in which the evaluation area weights 
generally remain constant over time.[Footnote 21] Thus, the systematic 
assessment and the automatic updating of evaluation area weights using 
a regression model approach better ensure the targeting of carriers 
that pose high crash risks--both currently and in the future. 

We compared the performance of our regression model approach to the 
current SafeStat model and to two alternative approaches that employ 
the current SafeStat model approach (with the current weighting of 
evaluation areas) but give higher priority to some carriers in category 
D (carriers that scored among the worst 25 percent of carriers in only 
the accident evaluation area). The two alternatives were substituting 
carriers in the worst 5 percent of the accident evaluation area for 
carriers in SafeStat categories A and B with (1) the lowest accident 
area scores and (2) the lowest overall SafeStat numerical 
scores.[Footnote 22] The regression model approach performed better 
than the current SafeStat approach and at least as well as the 
alternatives discussed in this report, in terms of identifying carriers 
that experienced a higher aggregate crash rate or a greater number of 
crashes. (See table 4.) For example, the regression model approach 
identified carriers with an average of 111 crashes per 1,000 vehicles 
over an 18-month period compared with the current SafeStat approach 
that identified carriers for compliance reviews with an average of 102 
crashes per 1,000 vehicles. The regression model approach also 
performed at least as well as the alternatives discussed in this report 
in terms of identifying carriers with the highest aggregate crash rate 
and much better than the alternatives in identifying carriers with the 
greatest number of crashes. Finally, the alternatives discussed in this 
report were superior to the results of FMCSA's current prioritization 
policy in terms of identifying carriers with both a higher aggregate 
crash rate and a greater number of crashes. 

Table 4: Regression Model Approach Compared with Refined Prioritization 
Approach and with Current SafeStat Approach: 

Approach: Regression model approach; 
Crash rate[A]: 111.4; 
Number of crashes in 18 months: 19,580. 

Approach: Refined prioritization approach alternative 1: substitute 
SafeStat category D (accident) carriers for category A and B carriers 
with the lowest overall SafeStat scores; 
Crash rate[A]: 111.0; 
Number of crashes in 18 months: 10,682. 

Approach: Refined prioritization approach alternative 2: substitute 
SafeStat category D (accident) carriers for category A and B carriers 
with the lowest accident area scores; 
Crash rate[A]: 107.8; Number of crashes in 18 months: 10,887. 

Approach: Current SafeStat approach; 
Crash rate[A]: 102.2; 
Number of crashes in 18 months: 10,076. 

Source: GAO analysis of FMCSA data. 

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

[A] Crash rates are crashes per 1,000 vehicles in the 18 months 
following the June 2004 SafeStat categorization. 

[End of table] 

FMCSA officials told us that the agency plans to assess whether the 
approach developed in this report--giving high priority to carriers 
that perform very poorly in only the accident evaluation area (such as 
those that scored among the worst 5 percent)--would be an effective use 
of its resources. However, FMCSA officials expressed concern that 
adopting our regression model approach would reduce the effectiveness 
of FMCSA's compliance review program by targeting many compliance 
reviews at carriers that, despite high crash rates, have good 
compliance records. FMCSA believes that compliance reviews of such 
carriers, compared with compliance reviews of carriers in SafeStat 
categories A or B (carriers that, by definition, have a history of 
noncompliance), have less potential to reduce accidents. FMCSA said 
that this is because compliance reviews are designed to reduce crashes 
by identifying safety violations that some carriers then correct, and 
compliance reviews of carriers with good compliance records but high 
crash rates have historically identified fewer serious violations than 
compliance reviews of carriers in SafeStat categories A and B. FMCSA 
officials told us that, as part of its Comprehensive Safety Analysis 
2010 reform initiative, the agency is evaluating the potential for new 
ways to address motor carriers that are having crashes, but that it 
believes are not good candidates for the compliance review tool. (See 
the discussion on FMCSA's Comprehensive Safety Analysis 2010 reform 
initiative in a subsequent section.) 

We agree with FMCSA that the use of our model could tilt enforcement 
heavily toward carriers with high crash rates and away from carriers 
with compliance problems. We believe that use of the model would 
enhance motor carrier safety, even if it resulted in FMCSA reviewing 
carriers with good compliance records. FMCSA's mission--and the 
ultimate purpose of compliance reviews--is to reduce the number and 
severity of truck and bus crashes. As previously discussed, we found 
that while driver, vehicle, and safety management evaluation area 
scores are correlated with the future crash risk of a carrier, high 
crash rates are a stronger predictor of future crashes than is poor 
compliance with safety regulations. These facts suggest that FMCSA 
would improve motor carrier safety more by targeting carriers with high 
crash rates, even if they have better compliance records, than by 
targeting carriers in SafeStat categories A and B with significantly 
lower crash rates but with worse compliance records. The missing piece 
in the puzzle is that FMCSA does not have a good understanding of why 
some carriers, despite good compliance records, have high crash rates; 
how compliance reviews affect their crash rates; and what other 
approaches may be effective in reducing their crash rates. We believe 
that developing this understanding would be a natural outgrowth of 
implementing our regression model approach. 

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

FMCSA officials were also concerned that our issuing two reports on 
SafeStat within several months of each other could be interpreted as an 
indictment of SafeStat and of FMCSA's responsiveness to our June 2007 
report on this issue. This is not the case. SafeStat does a good job of 
identifying carriers that pose high crash risks. As we reported in June 
2007, we found that SafeStat is nearly twice as effective (83 percent 
better than) as random selection in identifying carriers that pose high 
crash risks and, therefore, has value for improving safety. 
Nonetheless, we found that FMCSA's policy for prioritizing compliance 
reviews could be improved by applying either our regression model 
approach or one of the prioritization approaches we developed in this 
report. While we believe that the regression model approach provides 
somewhat better safety results, we understand, as discussed in our June 
2007 report, that it could require FMCSA to re-educate the motor 
carrier industry and others, such as safety advocates, insurers, and 
the public, about the new approach. We would prefer that FMCSA 
implement our recommendation that it use our regression model approach 
but adopting either our regression model approach or one of the 
prioritization approaches we developed in this report would, in our 
opinion, improve FMCSA's targeting of high-risk carriers. The 
recommendation that we make in this report reflects this conclusion. 
Finally, FMCSA has been very helpful and responsive during both our-- 
largely concurrent--reviews. 

FMCSA Has Acted to Address Data Quality Problems That Potentially 
Hinder SafeStat's Ability to Identify High-Risk Carriers: 

For our June 2007 report, we assessed the quality of the data used by 
SafeStat and the degree to which the quality of the data affects 
SafeStat's identification of high-risk carriers, and we identified 
actions FMCSA has taken to improve the quality of the data used by 
SafeStat. We found that crash data reported by the states from December 
2001 through June 2004 have problems in terms of timeliness, accuracy, 
and completeness that potentially hinder FMCSA's ability to identify 
high-risk carriers. Regarding timeliness, we found that including late- 
reported data had a small impact on SafeStat--had all crash data been 
reported within 90 days of when the crashes occurred, 182 of the 
carriers identified by SafeStat as highest risk would have been 
excluded (because other carriers had higher crash risks), and 481 
carriers that were not originally designated as posing high crash risks 
would have scored high enough to be considered high risk, resulting in 
a net addition of 299 carriers (or 6 percent) to the original 4,989 
carriers that the SafeStat model ranked as highest risk in June 2004. 
We were not able to quantify the effect of incomplete or inaccurate 
data on SafeStat's ability to identify carriers that pose high crash 
risks, because doing so would have required us to gather crash records 
at the state level--an effort that was impractical. FMCSA has acted to 
improve the quality of SafeStat's data by completing a comprehensive 
plan for data quality improvement, implementing an approach to correct 
inaccurate data, and providing grants to states for improving data 
quality, among other things. We could not quantify the effects of 
FMCSA's efforts to improve the completeness or accuracy of the data for 
the same reason as just mentioned. (See app. II for a more detailed 
discussion of the quality of the data used by SafeStat.) 

FMCSA Is Considering Replacing SafeStat with a New Tool by 2010: 

As part of its Comprehensive Safety Analysis 2010, a reform initiative 
aimed at improving its processes for identifying and dealing with 
unsafe carriers and drivers, FMCSA is considering replacing SafeStat 
with a new tool by 2010. The new tool could take on greater importance 
in FMCSA's safety oversight framework because the agency is considering 
using the tool's assessments of carriers' safety to determine whether 
carriers are fit to continue operating.[Footnote 23] In contrast, 
SafeStat's primary use now is in prioritizing carriers for compliance 
reviews, and determinations of operational fitness are made only after 
the compliance reviews are completed. 

While the new tool may use some of the same data included in SafeStat, 
such as carriers' crash rates and driver and vehicle violations 
identified during compliance reviews and roadside inspections, it may 
also consider a broader range of behavioral data related to crashes 
than does SafeStat. For example, the new tool may consider information 
from crash reports, such as whether driver fatigue, a lack of driver 
experience, a medical reason, a mechanical failure, shifting loads, or 
spilled or dropped cargo, were cited as causal or contributing factors. 
An FMCSA official told us that the agency is analyzing the relationship 
between these factors and crash rates to help it determine how the 
factors should be assessed and the relative weights to place on the 
factors. We believe that, compared with the expert-judgment-based 
approach that FMCSA used to select the weights for SafeStat's 
evaluation areas, this analytical approach has the potential to better 
identify high-risk carriers. 

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

FMCSA manages its compliance reviews in a fashion that meets our 
standards for internal control, thereby promoting thoroughness and 
consistency in the reviews.[Footnote 24] For example, it records its 
policies and procedures related to compliance reviews in an operations 
manual. FMCSA also provides investigators with classroom and on-the-job 
training on how to plan for and conduct compliance reviews. In 
addition, it employs an information system that documents the results 
of compliance reviews and allows FMCSA and state managers to review the 
compliance reviews for thoroughness, accuracy, and consistency. FMCSA 
uses several approaches to monitor its compliance review program, 
including an agencywide review in 2002 that led to several changes in 
the program. 

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

FMCSA's communication of its policies and procedures related to 
conducting compliance reviews meets our standards for internal control. 
These standards state that an organization's policies and procedures 
should be recorded and communicated to management and others within the 
entity who need it and in a form (e.g., clearly written and provided as 
a paper or electronic manual) and within a time frame that enables them 
to carry out their responsibilities. FMCSA records and communicates its 
policies and procedures electronically through its "Field Operations 
Training Manual" (hereafter called the operations manual), which it 
provides to all federal and state investigators and their managers. The 
operations manual includes guidance on how to prepare for a compliance 
review. For example, it tells investigators that they must download and 
review a report that includes information on the carrier's accidents, 
drivers, and inspections, and it explains how this information can help 
the investigator focus the compliance review. It also specifies the 
minimum number of driver and vehicle maintenance records to be examined 
and the minimum number of vehicle inspections to be conducted during a 
compliance review. FMCSA aims to update its operations manual twice a 
year. It posts updates to the operations manual that automatically 
download to investigators and managers when they connect to the 
Internet. In between these updates, FMCSA communicates policy changes 
by e-mail. 

In addition to the operations manual, FMCSA provides training to 
investigators on its policies and procedures related to compliance 
reviews. FMCSA policy requires that investigators successfully complete 
classroom training and examinations before they conduct a compliance 
review. The training covers the safety and hazardous materials 
regulations and software tools used during compliance reviews. 
According to FMCSA officials, investigators then receive on-the-job 
training, which allows them to accompany an experienced investigator 
during compliance reviews. This training lasts until managers decide 
that the trainees are ready to complete a compliance review on their 
own, typically after 3 to 6 months on the job. Investigators can also 
take additional classroom training on specialized topics throughout 
their careers. Furthermore, according to FMCSA officials, FMCSA's 
division offices hold periodic and ad hoc meetings to train 
investigators about policy changes related to compliance reviews. In 
addition, in commenting on a draft of this report, FMCSA noted that it 
has an annual safety investigator certification process to ensure that 
only qualified personnel conduct compliance reviews. 

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

FMCSA's documentation of compliance reviews meets our standards for 
internal control. These standards state that all transactions and other 
significant events should be clearly and promptly documented, and the 
documentation should be readily available for examination. This applies 
to the entire process or life cycle of a transaction or event from the 
initiation and authorization through its final classification in 
summary records. The standards also state that control activities, 
including reviews of information and system edit checks, should help to 
ensure that all transactions are completely and accurately recorded. 
FMCSA and state investigators use an information system to document the 
results of their compliance reviews, including information on crashes 
and any violations of the safety regulations that they identify. This 
documentation is readily available to FMCSA managers, who told us that 
they review it to help ensure completeness and accuracy. FMCSA 
officials told us that the information system also helps ensure 
thoroughness and consistency by prompting investigators to follow 
FMCSA's policies and procedures, such as requirements to meet a minimum 
sample size. The information system also includes checks for 
consistency and reasonableness and prompts investigators when the 
information they enter appears to be inaccurate. An FMCSA manager told 
us that managers typically assess an investigator's thoroughness by 
comparing the investigator's rate of violations identified over the 
course of several compliance reviews with the average rate for 
investigators in their division office; a rate that is substantially 
below the average suggests insufficient thoroughness. Generally, FMCSA 
and state investigators and managers said they found the information 
system to be useful. 

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

FMCSA's performance measurement and monitoring of compliance review 
activities meet our standards for internal control. These standards 
state that managers should compare actual performance to planned or 
expected results and analyze significant differences. Monitoring of 
internal controls should include policies and procedures for ensuring 
that the findings of audits and other reviews are promptly resolved. 
According to FMCSA and state managers and investigators, the managers 
review all compliance reviews in each division office and state to 
ensure thoroughness and consistency across investigators and across 
compliance reviews. The investigators we spoke with generally found 
these reviews to be helpful, and several investigators said that the 
reviews helped them learn policies and procedures and ultimately 
perform better compliance reviews. FMCSA and state managers told us 
that they also use monthly reports to track the performance of 
investigators using measures such as the numbers of reviews completed 
and the rates of violations found. Managers generally found that these 
reports provide useful information on investigators' performance, and 
several managers said that they use the reports to help identify 
specific areas where an investigator needs additional coaching or 
training. However, several state managers said that monitoring of their 
investigators' performance would be enhanced if they had access to 
FMCSA's monthly report on their investigators; currently, states rely 
on their own custom reports. FMCSA told us that it plans to make its 
monthly report on state investigators available to state managers by 
October 2007. 

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

FMCSA's agencywide review indicated that inconsistencies and 
bottlenecks in the compliance review process were reducing its 
efficiency and effectiveness, and FMCSA made several changes in 2003 
aimed at improving compliance review policies, procedures, training, 
software, and supporting motor carrier data. Examples of problems 
identified and actions taken are as follows: 

* FMCSA discouraged repeat visits to high-risk motor carriers that had 
received unsatisfactory ratings during their last compliance review 
within the past 12 months because the agency believed that not enough 
time had elapsed to show whether safety improvements had taken effect. 

* FMCSA discouraged safety investigators from their earlier practice of 
favoring violations of drug and alcohol regulations over violations of 
hours-of-service regulations when they choose which violations to 
document for enforcement because crash data and FMCSA's survey of its 
field staff suggest that compliance with hours-of-service regulations 
is more important for safety. 

* FMCSA revised its operations manual to encourage FMCSA's division 
offices to document the maximum number of areas of the regulations 
where major safety violations are discovered, rather than penalizing 
motor carriers for a few violations in a particular area at the expense 
of other areas. 

FMCSA's review also concluded that most investigators were not 
following FMCSA's policy requiring them to perform vehicle inspections 
as part of a compliance review if the carrier has not already received 
the required number of roadside vehicle inspections.[Footnote 25] FMCSA 
has since changed its policy so that inspecting a minimum number of 
vehicles is no longer a strict requirement--if an investigator is 
unable to inspect the minimum number of vehicles, he or she must 
explain why in the compliance review report.[Footnote 26] FMCSA told us 
that, as part of their review of individual compliance reviews, 
division office managers ensure that when compliance reviews have fewer 
than the minimum number of vehicle inspections, investigators provide 
adequate justification in their reports. We did not verify this 
statement because we did not have enough time or resources. We did, 
however, assess the extent to which compliance reviews included the 
minimum number of vehicle inspections. In fiscal year 2005, FMCSA and 
its state partners conducted 7,436 compliance reviews on carriers that 
had not already received the minimum number of vehicle inspections; of 
these, only 254 compliance reviews (3 percent) included the minimum 
number of vehicle inspections. 

FMCSA's review also found that investigators considered inspections to 
be the one aspect of compliance reviews, other than licensing and 
insurance verification, that had the smallest effect on carriers' 
safety performance. FMCSA's review team recommended that FMCSA 
establish new criteria for conducting vehicle inspections during 
compliance reviews, and suggested that inspections could be made 
optional. In contrast, in 2002, the National Transportation Safety 
Board (the Safety Board) recommended that FMCSA require that all 
compliance reviews include vehicle inspections. The Safety Board based 
its recommendation on its belief that the vehicles that receive 
roadside inspections may be less likely to have violations than the 
vehicles that could be inspected during a compliance review. In July 
2006, FMCSA responded that implementing this recommendation would be 
imprudent because it would divert attention from driver and other 
safety factors, and FMCSA's recent study of the causes of large truck 
crashes indicates the importance of driver factors, such as driving too 
fast for conditions and driver fatigue. FMCSA has not changed its 
policy, but an FMCSA official told us that under the operational model 
that FMCSA has proposed for its Comprehensive Safety Analysis 2010 
reform initiative, vehicle inspections during compliance reviews would 
be optional. FMCSA also told us that it is developing a policy that 
would allow investigators conducting compliance reviews to inspect 
vehicles that operate in intrastate commerce. FMCSA believes that this 
policy will increase the number of compliance reviews with the minimum 
number of vehicle inspections. 

Finally, FMCSA's review found that although investigators generally 
sampled the number of carrier records required by FMCSA's policies, the 
number of undersized samples of drivers' work hour logs was a cause for 
concern. The review said that a lack of clarity in FMCSA's requirements 
for how carriers must document drivers' hours was likely resulting in 
some carriers having too few records to sample. FMCSA is working to 
clarify its documentation requirements, but it has not set a date for 
completing this task. 

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

From fiscal year 2001 through fiscal year 2006, each of the nine major 
applicable areas of the safety regulations was covered by most of the 
approximately 76,000 compliance reviews conducted by FMCSA and the 
states. (See table 5.) 

Table 5: Percentages of Compliance Reviews for Fiscal Years 2001 
through 2006 That Covered Each of the Major Applicable Areas of the 
Safety Regulations: 

Regulatory area: Procedures for handling and evaluating accidents; 
Percentage: 97%. 

Regulatory area: Drivers' qualifications; 
Percentage: 96. 

Regulatory area: Drivers' hours of service; 
Percentage: 96. 

Regulatory area: Inspection, repair, and maintenance of vehicles; 
Percentage: 96. 

Regulatory area: Drug and alcohol use and testing; 
Percentage: 95. 

Regulatory area: Commercial driver's license standards; 
Percentage: 95. 

Regulatory area: Driving of motor vehicles; 
Percentage: 94. 

Regulatory area: Minimum insurance coverage; 
Percentage: 90. 

Regulatory area: Vehicle parts and accessories necessary for safe 
operation; 
Percentage: 80. 

Source: GAO analysis of FMCSA data. 

[End of table] 

An FMCSA official told us that not every compliance review is required 
to cover all nine areas and cited the following reasons: 

* Follow-up compliance reviews of carriers rated unsatisfactory or 
conditional are sometimes streamlined to cover only the area or areas 
of the regulations in which the carrier had violations. 

* Commercial driver's license standards and drug and alcohol use and 
testing regulations apply primarily to those carriers that operate one 
or more vehicles weighing over 26,000 pounds (gross vehicle weight 
rating), that haul hazardous material, or that transport more than 15 
passengers. 

* Minimum insurance coverage regulations apply only to for-hire 
carriers and private carriers of hazardous materials; they do not apply 
to private passenger and nonhazardous materials carriers. 

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

In addition to the safety regulations, compliance reviews of hazardous 
materials carriers, shippers, and cargo tank facilities must cover 
hazardous materials regulations. In fiscal years 2005 and 2006, FMCSA 
conducted about 6,000 compliance reviews of hazardous materials 
operators. Collectively, these compliance reviews covered between 40 
percent and 80 percent of the various individual areas of these 
regulations. However, none of these compliance reviews was required to 
cover all areas of the hazardous materials regulations; the required 
areas vary with the type of operator. Because the categories that MCMIS 
uses to classify hazardous materials operators are different from the 
categories used to determine which areas of the regulations must be 
covered, we could not determine, for the different types of operators, 
the extent to which FMCSA's compliance reviews covered the required 
areas. 

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

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

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

FMCSA followed up with 1,193 of 1,196 carriers (99.7 percent) that 
received a proposed safety rating of unsatisfactory following a 
compliance review that was completed in fiscal year 2005. FMCSA's 
follow-up generally ensured that these carriers either made safety 
improvements that resulted in an upgraded final safety rating or--as 
required for carriers that also receive a final safety rating of 
unsatisfactory--were placed out of service. More specifically, FMCSA 
used the following approaches to follow up with these carriers: 

* Follow-up compliance review. Based on such reviews, FMCSA upgraded 
the final safety ratings of 663 carriers (329 to satisfactory, and 334 
to conditional). 

* Assignment of a final rating of unsatisfactory and issuance of an out-
of-service order. FMCSA assigned a final rating of unsatisfactory to 
312 carriers and issued an out-of-service order to 309 (99 percent) of 
them. An FMCSA official told us that it did not issue an out-of- 
service order to 2 carriers because it could not locate them, and it 
did not issue an out-of-service order to another carrier because the 
carrier was still subject to an out-of-service order that FMCSA issued 
several years prior to the 2005 compliance review. 

* Review of evidence of corrective action. Carriers can request an 
upgraded safety rating by submitting evidence of corrective action to 
FMCSA. Based on reviews of such evidence, FMCSA upgraded the final 
safety ratings of 217 carriers (23 to satisfactory, and 194 to 
conditional). 

* Administrative review. Carriers that believe FMCSA made an error in 
assigning their proposed safety rating may request the agency to 
conduct an administrative review. Based on the administrative review, 
FMCSA upgraded the final safety rating of 1 carrier to conditional. 

FMCSA did not assign final safety ratings to the remaining 3 carriers. 
For 1 of these carriers, MCMIS indicates that the compliance review 
that resulted in the proposed rating of unsatisfactory did not identify 
any violations, even though carriers without violations are not 
supposed to receive a proposed unsatisfactory rating. For another of 
the carriers, MCMIS shows crashes, inspections, and a compliance review 
while also indicating that the carrier is inactive. FMCSA has been 
unable to locate the final carrier, and MCMIS indicates that the 
carrier is inactive. 

Unless FMCSA upgrades a proposed unsatisfactory safety rating or grants 
a carrier an extension, the agency is required under its policy to 
assign the carrier a final rating of unsatisfactory and to issue it an 
out-of-service order on the 46th day after the date of FMCSA's notice 
of a proposed unsatisfactory rating for carriers of hazardous materials 
or passengers and on the 61st day for other types of carriers.[Footnote 
27] Of the 309 out-of-service orders that FMCSA issued to carriers 
rated unsatisfactory following compliance reviews conducted in fiscal 
year 2005, 276 (89 percent) were issued on time, 28 (9 percent) were 
issued between 1 and 10 days late, and 5 (2 percent) were issued more 
than 10 days late. FMCSA also assigned final upgraded safety ratings 
within these time frames in 837 (95 percent) of the 881 cases in which 
it upgraded these ratings. FMCSA assigned 20 upgrades (2 percent) 
between 1 and 10 days late, and it assigned another 20 (2 percent) more 
than 10 days late. MCMIS did not have information on the timing of the 
other 4 upgrades. An FMCSA official told us that when an out-of-service 
order was issued more than 1 week late, the primary reason for the 
delay was that the responsible FMCSA division office had difficulty 
scheduling a follow-up compliance review and thus waited to issue the 
orders. The official said that other delays were caused by clerical 
errors; extended periods during which certain division offices operated 
without a person serving in the position with primary responsibility 
for ensuring that out-of-service orders are issued on time; a lack of 
complete compatibility between MCMIS and FMCSA's enforcement database; 
and, in one service center whose policy is to personally serve out-of- 
service orders to carriers, insufficient advance notification by the 
service center to its division offices that an order was to be served. 
The official noted that the last two issues have been addressed and 
said that FMCSA plans to more closely monitor the timeliness of the 
issuance of out-of-service orders in all of FMCSA's division offices. 

FMCSA Monitors Carriers to Identify Those That Are Violating Out-of- 
Service Orders, but It Does Not Take Additional Action against Many of 
the Violators It Identifies: 

FMCSA uses two primary means to try to ensure that carriers that have 
been placed out of service do not continue to operate. First, FMCSA 
partners with states to help them suspend, revoke, or deny vehicle 
registration to carriers that have been placed out of service. FMCSA 
refers to these partnerships as the Performance and Registration 
Information Systems Management program (PRISM). PRISM links FMCSA 
databases with state motor vehicle registration systems and roadside 
inspection personnel to help identify vehicles operated by carriers 
that have been issued out-of-service orders. As of January 2007, 45 
states had been awarded PRISM grants, and 27 states were operating with 
PRISM capabilities. FMCSA officials told us that some states have not 
applied for PRISM grants because they do not want to bear the costs 
that are not covered by the grants or they have not made the 
legislative changes required to implement PRISM. According to an FMCSA 
official, FMCSA has also begun working with PRISM states to enable them 
to receive automated notifications of carriers that have been placed 
out of service. PRISM can also identify carriers that attempt to 
register vehicles under a different carrier name, and FMCSA provided us 
with information on two out-of-service carriers that Connecticut, using 
PRISM, had caught trying to register vehicles by using a new company 
name. In addition, in commenting on a draft of this report, FMCSA said 
that during the first 6 months of fiscal year 2007, states that 
reported data to FMCSA indicated that at least 104 motor carriers had 
their state vehicle registrations suspended, revoked, or denied based 
on an FMCSA order to cease interstate operations. 

FMCSA and its state partners also monitor carriers for indicators--such 
as roadside inspections, moving violations, and crashes--that the 
carriers may be violating an out-of-service order. First, FMCSA 
recently began to require the state partners that receive Motor Carrier 
Safety Assistance Program grants to check during roadside inspections 
whether carriers are operating under revoked authority and to take 
enforcement action against any that are. Second, FMCSA visits some 
suspect carriers that it identifies by monitoring crash and inspection 
data to examine their records to determine whether they did indeed 
violate the order. FMCSA told us it is difficult for it to verify that 
such carriers were operating in violation of out-of-service orders 
because its resources do not allow it to visit each carrier or conduct 
roadside inspections on all vehicles, and we agree. In fiscal years 
2005 and 2006, 677 of 1,741 carriers (39 percent) that were subject to 
an out-of-service order had a roadside inspection or crash; FMCSA cited 
only 36 of these 677 carriers for violating the out-of-service order. 
An FMCSA official told us that some of these carriers, such as carriers 
that were operating intrastate or leasing vehicles to other carriers, 
may not have been violating the out-of-service order. The official said 
that the agency did not have enough resources to determine whether each 
of the carriers was violating the out-of-service order. He also said 
that FMCSA recently completed a pilot program in which the agency cited 
obvious violators such as carriers that have a roadside inspection 
outside their home state. In commenting on a draft of this report, 
FMCSA said that it is developing new policies and procedures intended 
to establish a uniform national approach for follow-up, as well as 
additional enforcement action against motor carriers that have violated 
an out-of-service order. 

The Safety Board Recently Concluded That FMCSA Is Making Adequate 
Progress in Ensuring That Carriers Do Not Operate under Revoked 
Authority: 

In 2006, the Safety Board assessed FMCSA's approach to ensuring that 
carriers whose operating authority has been revoked do not operate and 
concluded that it was inadequate.[Footnote 28] The Safety Board 
recommended that FMCSA establish a program to address this issue. In 
response to this recommendation, FMCSA noted that, because the numbers 
of carriers that have been placed out of service or have had their 
operating authority revoked has significantly increased in recent 
years, it is difficult to ensure that these carriers do not continue to 
operate. An FMCSA official attributed this difficulty to FMCSA's lack 
of resources to visit each carrier or conduct roadside inspections on 
all vehicles--the same reason FMCSA cites for not following up on all 
carriers that may be violating an out-of-service order. Despite this 
difficulty, FMCSA responded that it (1) is linking its licensing and 
insurance database to its primary carrier database to improve the 
ability of roadside inspection personnel in all states and registration 
offices in PRISM states to identify carriers that have had their 
operating authority revoked and (2) has directed division office 
managers to assess fines when data accessed during roadside inspections 
indicate that carriers were operating under revoked authority. In March 
2007, the Safety Board said that FMCSA was making acceptable progress 
on the recommendation, but expressed concern that some states will 
choose not to implement PRISM and that, based on the program's rate of 
implementation thus far, it will take too long to become fully 
operational in many other states. The Safety Board, therefore, 
encouraged FMCSA to implement PRISM more rapidly in all states. An 
FMCSA official told us that the agency is already making a concerted 
effort to encourage the 5 states without PRISM to adopt the program and 
the 18 PRISM states that do not yet have full PRISM capabilities to 
achieve them. 

FMCSA Has Reduced the Number of Carriers Rated Conditional That Need 
Follow-up Compliance Reviews, but the Timeliness of These Reviews Is 
Difficult to Assess: 

FMCSA's policy requires the agency to conduct follow-up compliance 
reviews on all carriers rated conditional and, over the last several 
years, the agency has reduced the number of such carriers needing 
review. After the Department of Transportation Inspector General 
reported in 1999 that FMCSA allowed motor carriers with less than 
satisfactory ratings to continue operations for extended periods of 
time, FMCSA began requiring follow-up compliance reviews on all 
carriers rated conditional. In fiscal years 2005 and 2006, 
respectively, FMCSA conducted 2,537 and 2,692 follow-up reviews of 
carriers rated conditional or unsatisfactory,[Footnote 29] exceeding 
its annual goal of 2,500 follow-up reviews.[Footnote 30] In addition, 
from fiscal year 2000 through fiscal year 2006, the number of carriers 
rated conditional that needed a follow-up review decreased from about 
40,000 to about 30,000. 

While FMCSA has reduced the number of carriers rated conditional that 
need a follow-up review, it is difficult to assess the agency's 
timeliness in conducting these reviews because FMCSA's policy does not 
specify a time frame for following up on carriers with conditional 
safety ratings. The policy does discourage follow-up reviews within 12 
months because FMCSA believes that more time is needed to show the 
effects of safety improvements. Yet the policy also gives FMCSA's 
division office administrators the discretion to determine whether a 
follow-up review should be conducted within 12 months. Almost half of 
all carriers that received a conditional rating from fiscal year 2002 
through fiscal year 2004 received a follow-up review within 12 months; 
however, because of the policy's allowance for discretion, we could not 
determine how many, if any, of these follow-up reviews, occurred too 
soon. (See table 6.) In addition, because FMCSA does not specify a 
deadline for conducting follow-up reviews, we could not determine 
whether any of the reviews occurred too late. Our analysis of the 
timing of follow-up reviews shows that from fiscal year 2002 through 
fiscal year 2004, 66 percent of the carriers that received a 
conditional rating received a follow-up review within 24 months, while 
7 percent received a follow-up review more than 24 months after they 
received their conditional rating. Another 27 percent of the carriers 
still needed a review as of September 2006. 

Table 6: Time Elapsed before Carriers Rated Conditional Received Follow-
up Compliance Reviews, Fiscal Years 2002 through 2004, as of September 
2006: 

Time elapsed before follow-up compliance review: 0 to 12 months; 
2002: Number of follow-up reviews: 1,203 (51%); 
2003: Number of follow-up reviews: 1,132 (42%); 
2004: Number of follow-up reviews: 1,021 (42%); 
Total: Number of follow-up reviews: 3,356 (45%). 

Time elapsed before follow-up compliance review: More than 12 months to 
18 months; 
2002: Number of follow-up reviews: 311 (13); 
2003: Number of follow-up reviews: 413 (15); 
2004: Number of follow-up reviews: 398 (16); 
Total: Number of follow-up reviews: 1,122 (15). 

Time elapsed before follow-up compliance review: More than 18 months to 
24 months; 
2002: Number of follow-up reviews: 86 (4); 
2003: Number of follow-up reviews: 163 (6); 
2004: Number of follow-up reviews: 191 (8); 
Total: Number of follow-up reviews: 440 (6). 

Time elapsed before follow-up compliance review: More than 24 months; 
2002: Number of follow-up reviews: 180 (8); 
2003: Number of follow-up reviews: 274 (10); 
2004: Number of follow-up reviews: 86 (4); 
Total: Number of follow-up reviews: 540 (7). 

Time elapsed before follow-up compliance review: Still need a review; 
2002: Number of follow-up reviews: 568 (24); 
2003: Number of follow-up reviews: 722 (27); 
2004: Number of follow-up reviews: 723 (30); 
Total: Number of follow-up reviews: 2,013 (27). 

Time elapsed before follow-up compliance review: Total; 
2002: Number of follow-up reviews: 2,348 (100%); 
2003: Number of follow-up reviews: 2,704 (100%); 
2004: Number of follow-up reviews: 2,419 (100%); 
Total: Number of follow-up reviews: 7,471 (100%). 

Source: GAO analysis of FMCSA data. 

[End of table] 

FMCSA Is Developing a New Safety Rating Methodology: 

In 1999, the Safety Board recommended that FMCSA lower its threshold 
for rating a carrier unsatisfactory to include carriers with an 
unsatisfactory rating in either the driver or vehicle factor of the 
rating scheme. The Safety Board has classified this recommendation as 
one of its "most wanted" safety improvements since 2000.[Footnote 31] 
Although FMCSA has not yet decided whether it will implement this 
recommendation, it is developing a new rating methodology as part of 
its Comprehensive Safety Analysis 2010 reform initiative, and it plans 
to implement the methodology in 2010. As mentioned previously, the new 
methodology would base determinations of whether carriers are fit to 
continue operating on assessments made by the tool that FMCSA is 
developing to replace SafeStat, rather than on the results of 
compliance reviews. FMCSA believes that the new approach will enable 
the agency to assess the safety fitness of a larger share of the motor 
carrier industry. 

FMCSA is also considering determining the safety fitness of drivers, 
and applying interventions to those that it deems need them. FMCSA 
believes that the increased focus that this would bring to the safety 
of drivers is important because the results of its recent study on the 
causes of large truck crashes indicate that drivers of large trucks and 
other vehicles involved in truck crashes are 10 times more likely to be 
the cause of the crash than other factors, such as weather, road 
conditions, and vehicle performance. In addition, FMCSA is considering 
eliminating the conditional rating and using only two ratings-- 
"continue to operate" and "unfit." An FMCSA official told us that FMCSA 
may eliminate the conditional rating because the agency feels that the 
current satisfactory rating is being misinterpreted by some government 
agencies and members of the public that hire carriers as FMCSA's seal 
of approval. The official said that the agency believes that the 
"continue to operate" rating, which would be given to all carriers that 
are allowed to continue to operate, is less likely to be viewed as a 
seal of approval than the satisfactory rating, which indicates a level 
of safety that is greater than the conditional rating that also allows 
carriers to continue operating. Depending on their safety performance, 
carriers or drivers allowed to continue operating could be subject to 
interventions, such as Web-based education, warning letters, requests 
for submission of documents, targeted roadside inspections, focused on- 
site reviews, comprehensive on-site reviews (similar to compliance 
reviews), and enforcement actions. 

Policy Change Gives FMCSA Appropriate Discretion in Performing 
Statutorily Required Reviews of High-Risk Carriers: 

From August 2006 through February 2007, data from MCMIS indicate that 
FMCSA performed compliance reviews on 1,136 of the 2,220 (51 percent) 
carriers that were covered by FMCSA's mandatory compliance review 
policy.[Footnote 32] Under the Safe, Accountable, Flexible, Efficient 
Transportation Equity Act: A Legacy for Users, FMCSA is required to 
conduct compliance reviews on carriers rated in SafeStat categories A 
or B for 2 consecutive months. In response to this requirement, in June 
2006, FMCSA implemented a policy requiring a compliance review within 6 
months for any such carrier unless the carrier had received a 
compliance review within the previous 12 months.[Footnote 33] An FMCSA 
official told us that the agency did not have enough resources to 
conduct compliance reviews on all of the 2,220 carriers within the 
first 6-month period. 

In April 2007, FMCSA revised the policy because the agency believes 
that it required compliance reviews for some carriers that did not need 
them, leaving FMCSA with insufficient resources to conduct compliance 
reviews on other carriers that did need them. The carriers that did not 
need compliance reviews were those that had already had a compliance 
review and had corrected identified violations, but these violations 
continued to adversely affect their SafeStat rating because SafeStat 
penalizes carriers for violations regardless of whether they have been 
corrected. This unnecessary targeting drained resources, leaving FMCSA 
without the means to conduct compliance reviews of carriers that had 
never received such a review, but, in FMCSA's view, should have 
received one because of current safety performance issues that led to 
their placement in SafeStat categories C, D, or E. The new policy 
requires compliance reviews within 6 months for carriers that have been 
in SafeStat categories A or B for 2 consecutive months and received 
their last compliance review 2 or more years ago (or have never 
received a compliance review).[Footnote 34] In addition, compliance 
reviews are recommended for carriers that have been in SafeStat 
categories A or B for 2 consecutive months and received their last 
compliance review more than 1 year ago but less than 2 years ago. FMCSA 
division offices can decide not to conduct a compliance review on such 
a carrier if (1) its SafeStat category changes to a category other than 
A or B or (2) its safety evaluation area values are based largely on 
prior compliance review violations that have been corrected or on 
accidents or inspections that occurred prior to the carrier's last 
compliance review. We believe that these changes are consistent with 
the act's requirement and give FMCSA appropriate discretion in 
allocating its compliance review resources. 

FMCSA Has Substantially Reduced Its Backlog of Enforcement Cases: 

From October 2005 through October 2006, FMCSA reduced its backlog of 
enforcement cases that had been open for 6 months or more by about 70 
percent (from 807 to 247).[Footnote 35] As the Department of 
Transportation Inspector General has noted, a large backlog of 
enforcement cases negatively affects the integrity of the enforcement 
process for two reasons. First, because FMCSA considers only closed 
enforcement cases when targeting motor carriers for a compliance 
review, high-risk motor carriers are less likely to be selected if they 
have an open enforcement case. Second, because FMCSA assesses smaller 
fines against carriers with open cases than against those with closed 
cases, it may not assess appropriate fine amounts against carriers with 
multiple enforcement cases (the number of prior enforcement cases is 
one of the criteria that FMCSA uses to determine fine amounts). FMCSA's 
2002 review of its compliance review program also found that delays in 
closing enforcement cases were negatively affecting the integrity of 
the agency's enforcement process. An FMCSA official told us that in 
response to this review, the agency assigned a second attorney to work 
on enforcement cases. In 2005, we recommended that FMCSA establish a 
goal specifying how much it would like to reduce the enforcement 
backlog and by what date. In March 2007, FMCSA implemented this 
recommendation by establishing goals to (1) close, by the end of 2007, 
its backlog of 63 enforcement cases in its division offices that had 
been open for 270 days or more and (2) close, by August 31, 2007, its 
backlog of 14 cases pending before its Assistant Administrator for 
Enforcement for more than 18 months, without adding other cases to this 
backlog. 

FMCSA Does Not Assess Maximum Fines Against All of the Serious 
Violators That the Law Requires: 

FMCSA does not assess maximum fines against all of the serious 
violators that we believe the law requires. The law requires FMCSA to 
assess the maximum allowable fine for each serious violation by a 
carrier that is found (1) to have a pattern of committing such 
violations (pattern requirement) or (2) to have previously committed 
the same or a related serious violation (repeat requirement).[Footnote 
36] The legislative history of this provision provides evidence that 
FMCSA must assess maximum fines in these two distinct 
situations.[Footnote 37] However, FMCSA's policy on maximum fines does 
not fully meet these requirements. FMCSA enforces both requirements 
using what is known as the "three strikes rule," applying the maximum 
allowable fine when it finds that a motor carrier has violated the same 
regulation three times within 6 years. FMCSA officials said they 
interpret both parts of the act's requirements to refer to repeat 
violations, and because they believe that having two distinct policies 
on repeat violations would confuse motor carriers, FMCSA has chosen to 
address both requirements with its single three strikes policy. 
According to FMCSA officials, FMCSA developed the three strikes policy 
in response to a provision in the Motor Carrier Safety Act of 
1984,[Footnote 38] which permitted FMCSA's predecessor to assess a fine 
of up to $1,000 per offense (capped at $10,000) if the agency 
determined that "a serious pattern of safety violations" existed or had 
occurred. FMCSA officials told us that when Congress in 1999 enacted 
the current "pattern of violations" language in the Motor Carrier 
Safety Improvement Act, the agency interpreted it to be similar to the 
previous language and to mean three strikes.[Footnote 39] 

FMCSA's interpretation does not carry out the statutory mandate to 
impose maximum fines in two different cases. In contrast to FMCSA, we 
read the statute's use of the distinct terms "a pattern of violations" 
and "previously committed the same or a related violation" as requiring 
FMCSA to implement two distinct policies. A basic principle of 
statutory interpretation is that distinct terms should be read as 
having distinct meanings. In this case, the statute not only uses 
different language to refer to the violations for which maximum fines 
must be imposed, but it also sets them out separately and makes either 
type of violation subject to the maximum penalties. Therefore, one 
carrier may commit a variety of serious violations and another carrier 
may commit a serious violation that is the same as, or substantially 
similar to, a previous serious violation; the language on its face 
requires FMCSA to assess the maximum allowable fine in both situations-
-for a pattern of violations, as well as a repeat offense. 

FMCSA could define a pattern of serious violations in numerous ways 
that are consistent with the act's pattern requirement. Our application 
of eight potential definitions shows that the number of carriers that 
would be subject to maximum fines depends greatly on the definition. 
(See table 7.) For example, a definition calling for two or more 
serious violations in each of at least four different regulatory areas 
during a compliance review would have made 38 carriers subject to 
maximum fines in fiscal year 2006. In contrast, a definition calling 
for one or more serious violations in each of at least three different 
regulatory areas would have made 1,529 carriers subject to maximum 
fines during that time.[Footnote 40] 

Table 7: Number of Motor Carriers That Would Have Been Subject to 
Maximum Fines under Various Definitions of a Pattern of Serious 
Violations, Fiscal Years 2004 through 2006: 

Number of regulatory areas with serious violations: 2 or more; 
Number of carriers in 2004 with: 1 or more serious violations per area: 
2,935; 
Number of carriers in 2004 with: 2 or more serious violations per area: 
177; 
Number of carriers in 2005 with: 1 or more serious violations per area: 
3,004; 
Number of carriers in 2005 with: 2 or more serious violations per area: 
158; 
Number of carriers in 2006 with: 1 or more serious violations per area: 
3,348; 
Number of carriers in 2006 with: 2 or more serious violations per area: 
225. 

Number of regulatory areas with serious violations: 3 or more; 
Number of carriers in 2004 with: 1 or more serious violations per area: 
1,372; 
Number of carriers in 2004 with: 2 or more serious violations per area: 
64; 
Number of carriers in 2005 with: 1 or more serious violations per area: 
1,430; 
Number of carriers in 2005 with: 2 or more serious violations per area: 
58; 
Number of carriers in 2006 with: 1 or more serious violations per area: 
1,529; 
Number of carriers in 2006 with: 2 or more serious violations per area: 
114. 

Number of regulatory areas with serious violations: 4 or more; 
Number of carriers in 2004 with: 1 or more serious violations per area: 
494; 
Number of carriers in 2004 with: 2 or more serious violations per area: 
16; 
Number of carriers in 2005 with: 1 or more serious violations per area: 
557; 
Number of carriers in 2005 with: 2 or more serious violations per area: 
25; 
Number of carriers in 2006 with: 1 or more serious violations per area: 
530; 
Number of carriers in 2006 with: 2 or more serious violations per area: 
38. 

Number of regulatory areas with serious violations: 5 or more; 
Number of carriers in 2004 with: 1 or more serious violations per area: 
83; 
Number of carriers in 2004 with: 2 or more serious violations per area: 
2; 
Number of carriers in 2005 with: 1 or more serious violations per area: 
115; 
Number of carriers in 2005 with: 2 or more serious violations per area: 
9; 
Number of carriers in 2006 with: 1 or more serious violations per area: 
115; 
Number of carriers in 2006 with: 2 or more serious violations per area: 
7. 

Source: GAO analysis of FMCSA data. 

[End of table] 

We also interpret the statutory language for the repeat requirement as 
calling for a "two strikes" rule as opposed to FMCSA's three strikes 
rule. FMCSA's interpretation imposes the maximum fine only after a 
carrier has twice previously committed a serious violation. The 
language of the statute does not allow FMCSA's interpretation; rather 
it requires FMCSA to assess the maximum allowable fine for each serious 
violation against a carrier that has previously committed the same 
serious violation.[Footnote 41] In addition, in 2006, the Department of 
Transportation Inspector General found that FMCSA's implementation of 
its three strikes rule had allowed many third strike violators to 
escape maximum fines.[Footnote 42] Specifically, of the 533 third 
strike violators of the hours of service or the drug and alcohol 
regulations between September 2000 and October 2004, 33 (6 percent) 
third strike violators were assessed the maximum fine. The Inspector 
General found that FMCSA did not consider many of these violators to be 
third strike violators because the agency, in keeping with its policy, 
did not count the carriers' violations as strikes unless a violation 
resulted in the assessment of a fine. FMCSA does not always notify 
carriers of serious violations without fines and, therefore, FMCSA 
believes that counting such violations as strikes would violate the due 
process rights of carriers. The Inspector General agreed and 
recommended that FMCSA assess a no-dollar-amount fine or use another 
appropriate mechanism to legally notify a motor carrier of the 
violation and the policy that future violations will result in the 
maximum fine amount. An FMCSA official said that the agency is 
developing a policy designed to address this recommendation and plans 
to consider the related recommendation in this report as it develops 
the policy. FMCSA plans to implement the policy by June 2008. 

In fiscal years 2004 through 2006, there were more than four times as 
many carriers with a serious violation that constituted a second strike 
than there were carriers with a third strike. (See table 8.) For 
example, in fiscal year 2006, 1,320 carriers had a serious violation 
that constituted a second strike, whereas 280 carriers had a third 
strike.[Footnote 43] 

Table 8: Number of Motor Carriers That Would Have Been Subject to 
Maximum Fines under Two Strikes and Three Strikes Repeat Violator 
Policies, Fiscal Years 2004 through 2006: 

Policy: Two strikes; 
2004: 1,251; 
2005: 1,292; 
2006: 1,320; 
Total: 3,863. 

Policy: Three strikes[A]; 
2004: 269; 
2005: 284; 
2006: 280; 
Total: 833. 

Source: GAO analysis of FMCSA data. 

[End of table] 

AFMCSA's policy currently assesses the maximum fine for three 
violations in the same regulatory area. 

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

Conclusions: 

FMCSA's policy for prioritizing carriers for compliance reviews based 
on their SafeStat scores furthers motor carrier safety because it 
targets many carriers that pose high crash risks and thus has value for 
reducing both the number and severity of motor carrier crashes. 
However, the policy does not always target the carriers that have the 
highest crash risks. Modifications to the policy that we identified 
could improve FMCSA's targeting of high-risk carriers, thereby leading 
to compliance reviews that would have a greater potential to avoid 
crashes and their associated injuries and fatalities. Our June 2007 
report found that a regression model approach would better identify 
carriers that pose high crash risks than does SafeStat, enabling FMCSA 
to better target its resources. We recommended in that report that 
FMCSA implement such an approach. However, if FMCSA does not implement 
this recommendation, the analysis presented in this report suggests an 
alternative approach that would also better target carriers that pose 
high crash risks. This approach would give high priority for compliance 
reviews to carriers with very poor scores (such as the worst 5 percent) 
in the accident safety evaluation area. 

While FMCSA follows up with most carriers with serious safety 
violations, it has not established a time frame for carriers rated 
conditional to receive a follow-up compliance review. As a result, many 
carriers with conditional ratings can continue to operate for 2 years 
or more without a follow-up compliance review, posing safety risks to 
themselves and the public. 

Finally, we found that FMCSA assesses maximum fines against carriers 
that twice repeat a serious violation. However, because of FMCSA's 
interpretation of the statutory requirement to assess maximum fines 
against serious violators, many carriers that continue to accrue 
serious violations do not have the maximum fine assessed against them. 
Therefore, neither the statutory requirement nor FMCSA's enforcement is 
as effective as possible in deterring unsafe practices and, as a 
result, additional accidents could occur. 

Recommendations for Executive Action: 

In our June 2007 report on the effectiveness of SafeStat, we 
recommended that FMCSA use a regression model approach to identify 
carriers that pose high crash risks rather than its expert judgment 
approach. Should the Secretary of Transportation decide not to 
implement that recommendation, we recommend that the Secretary of 
Transportation direct the FMCSA Administrator to take the following 
action: 

* to improve FMCSA's targeting of carriers that pose high crash risks, 
modify FMCSA's policy for prioritizing compliance reviews so that 
carriers with very poor scores (such as the worst 5 percent) in the 
accident safety evaluation area will be selected for compliance 
reviews, regardless of their scores in the other areas. 

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

* to help ensure that carriers rated conditional make safety 
improvements in a timely manner, establish a reasonable time frame 
within which FMCSA should conduct follow-up compliance reviews on such 
carriers and: 

* to meet the Motor Carrier Safety Improvement Act's requirement to 
assess maximum fines and improve the deterrent effect of these fines, 
revise FMCSA's related policy to include (1) a definition for a pattern 
of violations that is distinct from the repetition of the same or 
related violations and (2) a two strikes rule rather than a three 
strikes rule. 

Agency Comments: 

We provided a draft of this report to the Department of Transportation 
for its review and comment. The department did not offer overall 
comments on the draft report. It said that it would assess the efficacy 
of the first recommendation, but it did not comment on the other 
recommendations. It offered several technical comments, which we 
incorporated where appropriate. 

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

If you have any questions about this report, please contact me at (202) 
512-2834 or flemings@gao.gov. Contact points for our Offices of 
Congressional Relations and Public Affairs may be found on the last 
page of this report. Staff who made key contributions to this report 
are listed in appendix V. 

Sincerely yours, 

Signed by: 

Susan A. Fleming: 
Director: 
Physical Infrastructure Issues: 

[End of section] 

Appendix I: Other Assessments of SafeStat's Ability to Identify High- 
Risk Motor Carriers: 

Several studies by the Volpe National Transportation Systems Center 
(Volpe), the Department of Transportation Office of Inspector General, 
the Oak Ridge National Laboratory (Oak Ridge), and others have assessed 
the predictive capability of the Motor Carrier Safety Status 
Measurement System (SafeStat) model and the data used by that model. In 
general, studies that assessed the predictive power of SafeStat offered 
suggestions to increase that power, and studies that assessed data 
quality found weaknesses in the data that the Federal Motor Carrier 
Safety Administration (FMCSA) relies upon. 

Assessments of SafeStat's Predictive Capability: 

The studies we reviewed compared SafeStat with random selection to 
determine which does a better job of selecting carriers that pose high 
crash risks and assessed whether statistical approaches could improve 
that selection and whether carrier financial positions or driver 
convictions are associated with crash risk. 

Predictive Capability of SafeStat Compared with Random Selection: 

In its 2004 and 1998 studies of the SafeStat model,[Footnote 44] Volpe 
analyzed retrospective data to determine how many crashes carriers in 
SafeStat categories A and B experienced over the following 18 months. 
The 2004 study used the carrier rankings from an application of the 
SafeStat model on March 21, 2001. Volpe then compared the SafeStat 
carrier safety ratings with state-reported data on crashes that 
occurred between March 22, 2001, and September 21, 2002, to assess the 
model's performance. For each carrier, Volpe calculated a total number 
of crashes, weighted for time and severity, and then estimated a rate 
per 1,000 vehicles for comparing carriers in SafeStat categories A and 
B with the carriers in other SafeStat categories. The 1998 Volpe study 
used a similar methodology. Each study used a constrained subset of 
carriers rather than the full list contained in the Motor Carrier 
Management Information System (MCMIS).[Footnote 45] Both studies found 
that the crash rate for the carriers in SafeStat categories A and B was 
substantially higher than for the other carriers during the 18 months 
after the particular SafeStat run. On the basis of this finding, Volpe 
concluded that the SafeStat model worked. 

In response to a recommendation by the Department of Transportation 
Office of Inspector General,[Footnote 46] FMCSA contracted with Oak 
Ridge to independently review the SafeStat model. Oak Ridge assessed 
the SafeStat model's performance and used the same data set (for March 
21, 2001) provided by Volpe, which Volpe had used in its 2004 
evaluation. Perhaps not surprisingly, Oak Ridge obtained a similar 
result for the weighted crash rate of carriers in SafeStat categories A 
and B over the 18-month follow-up period. Like the Volpe studies, the 
Oak Ridge study was constrained because it was based on a limited data 
set rather than the entire MCMIS data set. 

Application of Regression Models to Safety Data: 

While SafeStat does better than simple random selection in identifying 
carriers that pose high crash risks, other methods can also be used. 
Oak Ridge extended Volpe's analysis by applying regression models to 
identify carriers that pose high crash risks. Specifically, Oak Ridge 
applied a Poisson regression model and a negative binomial model using 
the safety evaluation area scores as independent variables to a 
weighted count of crashes that occurred in the 30 months before March 
21, 2001.[Footnote 47] 

In addition, Oak Ridge applied the empirical Bayes method to the 
negative binomial regression model and assessed the variability of 
carrier crash counts by estimating confidence intervals.[Footnote 48] 
Oak Ridge found that the negative binomial model worked well at 
identifying carriers that pose high crash risks. However, the data set 
Oak Ridge had to use did not include any carriers with one reported 
crash in the 30 months before March 21, 2001. Because the data included 
only carriers with zero or two or more reported crashes, the 
distribution of crashes was truncated. 

Since the Oak Ridge regression model analysis did not cover carriers 
with safety evaluation area data and one reported crash, the findings 
from the study are limited in their generalizeability. However, other 
modeling analyses of crashes at intersections and on road segments have 
also found that the negative binomial regression model works 
well.[Footnote 49] In addition, our analysis, using a more recent and 
more comprehensive data set, supports the finding that the negative 
binomial regression model performs better than the SafeStat model. 

The studies carried out by other authors advocate the use of the 
empirical Bayes method in conjunction with a negative binomial 
regression model to estimate crash risk. Oak Ridge also applied this 
model to identify motor carriers that pose high crash risks. We applied 
this method to the 2004 SafeStat data and found that the empirical 
Bayes method best identified the carriers with the largest number of 
crashes in the 18 months after June 25, 2004. However, the crash rate 
per 1,000 vehicles was much lower than that for carriers in SafeStat 
categories A and B. We analyzed this result further and found that 
although the empirical Bayes method best identifies future crashes, it 
is not as effective as the SafeStat model or the negative binomial 
regression model in identifying carriers with the highest future crash 
rates. The carriers identified with the empirical Bayes method were 
invariably the largest carriers. This result is not especially useful 
from a regulatory perspective. Companies operating a large number of 
vehicles often have more crashes over a period of time than smaller 
companies. However, this does not mean that the larger company is 
necessarily violating more safety regulations or is less safe than the 
smaller company. For this reason, we do not advocate the use of the 
empirical Bayes method in conjunction with the negative binomial 
regression model as long as the method used to calculate the safety 
evaluation area values remains unchanged. If changes are made in how 
carriers are rated for safety, this method may in the future offer more 
promise than the negative binomial regression model alone. 

[End of section] 

Appendix II: FMCSA's Crash Data Used to Compare Methods for Identifying 
High-Risk Carriers: 

The quality of crash data is a long-standing problem that hinders 
FMCSA's ability to accurately identify carriers that pose high crash 
risks.[Footnote 50] Despite the problems of late-reported crashes and 
incomplete and inaccurate data on crashes, the data were of sufficient 
quality for our use, which was to assess whether different approaches 
to categorizing carriers could lead to better identification of 
carriers that subsequently have high crash rates. Our reasoning is 
based on our use of the same data set to compare the crash risk of 
carriers in SafeStat categories A or B and of carriers that score among 
the worst 25, 10, or 5 percent in an individual safety evaluation area. 
Limitations in the data would apply equally to both results. FMCSA has 
undertaken a number of efforts to improve crash data quality. 

Late Reporting Had a Small Effect on SafeStat's Ability to Identify 
High-risk Carriers: 

FMCSA's guidance requires states to report all crashes to MCMIS within 
90 days of their occurrence. Late reporting can cause SafeStat to miss 
some of the carriers that should have received a SafeStat score. 
Moreover, since SafeStat scoring involves a relative ranking of 
carriers, a carrier may receive a SafeStat score and have to undergo a 
compliance review because crash data for a higher risk carrier were 
reported late and not included in the calculation. 

Late reporting affected SafeStat's ability to identify all high-risk 
carriers to a small degree--missing about 6 percent---for the period 
that we studied. Late reporting of crashes by states also affected the 
safety rankings of more than 600 carriers, both positively and 
negatively. When SafeStat analyzed the 2004 data, which did not include 
the late-reported crashes, it identified 4,989 motor carriers as 
highest risk, meaning they received a category A or B ranking. With the 
addition of late-reported crashes, 481 carriers moved into the highest 
risk category, and 182 carriers dropped out of the highest risk 
category, resulting in a net increase of 299 carriers (6 percent) in 
the highest risk category. After the late-reported crashes were added, 
481 carriers that originally received a category C, D, E, F, or G 
SafeStat rating received an A or B rating. These carriers would not 
originally have been given a high priority for a compliance review 
because the SafeStat calculation did not take into account all of their 
crashes. On the other hand, a number of carriers would have fared 
better if the late-reported crashes had been included in their score. 
Specifically, 182 carriers--or fewer than 4 percent of those ranked-- 
fell from the A or B category into the C, D, E, F, or G category once 
the late-reported crashes were included.[Footnote 51] These carriers 
would have avoided a compliance review if all crashes had been reported 
on time. Overall, however, the vast majority of carriers (96 percent) 
were not negatively affected by late reporting. 

The timeliness of crash reporting seems to be improving. The median 
number of days it took states to report crashes to MCMIS dropped from 
225 days in calendar year 2001 to 57 days in 2005 (the latest data 
available at the time of our analysis).[Footnote 52] In addition, the 
percentage of crashes reported by states within 90 days of occurrence 
has jumped from 32 percent in fiscal year 2000 to 89 percent in fiscal 
year 2006. (See fig. 3.) 

Figure 3: Percentage of Crashes Submitted to MCMIS within 90 Days of 
Occurrence, Fiscal Years 2000 through 2006: 

[See PDF for image] 

Source: GAO analysis of FMCSA data. 

[End of figure] 

Incomplete Data from States Limit SafeStat's Identification of All 
Carriers That Pose High Crash Risks: 

FMCSA uses a motor carrier identification number, which is unique to 
each carrier, as the primary means of linking inspections, crashes, and 
compliance reviews to motor carriers. Approximately 184,000 (75 
percent) of the 244,000 crashes reported to MCMIS between December 2001 
and June 2004 involved interstate carriers. Of these 184,000 crashes, 
nearly 24,000 (13 percent) were missing this identification number. As 
a result, FMCSA could not match these crashes to motor carriers or use 
data from them in SafeStat. In addition, the carrier identification 
number could not be matched to one listed in MCMIS for 15,000 (8 
percent) other crashes that involved interstate carriers. Missing data 
or data that cannot be matched to carriers for nearly one quarter of 
the crashes for the period of our review potentially have a large 
impact on a motor carrier's SafeStat score because SafeStat treats 
crashes as the most important source of information for assessing motor 
carrier crash risk. Theoretically, information exists to match crash 
records to motor carriers by other means, but such matching would 
require too much manual work to be practicable. 

We were not able to quantify the actual effect of the missing data and 
the data that could not be matched for MCMIS overall. To do so, we 
would have had to gather crash records at the state level--an effort 
that was impractical. For the same reason, we cannot quantify the 
effects of FMCSA's efforts to improve the completeness of the data 
(discussed later). However, the University of Michigan Transportation 
Research Institute issued a series of reports analyzing the 
completeness of the data submitted to MCMIS by the states.[Footnote 53] 
One of the goals of the research was to determine the states' crash 
reporting rates. Reporting rates varied greatly among the 14 states 
studied, ranging from 9 percent in New Mexico in 2003 to 83 percent in 
Missouri in 2005. It is not possible to draw wide-scale conclusions 
about whether states' reporting rates are improving over time because 
only 2 of the states--Missouri and Ohio--were studied in multiple 
years. However, the reporting rates of these 2 states did improve. 
Missouri experienced a large improvement in its reporting rate, with 61 
percent of eligible crashes reported in 2001, and 83 percent reported 
in 2005. Ohio's improvement was more modest, increasing from 39 percent 
in 2000 to 43 percent in 2005. 

The University of Michigan Transportation Research Institute's reports 
also identified a number of factors that may affect states' reporting 
rates. One of the main factors affecting reporting rates is the 
reporting officer's understanding of crash reporting requirements. The 
studies note that reporting rates are generally lower for less serious 
crashes and for crashes involving smaller vehicles, which may indicate 
that there is some confusion about which crashes are reportable. Some 
states, such as Missouri, aid the officer by explicitly listing 
reporting criteria on the police accident reporting form, while other 
states, such as Washington, leave it up to the officer to complete 
certain sections of the form if the crash is reportable, but the form 
includes no guidance on reportable crashes. Other states, such as North 
Carolina and Illinois, have taken this task out of officers' hands and 
include all reporting elements on the police accident reporting form. 
Reportable crashes are then selected centrally by the state, and the 
required data are transmitted to MCMIS. 

Inaccurate Data Potentially Limit SafeStat's Ability to Identify 
Carriers That Pose High Crash Risks: 

Inaccurate data, such as information on nonqualifying crashes reported 
to FMCSA, potentially have a large impact on a motor carrier's SafeStat 
score because SafeStat treats crashes as the most important source of 
information for assessing motor carrier crash risk. The University of 
Michigan Transportation Research Institute's reports on state crash 
reporting show that, among the 14 states studied, incorrect reporting 
of crash data is widespread. This inaccuracy limits SafeStat's ability 
to identify carriers that pose high crash risks. In the most recent 
reports, the researchers found that, in 2005, Ohio incorrectly reported 
1,094 (22 percent) of the 5,037 cases it reported, and Louisiana 
incorrectly reported 137 (5 percent) of the 2,699 cases it reported. In 
Ohio, most of the incorrectly reported crashes did not qualify because 
they did not meet the crash severity threshold. In contrast, most of 
the incorrectly reported crashes in Louisiana did not qualify because 
they did not involve vehicles eligible for reporting. Other states 
studied by the institute had similar problems with reporting crashes 
that did not meet the criteria for reporting to MCMIS. The addition of 
these nonqualifying crashes could cause some carriers to exceed the 
minimum number of crashes required to receive a SafeStat rating and 
result in SafeStat's mistakenly identifying carriers as posing high 
crash risks. Because each report focuses on reporting in one state in a 
particular year, it is not possible to identify the number of cases 
that have been incorrectly reported nationwide and, therefore, it is 
not possible to determine the impact of inaccurate reporting on 
SafeStat's calculations. 

We also found examples of crashes that are reported to MCMIS but cannot 
be used by SafeStat because of data errors. Specifically, we found that 
the carrier's identification number cannot be matched to an 
identification number in MCMIS in 8 percent of reported crashes. FMCSA 
cannot link these crashes to specific carriers without an accurate 
identification number and, therefore, cannot use these crashes in the 
SafeStat model to identify carriers that pose high crash risks. 

As noted in the University of Michigan Transportation Research 
Institute's reports, states may be unintentionally submitting incorrect 
data to MCMIS because of difficulties in determining whether a crash 
meets the reporting criteria. For example, in Missouri, pickups are 
systematically excluded from MCMIS crash reporting, which may cause the 
state to miss some reportable crashes. This may occur because, in 
recent years, a number of pickups have been equipped with rear axles 
that may increase their weight above the reporting threshold and make 
crashes involving them eligible for reporting. There is no way for the 
state to determine which crashes involving pickups qualify for 
reporting without examining the characteristics of each vehicle. In 
this case, the number of omissions is likely to be relatively small, 
but this example demonstrates the difficulty states may face when 
identifying reportable crashes. 

In addition, in some states, the information contained in the police 
accident report may not be sufficient for the state to determine if a 
crash meets the accident severity threshold. It is generally 
straightforward to determine whether a fatality occurred as a result of 
a crash, but it may be difficult to determine whether an injured person 
was transported for medical attention or a vehicle was towed because of 
disabling damage. In some states, such as Illinois and New Jersey, an 
officer can indicate on the form if a vehicle was towed by checking a 
box, but there is no way to identify whether the reason for towing was 
disabling damage. It is likely that such uncertainty results in 
overreporting because some vehicles may be towed for other reasons. 

FMCSA Has Undertaken Efforts to Improve Crash Data Quality: 

FMCSA has taken steps to try and improve the quality of crash data 
reporting. As we noted in November 2005, FMCSA has undertaken two major 
efforts to help states improve the quality of crash data. One program, 
the Safety Data Improvement Program, has provided funding to states to 
implement or expand activities designed to improve the completeness, 
timeliness, accuracy, and consistency of their data. FMCSA has also 
used a data quality rating system to rate and display ratings for the 
quality of states' crash and inspection data. Because these ratings are 
public, this system creates an incentive for states to improve their 
data quality. 

To further improve these programs, FMCSA has awarded additional grants 
to several states and implemented our recommendations to (1) establish 
specific guidelines for assessing states' requests for funding to 
support data improvement in order to better assess and prioritize the 
requests and (2) increase the usefulness of its state data quality map 
as a tool for monitoring and measuring commercial motor vehicle crash 
data by ensuring that the map adequately reflects the condition of the 
states' commercial motor vehicle crash data. 

In February 2004, FMCSA implemented Data Q's, an online system that 
allows for challenging and correcting erroneous crash or inspection 
data. Users of this system include motor carriers, the general public, 
state officials, and FMCSA. In addition, in response to a recent 
recommendation by the Department of Transportation Inspector General, 
FMCSA is planning to conduct a number of evaluations of the 
effectiveness of a training course on crash data collection that it 
will be providing to states by September 2008. 

While the quality of crash data is sufficient for use in assessing 
whether different approaches to categorizing carriers could lead to 
better identification of carriers that subsequently have high crash 
rates and has started to improve, commercial motor vehicle crash data 
continue to have some problems with timeliness, completeness, and 
accuracy. These problems have been well-documented in several studies, 
and FMCSA is taking steps to address the problems through studies of 
each state's crash reporting system and grants to states to fund 
improvements. As a result, we are not making any recommendations in 
this area. 

[End of section] 

Appendix III: Review of Studies on Predictors of Motor Carrier and 
Driver Crash Risk: 

Several studies have identified relationships between certain 
characteristics of motor carriers and drivers and their crash risks. 
Theses characteristics include carrier financial performance, carrier 
size, driver pay, and driver age. 

Relationship of Motor Carrier Characteristics and Crash Risk: 

The studies we reviewed assessed whether financial performance or other 
characteristics of carriers, such as size, are associated with crash 
risk. 

Carrier Financial Performance: 

Our 1991 study developed a model that linked changes in economic 
conditions to declining safety performance in the trucking industry. 
The study hypothesized that a decline in economic performance among 
motor carriers leads to a decline in safety performance in one or more 
of the following ways: (1) a lowering of the average quality of driver 
performance; (2) downward wage pressures encouraging driver 
noncompliance with safety regulations; (3) less management emphasis on 
safety practices; (4) deferred truck maintenance and replacement; and/ 
or (5) the introduction of larger, heavier, multitrailer trucks. Using 
data on 537 carriers drawn from the Department of Transportation and 
the Interstate Commerce Commission, we found that seven financial 
ratios show promise as predictors of truck firms' safety. For five of 
the seven financial variables we examined, firms in the weakest 
financial position had the highest subsequent accident rates. For 
example, weakness in any of three measures of profitability--return on 
equity, operating ratio, and net profit margin--was associated with 
subsequent safety problems as measured by accident rates. 

On behalf of FMCSA, a study carried out by Corsi, Barnard, and Gibney 
in 2002 examined how data on carriers' financial performance correlate 
with a carrier's safety rating following a compliance review. The 
authors selected motor carriers from MCMIS in December 2000 with 
complete data for the accident, driver, vehicle, and safety management 
safety evaluation areas. Using these data, the authors then matched a 
total of 700 carriers to company financial statements in the annual 
report database of the American Trucking Associations. The authors 
found that carriers that received satisfactory ratings following a 
compliance review performed better on two financial measures--operating 
ratio and return on assets--than carriers that received lower ratings. 

Two practical considerations limit the applicability of the findings 
from these two studies to SafeStat. First, the studies' samples of 537 
and 700 carriers, respectively, are not representative of the motor 
carriers that FMCSA oversees. For example, our sample included only the 
largest for-hire interstate carriers because these were the only 
carriers that were required to report financial information to the 
federal government. The carriers selected for the Corsi and others' 
study were also not representative because a very small percentage of 
the carriers evaluated by the SafeStat model in June 2004 had scores 
for all four safety evaluation areas. About 2 percent had a score for 
the the safety management safety evaluation area, and of these, not all 
had complete data for the other three safety evaluation areas. Second, 
FMCSA does not receive annual financial statements from carriers and, 
according to an FMCSA official, it is unlikely that the agency could 
obtain the authority it would need to require financial statements from 
all carriers. In addition, because the relationships identified by our 
study are based on data and economic conditions that are almost 20 
years old, the relationships would need to be reanalyzed within current 
conditions to determine whether they still exist. As part of its 
Comprehensive Safety Analysis 2010 reform initiative, discussed earlier 
in this report, FMCSA decided not to use financial data to help assess 
the safety risk of firms because of the limited availability of these 
data. 

Other Carrier Characteristics: 

A 1994 study by Moses and Savage found that crash rates decline as firm 
size increases; the largest 10 percent of firms have an accident rate 
that is one-third the rate of the smallest 10 percent of firms. Our 
1991 study found that the smallest carriers, as a group, had an 
accident rate that exceeded the rate for all firms by 20 percent. The 
study by Moses and Savage also found that (1) private fleets that serve 
the needs of their parent companies, such as manufacturers and 
retailers, have accident rates that are about 20 percent lower than the 
rates of carriers that offer for-hire trucking; (2) carriers of 
hazardous materials have accident rates that are 22 percent higher than 
the rates of carriers that do not transport these goods; and (3) 
general freight carriers have accident rates that are 10 percent higher 
than the rates of other freight carriers. We believe that Moses and 
Savage's findings are reasonable given their study's design, data, and 
methodology, but because the findings are based on data and economic 
conditions that are about 15 to 20 years old, current data would need 
to be reanalyzed within current conditions to determine whether the 
findings are still valid. As mentioned above, our study shares this 
limitation and is further limited by an unrepresentative sample of 
motor carriers. An FMCSA official told us that the agency would not 
want to rely directly on data on the size of the carrier to assess 
safety risk because the agency believes that its data on indicators of 
carrier size, such as revenue, number of drivers, and number of power 
units, are not of sufficient quality. Similarly, the agency would not 
want to distinguish between private and for-hire carriers or between 
carriers that carry different types of freight because it does not 
believe that its data are sufficiently reliable. 

Relationship of Driver Characteristics and Crash Risk: 

The studies we reviewed assessed whether driver characteristics-- 
including convictions for traffic violations, age and experience, pay, 
or frequency of job changes--are associated with crash risk. 

Driver Convictions for Traffic Violations: 

A series of studies by Lantz and others examined the effect of 
incorporating conviction data from the state-run commercial driver 
license data system into the calculation of carriers' safety management 
safety evaluation area scores. The studies found that the resulting 
driver conviction measure is weakly correlated with the crash-per- 
vehicle rate. However, the studies did not calculate new safety 
management safety evaluation area scores with the proposed driver 
conviction measure and then use the updated measure to estimate new 
SafeStat scores for carriers. FMCSA uses data on driver convictions to 
help target its roadside inspections, and it is considering using such 
data in the tool it is developing to replace SafeStat as part of its 
Comprehensive Safety Analysis 2010 reform initiative. 

Driver Age and Experience: 

Campbell's 1991 study found that the risk of a fatal crash is 
significantly higher for younger truck drivers than for older drivers. 
Campbell used data from surveys of fatal crashes and large truck travel 
to calculate fatal involvement rates per mile driven by driver age. 
Overall, fatal involvement rates remained high through age 26. The 
fatal crash rates for drivers under 19 years of age were four times 
higher than the rate for all drivers, and the rates for drivers aged 19 
to 20 years were six times higher. Our 1991 study found that younger, 
less experienced drivers posed greater-than-average accident risks. In 
particular, compared with drivers 40 to 49 years of age, drivers 21 to 
39 years of age have 28 percent greater odds of accident involvement. 
Compared with those for drivers over 50 years of age, the odds of the 
youngest group of drivers having an accident are about 60 percent 
greater. The differences in accident risks between drivers with 0 to 13 
years of experience, 14 to 20 years of experience, and 21 or more years 
of experience followed a very similar pattern. Although Campbell's 
study provides only limited information about the quality of the data 
it used, we believe that its findings are reasonable given the study's 
design and methodology, which relied on multiple kinds of analyses to 
substantiate a higher risk for younger drivers of large trucks. We 
believe that our 1991 findings are reasonable given our study's design, 
data, and methodology. An FMCSA official told us that, at this time, 
the agency would not be able to use driver age in SafeStat or in a 
similar model because the agency does not have access to data on all 
drivers. FMCSA said that it is exploring the possibility of gaining 
broader access to data on drivers, which are maintained by the states, 
so that the agency can use the data to help assess the safety of 
drivers as part of its Comprehensive Safety Analysis 2010 reform 
initiative. 

Driver Pay: 

Belzer and others' 2002 study found that drivers with lower pay had 
higher crash rates. Because economic theory predicts that low pay 
levels are associated with poorer performing workers, the study 
hypothesized that low pay levels for drivers are associated with unsafe 
driving. The study found that for every 10 percent more in average 
driver compensation (mileage rate, unpaid time, anticipated annual 
raise, safety bonus, health insurance, and life insurance), the 
carriers experienced 9.2 percent fewer crashes. We believe that this 
finding is reasonable given the study's design, data, and methodology. 
An FMCSA official told us that the agency could not use data on driver 
pay in SafeStat or in a similar model because such data are available 
only from studies or surveys that do not cover the full population of 
drivers. 

Frequency of Job Changes: 

Staplin and others' 2003 study for FMCSA found that drivers that 
average three or more jobs with different carriers each year have crash 
rates that are more than twice as high as drivers that average fewer 
job changes. Although the study authors acknowledge several limitations 
in the data used in study, we believe that the data and the analysis 
approach were sufficiently reliable to support the study's finding of a 
relationship between the number of jobs and the number of crashes. An 
FMCSA official told us that, as for data on driver pay, the agency 
could not use data on the frequency of job changes in SafeStat or in a 
similar model because such data are available only from studies or 
surveys that do not cover the full population of drivers. 

[End of section] 

Appendix IV: Scope and Methodology: 

To determine the extent to which FMCSA's policy for prioritizing 
compliance reviews targets carriers that subsequently have high crash 
rates, we analyzed data from FMCSA's MCMIS on the June 2004 SafeStat 
assessment of carriers and on the assessed carriers' crashes in the 18 
months following the SafeStat assessment. We selected June 2004 because 
this date enabled us to examine MCMIS data on actual crashes that 
occurred in the 18-month period from July 2004 through December 2005. 
We defined various groups of carriers for analysis, such as those in 
each SafeStat category, those to which FMCSA gave high priority (i.e., 
those in categories A or B), and those in the worst 5 or 10 percent of 
carriers in a particular safety evaluation area without being in the 
worst 25 percent of carriers in any other area. We then calculated the 
aggregate crash rate in the 18 months following the SafeStat assessment 
for each of these groups by dividing the total crashes experienced by 
all the carriers in a group during that time period by the total number 
of vehicles operated by those carriers, as reported on their motor 
carrier census form. We then compared crash rates among the various 
groups to determine whether there were any groups with substantially 
higher aggregate crash rates than the carriers in SafeStat categories A 
or B. We also talked to FMCSA officials about how FMCSA developed 
SafeStat, their views on other evaluations of SafeStat, and FMCSA's 
plans to replace SafeStat with a new tool. 

In assessing how FMCSA ensures that its compliance reviews are 
completed thoroughly and consistently, we reviewed our report on 
internal control standards for the federal government. We identified 
key standards in the areas that we believe are critical to maintaining 
the thoroughness and consistency of compliance reviews, namely the 
recording and communication of policy to management and others, the 
clear documentation of processes, and the monitoring and reviewing of 
activities and findings. We assessed the extent to which FMCSA's 
management of its compliance reviews is consistent with these internal 
control standards by interviewing FMCSA and state managers and 
investigators. We interviewed investigators who conduct compliance 
reviews and their managers in FMCSA's headquarters office, as well as 
in 7 of FMCSA's 52 field division offices that work with states, two of 
its four regional service centers that support division offices, and 
three state offices that partner with 3 of the FMCSA division offices 
in which we did our work. We also interviewed two safety investigators 
in each of the same 7 division offices. The division offices and states 
that we reviewed--California, Georgia, Illinois, New York, Ohio, 
Pennsylvania, and Texas--received 30 percent of all the of the grant 
funds that FMCSA awarded to the states in fiscal year 2005 (the latest 
year for which data were available) through its primary grant program, 
the Motor Carrier Safety Assistance Program. Because we chose the seven 
states judgmentally (representing the largest grantees), we cannot 
project our findings nationwide.Reviewing a larger number of grantees 
would not have been practical because of resource constraints. 

We gathered information on the recording and communication of policy 
from discussions with FMCSA officials, documents, and system software, 
including the electronic operations manual. We obtained information 
about how FMCSA documents the findings of compliance reviews through 
discussions with FMCSA officials and reviews of FMCSA documents. We 
obtained information on how FMCSA monitors and reviews the performance 
of its compliance reviews through discussions with FMCSA officials and 
reviews of FMCSA documents, including the 2002 report of FMCSA's 
Compliance Review Work Group. The data assessments of the number of 
vehicles inspected during compliance reviews and the percentage of 
applicable areas of the regulations covered by compliance reviews since 
2001 were provided to us by FMCSA. 

In assessing the extent to which FMCSA follows up with carriers with 
serious violations, we reviewed regulations directing how FMCSA should 
follow up and track these violators and analyzed data to determine if 
FMCSA had met these policies. Particularly, we examined FMCSA policies 
and discussed with FMCSA officials the agency's policy to perform a 
follow-up compliance review on carriers in SafeStat categories A and B, 
its policy to place carriers rated unsatisfactory out of service, its 
policy to perform a follow-up compliance review on carriers with a 
conditional rating, and its reduction of its enforcement backlog. 
Additional analysis was performed--as of the end of each fiscal year 
from 2001 through 2006--using data from FMCSA's MCMIS to determine the 
total number of carriers with a conditional rating that had not 
received a follow-up compliance review. We also used MCMIS to determine 
how many carriers with a conditional rating received a follow-up 
compliance review and how soon after the original compliance review the 
second review occurred. 

To assess FMCSA's implementation of the statutory requirement to assess 
the maximum fine against any carrier with either a pattern of 
violations or previously committed violations, we compared FMCSA's 
policy with the language of the act and held discussions with FMCSA 
officials. In addition, we assessed the number of carriers that would 
have been assessed the maximum fine under differing definitions of a 
pattern of violations. We also reviewed the report of the Department of 
Transportation Inspector General on the implementation of the policy 
and documents pertaining to FMCSA's response to the Inspector General's 
report. 

In determining the reliability of FMCSA's data on compliance reviews, 
violations, and enforcement cases, we performed electronic testing for 
obvious errors in accuracy and completeness. As part of a recent 
evaluation of FMCSA's enforcement programs, we interviewed officials 
from FMCSA's data analysis office who are knowledgeable about the same 
data sources. We determined that the data were sufficiently reliable 
for the types of analysis we present in this report. 

To assess the extent to which the timeliness, completeness, and 
accuracy of MCMIS and state-reported crash data affect SafeStat's 
performance, we carried out a series of analyses with the MCMIS master 
crash file, and the MCMIS census file, as well as surveying the 
literature to assess other studies' findings on the quality of MCMIS 
data. To assess timeliness, we first measured how many days on average 
it was taking each state to report crashes to FMCSA by year for 
calendar years 2000 through 2005. We also recalculated SafeStat scores 
from June 25, 2004, to include crashes that had occurred more than 90 
days previously but had not yet been reported to FMCSA by that date. We 
compared the number and rankings of carriers from the original SafeStat 
results with those obtained with the addition of late-reported crashes. 
In addition, we reviewed the University of Michigan Transportation 
Research Institute's studies of state crash reporting to MCMIS to 
identify the impact of late reporting in individual states on MCMIS 
data quality. 

To assess completeness, we attempted to match all crash records in the 
MCMIS master crash file for crashes occurring between December 2001 and 
June 2004 to the list of motor carriers in the MCMIS census file. We 
used a variety of matching techniques to try and match the crash 
records without a carrier Department of Transportation number to 
carriers listed in the MCMIS census file. In addition, we reviewed the 
University of Michigan Transportation Research Institute's studies of 
state crash reporting to MCMIS to identify the impact of incomplete 
crash reporting in individual states on MCMIS data quality. 

To assess accuracy, we reviewed an audit by the Inspector General that 
tested the accuracy of electronic data by comparing records selected in 
the sample to source paper documents. In addition, we reviewed the 
University of Michigan Transportation Research Institute's studies of 
state crash reporting to MCMIS to identify the impact of incorrectly 
reported crashes in individual states on MCMIS data quality. 

We determined that the data reported to FMCSA for use in SafeStat-- 
while not as timely, complete, or accurate as they could be--were of 
sufficient quality for our use. Through our analyses, we found that the 
data identify many carriers that pose high crash risks and are, 
therefore, useful for the purposes of this report. 

To understand what other researchers have found about how well SafeStat 
identifies motor carriers that pose high crash risks, we identified 
studies through a general literature review and by asking stakeholders 
and study authors to identify high-quality studies. The studies 
included in our review were (1) the 2004 study of SafeStat done by Oak 
Ridge National Laboratory, (2) the SafeStat effectiveness studies done 
by the Department of Transportation Inspector General and Volpe 
Institute, (3) the University of Michigan Transportation Research 
Institute's studies of state crash reporting to FMCSA, and (4) the 2006 
audit by the Department of Transportation Inspector General of data for 
new entrant carriers. We assessed the methodology used in each study 
and identified which findings are supported by rigorous analysis. We 
accomplished this analysis by relying on information presented in the 
studies and, where possible, discussing the studies with the authors. 
When the studies' methodologies and analyses appeared reasonable, we 
used the findings from those studies in our analysis of SafeStat. We 
discussed with FMCSA and industry and safety stakeholders the SafeStat 
methodology issues and data quality issues raised by these studies. We 
also discussed the aptness of the respective methodological approaches 
with FMCSA. Finally, we reviewed FMCSA documentation on how SafeStat is 
constructed and assessments of SafeStat conducted by FMCSA. 

To identify studies on predictors of motor carrier and driver crash 
risk, we conducted a general literature review. We shared this 
preliminary list of studies with the members of the Transportation 
Research Board's Committee on Truck and Bus Safety and requested them 
to identify additional relevant studies. We selected those studies that 
assessed a relationship between one or more motor carrier or driver 
characteristics and crash risk. Based on information presented in the 
selected studies, we assessed the methodology used in each study and 
report only those findings that were based on sound methodology and 
analysis. 

[End of section] 

Appendix V: GAO Contact and Staff Acknowledgments: 

GAO Contact: 

Susan A. Fleming, (202) 512-2834, or flemings@gao.gov: 

Staff Acknowledgments: 

In addition to the individual named above, James Ratzenberger, 
Assistant Director; Carl Barden; Elizabeth Eisenstadt; David Goldstein; 
Ryan Gottschall; Laurie Hamilton; Eric Hudson; Bert Japikse; and 
Gregory Wilmoth made key contributions to this report. 

[End of section] 

Footnotes: 

[1] Large trucks are those with a gross vehicle weight greater than 
10,000 pounds. A bus is a motor vehicle that is used to carry more than 
eight passengers (including the driver). 

[2] According to FMCSA, this is the number of commercial motor carriers 
registered in its Motor Carrier Management Information System, as of 
February 2007. It includes an unidentified number of carriers that are 
registered, but are no longer in business. Furthermore, it includes 
only carriers classified as interstate carriers (about 696,000 
carriers) or intrastate carriers of hazardous materials (about 15,000 
carriers). For the sake of simplicity, we refer to these carriers 
collectively as "interstate carriers." 

[3] Within each safety evaluation area, this includes only those 
carriers for which FMCSA had sufficient data to calculate a value. 

[4] A conditional safety rating means a motor carrier, as a result of 
not having adequate safety management controls, has had serious 
violations of the safety regulations. 

[5] We use the term "fine" to refer to civil fines as opposed to 
criminal fines. 

[6] We use the term "serious violations" to refer to acute or critical 
violations. Acute violations are so severe that FMCSA will require 
immediate corrective actions by a motor carrier regardless of the 
overall safety status of the motor carrier. An example of an acute 
violation is a carrier failing to implement an alcohol or drug testing 
program for drivers. Critical violations are less severe than acute 
violations and most often point to gaps in carrier management or 
operational controls, such as not maintaining records of driver medical 
certificates. 

[7] GAO, Motor Carrier Safety: A Statistical Approach Will Better 
Identify Commercial Carriers That Pose High Crash Risks Than Does the 
Current Federal Approach, GAO-07-585 (Washington, D.C.: June 11, 2007). 
Our findings are summarized in the section of this report dealing with 
FMCSA's policy for prioritizing compliance reviews. 

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

[9] GAO, Internal Control: Standards for Internal Control in the 
Federal Government, GAO/AIMD-00-21.3.1 (Washington, D.C.: November 
1999). 

[10] We did not interview managers or investigators in three of the 
seven states because they do not conduct compliance reviews of 
interstate carriers, and we did not interview managers or investigators 
in one state because they did not respond to our attempts to contact 
them. 

[11] U.S. Department of Transportation Office of Inspector General, 
Significant Improvements in Motor Carrier Safety Program Since 1999 Act 
but Loopholes for Repeat Violators Need Closing, Report MH-2006-046 
(Washington, D.C.: Apr. 21, 2006). 

[12] We applied the SafeStat model to retrospective data. Because of 
changes to the MCMIS crash file over the past 2 years, our number does 
not correspond exactly to the number of carriers identified by FMCSA as 
high risk on June 25, 2004. Had all crash data been reported within 90 
days of when the crashes occurred, 182 of the carriers identified by 
SafeStat as highest risk would have been excluded (because other 
carriers had higher crash risks), and 481 carriers that were not 
originally designated as posing high crash risks would have scored high 
enough to be considered high risk, resulting in a net addition of 299 
carriers. 

[13] FMCSA partners with each of the 50 states, the District of 
Columbia, and the U.S. territories of American Samoa, Guam, the 
Northern Marianas, Puerto Rico, and the Virgin Islands. 

[14] Except for carriers of hazardous materials, FMCSA does not have 
the authority to prohibit motor carriers from operating intrastate. 

[15] These eight definitions were chosen to illustrate the effect of 
different potential definitions of pattern. 

[16] This figure is from 2002, the most recent year for which data are 
available. 

[17] We found that SafeStat is about twice as effective in identifying 
these high-risk carriers than is randomly selecting them for compliance 
reviews. See GAO-07-585. 

[18] We are defining "crash risk" as the number of crashes for the 
carrier per 1,000 vehicles in the 18 months following the SafeStat 
categorization. By "aggregate" crash risk, we mean the total number of 
crashes for all carriers in the group per 1,000 vehicles in the 18 
months following the SafeStat categorization. 

[19] To give a sense of FMCSA's and the states' compliance review 
workload, in fiscal year 2006, FMCSA and the states conducted 15,182 
compliance reviews; about half of these were on carriers that were in 
SafeStat categories A or B. 

[20] GAO-07-585. 

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

[22] These alternatives are for use as examples only. FMCSA could 
choose other cut points, such as carriers in the worst 10, 15, or 20 
percent of the accident evaluation area. Our analyses show that these 
other alternatives provided superior results to the current SafeStat 
approach. 

[23] Based on results from its 2006 study of the causes of large truck 
crashes, which indicated that driver behavior rather than vehicle 
condition was the primary reason for most crashes, FMCSA also plans to 
develop a tool to assess the safety status of individual drivers, along 
with tools for dealing with unsafe drivers. 

[24] See GAO/AIMD-00-21.3.1. In assessing the extent to which FMCSA's 
management of its compliance reviews is consistent with our internal 
controls, we were not able to verify the statements made by FMCSA and 
state officials and investigators about their performance and 
management of compliance reviews because doing so was not practicable 
given our time and resource constraints. 

[25] The required number of inspections was based on the number of 
vehicles operated by the carrier. 

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

[27] FMCSA may allow a carrier with a proposed rating of unsatisfactory 
(unless the carrier is transporting passengers or hazardous materials) 
to continue to operate in interstate commerce for up to 60 days beyond 
the 60 days specified in the proposed rating if FMCSA determines that 
the carrier is making a good faith effort to improve its safety. For 
carriers of passengers or hazardous materials, FMCSA may extend by up 
to 10 days the 45-day period before which the proposed safety rating 
becomes final, but it may not extend the 45-day period before which 
these carriers are to be placed out of service. 

[28] FMCSA's policy calls for the agency to revoke the operating 
authority of any carrier that does not have the minimum required amount 
of insurance coverage; the minimum amount depends on whether the 
carrier is for-hire or private, whether it transports commodities or 
passengers, and what type of commodity or number of passengers is 
transported. Operating without the minimum required amount of insurance 
coverage is a serious violation of the safety regulations. 

[29] FMCSA also aims to conduct follow-up compliance reviews of 
carriers rated unsatisfactory (1) that request a follow-up review or 
(2) that received their ratings before November 20, 2000, when FMCSA's 
regulation requiring the agency to place carriers rated unsatisfactory 
out of service became effective. 

[30] FMCSA's goal for follow-up reviews includes only those follow-up 
reviews conducted by FMCSA. An FMCSA official told us that the agency 
chose not to include reviews conducted by the states as part of the 
goal because FMCSA receives an appropriation that covers its follow-up 
reviews. However, follow-on compliance reviews conducted by states are 
funded through a separate appropriation, the Motor Carrier Safety 
Assistance Program. FMCSA could choose to have states establish goals 
when applying for these funds. 

[31] The Safety Board's most wanted list, which is drawn up from issued 
safety recommendations, is intended to emphasize the transportation 
safety issues the Safety Board deems most critical. 

[32] An FMCSA official told us that the agency believes that using 
MCMIS data results in an overestimate of the number of carriers that 
were required to receive, but did not receive, a compliance review, 
primarily because the agency has indications that some carriers listed 
as active in MCMIS are actually inactive. The official said that 
FMCSA's eastern service center examined the cases of 95 of the 162 
carriers that MCMIS indicated did not receive a compliance review even 
though one was required and found that 39 of them did not require a 
compliance review, and 7 actually did receive a compliance review. 

[33] The first group of carriers to be affected by this policy was the 
2,220 carriers in SafeStat categories A or B in both July and August 
2006 that did not receive a compliance review in the previous 12 months 
(another 2,887 carriers that were in SafeStat categories A or B in both 
July and August 2006 did receive a compliance review in the previous 12 
months). 

[34] For the carriers that have received a prior compliance review, 
FMCSA would be able to extend the deadline to 12 months if it has 
applied an alternative intervention, such as a consent agreement. A 
consent agreement is an agreement between FMCSA and a carrier that can 
lower the amount of an assessed fine in exchange for corrective action 
and additional safety improvements by the carrier. 

[35] We defined the backlog as consisting of enforcement cases that had 
been open for 6 months or more to be consistent with our and the 
Inspector General's earlier work on the backlog. See GAO, Large Truck 
Safety: Federal Enforcement Efforts Have Been Stronger Since 2000, but 
Oversight of State Grants Needs Improvement, GAO-06-156 (Washington, 
D.C.: Dec.15, 2005) and U.S. Department of Transportation Office of 
Inspector General, Motor Carrier Safety Program, Federal Highway 
Administration, Report TR-1999-091 (Washington, D.C.: Apr. 26, 1999).We 
did not compare how FMCSA closed the cases that were and were not 
backlogged because doing so would have required too many resources. 

[36] Motor Carrier Safety Improvement Act of 1999, Pub. L. No. 106-159, 
§ 222(b)(2), 113 Stat. 1748, 1769 (49 U.S.C.A. § 521 Note). 

[37] See statement of Congressman Oberstar, then ranking member of the 
Committee on Transportation and Infrastructure, explaining, along with 
then-Chairman Shuster, the Motor Carrier Safety Improvement Act of 
1999, 145 Cong. Rec. H12868-12870 (Daily ed. Nov. 9, 1999). After 
observing that prior federal efforts at motor carrier oversight had 
proved to have major deficiencies, he stated: 

"The bill makes numerous programmatic changes to improve safety by 
keeping dangerous drivers off the roads and enhancing oversight. 

"Violators of safety laws and regulations will face penalties high 
enough to promote future compliance. Maximum fines will be assessed for 
repeat offenders as well as a pattern of violations of our safety laws 
and regulations." (Emphasis added.) 

While the congressional committees did not submit reports on this 
legislation, the Chairman introduced materials to serve as the joint 
statement of managers for the legislation. Those materials and other 
floor statements also referred to repeat offenders or a pattern of 
violations. Id. at H.12874. 

[38] Pub. L. No. 98-554, title II, 98 Stat. 2832, 2842 (1984). 

[39] In making its argument, FMCSA is referring to the Office of Motor 
Carriers, which was an office within the Federal Highway Administration 
until 1999, the year when FMCSA was created with the adoption of the 
Motor Carrier Safety Improvement Act. That act strengthened and 
transferred to FMCSA the functions previously assigned to the Office of 
Motor Carriers. Furthermore, section 222(b)(2) not only used different 
language in the requirements for the imposition of fines; it also made 
the imposition of the maximum fines mandatory and specifically included 
repeat, as well as patterns of violations of critical or acute 
regulations. In this context, we do not agree that section 222(b)(2) 
was just a continuation of earlier, less specific, discretionary 
authority. Section 222(b)(2), along with other changes, was part of a 
congressional design to remedy what Congress viewed as serious 
shortcomings in the Office of Motor Carriers. Congress denied funding 
to that office under section 338 of the Department of Transportation 
and Related Agencies Appropriations Act, 2000, Pub. L. No. 106-69, 113 
Stat. 986 (1999), with responsibility for trucking safety being 
temporarily transferred to the Office of the Secretary. Only thereafter 
was FMCSA created as a separate administration within the Department of 
Transportation. 

[40] Our definitions are for analysis purposes only. We are neither 
suggesting which, if any, of these pattern definitions FMCSA should 
adopt as its policy, nor is our exclusive focus on patterns involving 
only violations identified during a single compliance review meant to 
suggest that the pattern definitions could not require that serious 
violations occur over multiple compliance reviews. 

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

[42] Office of Inspector General, Report MH-2006-046. 

[43] These figures count all serious violations as strikes, regardless 
of whether they resulted in a fine. This is consistent with the policy 
that FMCSA is developing in response to the Inspector General's 
recommendation. 

[44] David Madsen and Donald Wright, Volpe National Transportation 
Systems Center, An Effectiveness Analysis of SafeStat (Motor Carrier 
Safety Status Measurement System), Paper No. 990448, November 1998 and 
John A. Volpe National Transportation Systems Center, Motor Carrier 
Safety Assessment Division, SafeStat Effectiveness Study Update, March 
2004. 

[45] Volpe included only carriers which met one or more of the 
following conditions: two or more reported crashes; three or more 
roadside inspections during the preceding 30 months; an enforcement 
action within the past 6 years; or a compliance review within the 
previous 18 months. This is consistent with the SafeStat minimum event 
requirements. 

[46] U.S. Department of Transportation Office of Inspector General, 
Improvements Needed in the Motor Carrier Safety Status Measurement 
System, Report MH-2004-034 (Washington, D.C.: Feb. 13, 2004). 

[47] Both the Poisson model and the negative binomial model are 
statistically appropriate for use when modeling counts are positive and 
integer valued. The two models differ in their assumptions about the 
mean and variance. Whereas the Poisson model assumes that the mean and 
the variance are equal, the negative binomial model assumes that the 
mean is not equal to the variance. 

[48] The empirical Bayes method takes a weighted average of the rate of 
crashes for a carrier from a prior period of time and the predicted 
mean number of crashes from the negative binomial regression. This 
method optimizes the identification of carriers with the highest number 
of future crashes. 

[49] Ezra Hauer, Douglas Harwood, and Michael Griffith, The Empirical 
Bayes Method for Estimating Safety: A Tutorial, Transportation Research 
Record 1784, National Academies Press, 2002, 126-131. 

[50] For another assessment of data quality, see U.S. Department of 
Transportation Office of Inspector General, Improvements Needed in the 
Motor Carrier Safety Status Measurement System, Report MH-2004-034 
(Washington, D.C.: Feb. 13, 2004). 

[51] These 182 carriers were no longer in the worst 25 percent for the 
accident safety evaluation area after the addition of the late-reported 
crashes. 

[52] One reason for the improvement in the timeliness of reporting for 
the most recent year is that an unknown number of crashes that occurred 
in 2005 had still not been reported, as of June 2006, the date we 
obtained these data. 

[53] The University of Michigan Transportation Research Institute's 
reports on state crash reporting can be found at [hyperlink, 
http://www.umtri.umich.edu/publicationList.php?divID=4&t=8uFEHJI&plc=63|
9||5|CHRON||||]. State reports issued by the University of Michigan 
Transportation Research Institute cover California, Florida, Illinois, 
Iowa, Louisiana, Maryland, Michigan, Missouri, New Jersey, New Mexico, 
North Carolina, Ohio, Washington, and Nebraska. We included all of 
these reports in our review. 

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

[55] GAO, Freight Trucking: Promising Approach for Identifying 
Carriers’ Safety Risks, GAO/PEMD-91-13 (Washington, D.C.: Apr. 4, 
1991). 

[56] T. Corsi, R. Barnard, and J. Gibney, “Motor Carrier Industry 
Profile: Linkages Between Financial and Safety Performance Among 
Carriers in Major Industry Segments,” Robert H. Smith School of 
Business at the University of Maryland, October 2002.

[57] The American Trucking Associations is an association of trucking 
associations. Its mission is to serve and represent the interests of 
the trucking industry. 

[58] L.N. Moses and I. Savage, “The Effect of Firm Characteristics on 
Truck Accidents,” Accident Analysis and Prevention 26, no. 2 (1994).

[59] B. Lantz and D. Goettee, An Analysis of Commercial Vehicle Driver 
Traffic Conviction Data to Identify Higher Safety Risk Motor Carriers, 
Upper Great Plains Transportation Institute and FMCSA, March 2004. B. 
Lantz, Development and Implementation of a Driver Safety History 
Indicator into the Roadside Inspection Selection System, FMCSA, April 
2006. 

[60] Correlation = 0.085. (FMCSA, Development and Implementation of a 
Driver Safety History Indicator into the Roadside Inspection Selection 
System, April 2006, 14). 

[61] K. L. Campbell, “Fatal Accident Rates by Driver Age for Large 
Trucks,” Accident Analysis and Prevention 23, no. 4 (1991). 

[62] M. H. Belzer, D. Rodriguez, and S.A. Sedo, “Paying for Safety: An 
Economic Analysis of the Effect of Compensation on Truck Driver 
Safety,” prepared for FMCSA, September 2002. 

[63] L. Staplin, K. Gish, L. Decina, and R. Brewster, “Commercial Motor 
Vehicle Driver Retention and Safety,” FMCSA-RT-03-004 (Washington, 
D.C.: March 2003). 

[64] We obtained crash data for this period that were reported to FMCSA 
through June 2006. This allowed us to obtain data on late-reported 
crashes for the July 2004 through December 2005 period. 

[65] We did not interview managers or investigators in three of the 
seven states because they do not conduct compliance reviews of 
interstate carriers, and we did not interview managers or investigators 
in one state because they did not respond to our attempts to contact 
them. 

[66] Results from nonprobability samples cannot be used to make 
inferences about a population, because in a nonprobability sample some 
elements of the population being studied have no chance or an unknown 
chance of being selected as part of the sample. 

[67] Campbell, Schmoyer, and Hwang, Review of the Motor Carrier Safety 
Status Measurement System (SAFESTAT), 2004; U.S. Department of 
Transportation Office of Inspector General, Improvements Needed in the 
Motor Carrier Safety Status Measurement System, Report MH-2004-034 
(Washington, D.C.: Feb. 13, 2004); Madsen and Wright, Volpe National 
Transportation Systems Center, An Effectiveness Analysis of SafeStat, 
November 1998; Volpe National Transportation Systems Center, SafeStat 
Effectiveness Study Update, March 2004; University of Michigan 
Transportation Research Institute MCMIS State Reports; U.S. Department 
of Transportation Office of Inspector General, Significant Improvements 
in Motor Carrier Safety Program Since 1999 Act but Loopholes for Repeat 
Violators Need Closing, Report MH-2006-046 (Washington, D.C.: Apr. 21, 
2006). 

[68] The Transportation Research Board is a unit of the National 
Research Council, a private, nonprofit institution that is the 
principal operating agency of the National Academy of Sciences and the 
National Academy of Engineering. The board’s mission is to promote 
innovation and progress in transportation by motivating and conducting 
research, facilitating the dissemination of information, and 
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