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CSA Reform Status

 Steve Bryan, Vigillo CEO/Founder gives comments to National Academies of Sciences in Washington DC last June

Steve at NAS

Background

On December 4th, 2015, President Obama signed the FAST Act (Highway Bill) that secured funding for infrastructure, removed CSA Scores from public view, and defined a reform process for the CSA Program that would lead to the return of the Scores once proper reforms were made and Congress authorized their re-publication to the public.

Reform Summary

The FAST Act required the FMCSA to retain the services of the National Academies of Sciences – Engineering – Medicine. (NAS) An 18 month process was outlined where the NAS would address the flaws of CSA and issue recommendations as to how they might be addressed.  I have previously summarized those flaws from the FAST Act as follows:

1. The accuracy with which the BASIC’s identify high risk carriers and predict or are correlated with future crash risk, crash severity, or other safety indicators for motor carriers. (Safety Event Groups)

2. The accuracy of safety data, including the use of crash data from crashes in which a motor carrier was free from fault. (Crash Accountability)

3. Whether BASIC percentiles for carriers of passengers should be calculated separately from motor carriers of freight. (Freight vs Passenger systems)

4. The differences in the rates at which violations are reported to the FMCSA by various enforcement authorities, including States, territories, and Federal inspectors (State Difference)

5. How members of the public use the SMS and what effect making the SMS information public has had on reducing crashes

6. Whether the SMS provides comparable precision and confidence, through SMS alerts and percentiles, for the relative crash risk of individual large and small motor carriers;  (Small Carriers largely unscored)

7. Whether alternatives to the SMS would identify high risk carriers more accurately

8. FMCSA has fully implemented or satisfactorily addressed the issues raised in the report titled ‘‘Modifying the Compliance, Safety, Accountability Program Would Improve the Ability to Identify High Risk Carriers’’ of the GAO dated February 2014.

Reform Status

Early in 2016, FMCSA did in fact retain NAS and a panel was convened to begin the study.  The panel, all of whom come with a leading “Dr.” in front of their names, and are attached to some of the leading Universities in the USA, are to say the least, a very impressive group.  The individuals who comprise the panel are listed here.

There have now been three meetings of the panel, where at least some portion of the meeting was open to the public. I was asked to give the remarks of stakeholders on behalf of the ATA at the June meeting and was introduced by Chairman Thomas. I am pretty sure I am correct in stating that aside from the Panel and NAS Staff, and the representatives of FMCSA, I am the only person from the industry who attended every meeting.  All three meetings were held in Washington DC, June 29, August 30, and Just a few days ago on December 15.  Meetings agenda’s are posted here.

Next Steps

The FAST Act calls for an 18 month timeline for the NAS to submit a report outlining the suggested reforms.  There will be one more meeting of the NAS Panel (closed to the public) early in 2017, and then a report will be written, reviewed, and finally released for public comment by late May or early June, right on the 18 month schedule.

Opinion Alert

So, what is going to be the outcome? A major overhaul of CSA?  Will Scores come back online?  What is FMCSA’s position on all of this?  Does the NAS Panel understand the issues?

Here is my opinion, and it is only that, an opinion based on what I have observed in the meetings.  I don’t have any information about what the panel is discussing in closed meetings.  Those are between FMCSA and the panel.  So I don’t have all of the information.

First, the Panel is made up of a very smart, very professional, and very successful individuals. They are the top of their fields including statistics, bio-statistics, education, engineering, transportation, and safety.  They have very impressive resumes, and for their participation in this study, they are each paid a whopping fee of $0.  So this begins to inform my opinion that this group is very independent, and not beholden to any party in this process.  They do this kind of work to develop and enhance their professional reputations.  So my first observation is that the report will be a very honest and professional analysis of CSA.

Second, the people who have been asked to contribute comments and presentations come from every corner of safety, transportation, data, government, and business.  Comments have been submitted by suppliers like Vigillo, freight and passenger carriers, FAA, NTSB, GAO, ATRI, CVSA, TIA, FMCSA, Insurance and safety advocates have all had the opportunity to comment on the pros and cons of CSA, its data, and methodology. Every opinion has been heard and documented, and the report promises to address every one of those opinions.  It will be very comprehensive.

In my opinion, the NAS Panel will suggest some very significant changes to the CSA program.  It will not be a few tweaks.  CSA requires a lot more data, from a lot more sources, on a lot more carriers.

And finally, in the spirit of the season, I also believe the Agency is listening.  I am hopeful that this reform process will result in a better CSA program that does a much better job of identifying unsafe carriers and saves lives.  If this process can get us there, we all win.

Merry Christmas everybody.

 

Steve

Hi everyone,

We have not updated you about the FMCSA upgrades in a  little while but we’ve been back to Washington DC and met with the FMCSA since last time and have some news:

The FMCSA upgrade is still not complete but thankfully the FMCSA are now posting news about the upgrade status, you can see those below. At Vigillo what we are seeing is that some DOT’s still cannot log in to FMCSA Portal. The FMCSA are very aware of this and we contact them multiple times per day and have escalated this to the very highest levels.

SMS 

The SMS BASIC Percentile scores for this month were calculated with inspection, violation and crash data only up through November 16th, not up to the SMS Snapshot date of November 25th. The data for the latter half of November (Nov 17th – Nov 25th) will be included in next month’s SMS update. This may cause you some anomalies in your BASIC Percentile scores this month as only half the usual amount of data is being used. Still, the CSA Methodology is a relative scoring system so much of this should mostly balance out but we do see some significant Percentile changes for the month.

We are seeing that some States are still not reporting inspection, violation or crash data, or are not reporting it completely. We don’t yet know if this data will be backdated at a later time but we will keep you updated on this.

Here is what the FMCSA are reporting:

  • Display of the Safety Measurement System (SMS) Behavior Analysis and Safety Improvement Categories (BASICs) is currently disabled within the Portal. To view your SMS data, log into the CSA SMS Website.
  • Not all State inspections/crashes are uploaded at this time. FMCSA is working/troubleshooting with some individual States to complete the inspection/crash upload.
  • Individual Carrier Safety Profile generation is not working for some carriers. FMCSA is working to restore this functionality to all carriers

QC Mobile API

The QC Mobile API used to programmatically retrieve L&I information is back online although it does have some intermittent problems and was down for much of last weekend. It is working correctly at this moment. The FMCSA are working on this.

The FMCSA have reported to us that they expect to have all problems relating to the Compass Portal upgrade addressed by the time of the next SMS monthly update which is on the week of January 9th 2017.

We will keep you updated as we find out more and Happy Holidays from Vigillo.

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Today we have some good news about the L&I API:

QC Mobile L&I API

This API is the main and only way to bulk or programmatically retrieve L&I information from the FMCSA. Many DOT’s and software companies use this API to populate L&I information. Unfortunately this API has been unavailable since the FMCSA’s move to Amazon’s servers (called AWS) since November 16th 2016:

GOOD NEWS: This API is back working today 12/16

We don’t know how reliable it will be but here at Vigillo we have turned our access back on and L&I information is now flowing into our Carrier Select program once more.

We will keep you updated on this.

FMCSA Compass Portal Access

While many DOT’s now have access to their FMCSA Portal account we have significant reports of accounts still locked out, accounts are “stuck in a loop”.  We know from discussions with the FMCSA that they are highly aware of this and are working on it as a priority.

Vigillo’s Inspection Management System compares FMCSA inspections with company provided inspections. Normally these match up to a high degree. However, we are recently seeing higher rates of mismatch. This appears to indicate that the inspection, violations and crash data in FMCSA Portal may not be complete. We will continue to investigate this and keep you updated.

SMS Monthly Update

The SMS snapshot date is November 25, 2016 but there isn’t any inspection/violation or crash data later than November 16th currently in SMS. We have investigated this and preliminary results show that the FMCSA appear to have used only this data to compute this month’s BASIC Percentile scores. We should have a complete answer on this  very soon and will keep you updated.

As previously mentioned  the FMCSA has added 10 new Acute/Critical violations this month.

The FMCSA’s Compass Portal migration to Amazon is still experiencing challenges today. Here is the latest update:

FMCSA Compass Portal Access

While Vigillo can now access daily data from portal for many customers there is still widespread Portal Account access issues. The FMCSA are aware of this (we just spoke with them this morning) and have escalated this issue. If you are having problems accessing your portal account then this should get addressed by the FMCSA hopefully soon (no need to call as they won’t submit a ticket since they already know about this).

Our Support team are working directly with customers on this issue. If you have any questions please call us at 503-688-5100 x102 or email us at support@vigillo.com

SMS Monthly Update

While the latest SMS snapshot date is November 25, 2016 there doesn’t appear to be any inspection/violation or crash date later than November 16th in SMS. This begs the question; what data was used by the FMCSA to compute this month’s CSA Percentile Scores? Is it all the data up to the snapshot of Nov 25th, or is it just half the regular data displayed up to Nov 16th. Here is what the FMCSA says:

“The CSA Safety Measurement System (SMS) Website has been updated with the November 25, 2016 snapshot. Please note: inspection and crash data is current as of November 16, 2016. The next snapshot will include inspection and crash data for November 17-25. Motor carriers, check your own safety assessments now.”

We are working on identifying this issue.

Additionally, the two Inspections and Violations files available for download from SMS that contain the publicly available inspection and violation data used for the current month’s SMS calculations also truncates on November 16th – the data only goes up to 11/16/2016 (instead of the SMS Snapshot date of 11/25/2016). The rest of this data will be posted in next month’s SMS update. Here is what the FMCSA says about this:

Inspection and crash data is current as of November 16, 2016. The next snapshot will include inspection and crash data for November 17-25. Motor carriers

Changes to CSA This Month.

A change this month is that the FMCSA has added 10 new Acute/Critical violations.

QC Mobile L&I API

This API is still down so no access to L&I information is available in bulk or programmatically, it is one DOT at a time on the L&I website at:

http://li-public.fmcsa.dot.gov/LIVIEW/pkg_carrquery.prc_carrlist

The FMCSA report this as a difficult problem so we have no ETA on when this will get resolved.

Upcoming FMCSA Changes

The FMCSA are going to remove DOT and PIN login to SMS. No more PINS! The only access to SMS in future will be through Compass Portal. This means all motor carriers will need a Portal account. The timeframe from the FMCSA on this is “in the coming months”, here is how the FMCSA phrases it:

“In the coming months, access by U.S. DOT Number and U.S. DOT Number PIN will be disabled on SMS and motor carriers will need to log in using the FMCSA Portal”

This is the latest information we have. The FMCSA are aware of all of these issues and are working to correct them.

We will keep you updated as we learn more

Happy Friday!

More positive FMCSA news today in that we can successfully access most DOT’s inspections, violations and crashes from the FMCSA Compass Portal now on a daily basis and provide this information in Vigillo’s scorecards

The most recent Post Date is Thursday 12/8/2016 which is the most up the date information available which is good

We still have a few DOT’s with no access and we are working on those. If you have problems accessing the FMCSA Compass Portal, try Chat with them here (this is usually responsive):

  • https://ask.fmcsa.dot.gov/app/chat/chat_launch

If you are running Vigillo’s VDU, and you most likely are if you have the Vigillo Daily Update feature, there are a few customers who still need to upgrade to the new version released on 12/1/2016. We will be contacting you about this but please go ahead and update if you can (there should be pop-up that appears on your screen asking to update)

The BASIC Percentile scores on the Compass Portal home are still incorrect (they are shifted) so look to SMS for the correct scores:

  • https://ai.fmcsa.dot.gov/SMS

The QC Mobile API used to gather L&I information is still down.

We are noticing quite a lot of Clean Inspections and we are not yet sure these are all correct. In the past, during Compass Portal data outages, we have first seen inspections recovered as Clean inspections initially but then later become populated with their true violations so please keep an eye out for that.

We are still having problems with accessing some DOT accounts and we still have reports of customers with problems accessing Compass Portal although it appears to be improving

Contacting the FMCSA: If you are still having problems logging into Compass Portal the most immediate way to get help from the FMCSA is through their Chat system at:

  • https://ask.fmcsa.dot.gov/app/chat/chat_launch

Here are some other direct links to FMCSA Support:

  • https://ask.fmcsa.dot.gov/app/home
  • https://ask.fmcsa.dot.gov/app/ask
  • https://www.fmcsa.dot.gov/mission/field-offices

FMCSA Contact Center support number:

  • 1-800-832-5660

The remaining issues from yesterday such as Portal CSA Scores, L&I API etc. are not addressed yet although the FMCSA are actively working on these issues and we will keep you updated

We are have been watching FMCSA Portal overnight and have been in contact with the FMCSA today: The latest news we have is:

  1. While we do have access to many DOT’s daily inspections, violations and crashes, we do see Portal login problems. We have heard from the FMCSA today that Portal access is still “hit and miss”.
  2. We see Post Dates bunched on Dec 2nd (Friday) and Dec 5th (Monday) as Portal was “frozen” over the weekend and is now catching up. We do expect data to be fully restored but it is coming back in batches at a time.
  3. We have reports of Vigillo customers who cannot log into FMCSA Compass Portal because of errors who call the FMCSA to report this but the FMCSA responds that there are no problems. There are indeed login problems and we have reported these to the FMCSA who are working on it.
  4. The BASIC Percentile scores on the Compass Portal home are still incorrect (they are shifted).
  5. The main Safer website at http://safer.fmcsa.dot.gov/ is intermittent at the moment.
  6. The QC Mobile API used to gather L&I information is still down.

We will keep you updated as we discover more. The main thing for Daily Update customers is to update your version of the VDU program if you have not done so since 12/1/2016 as it will then keep your Vigillo Scorecards current with FMCSA progress in restoring your data.

Good news today; FMCSA Compass Portal is back online!

We successfully retrieved customer Daily Update information beginning last night and through this morning from Compass Portal.

If you are a Vigillo Daily Update customer then Vigillo will download Compass Portal inspection, violation and crash data automatically on your behalf and display it in your scorecards

If you are a Vigillo Daily Update customer then you are running the Vigillo Daily Updater (VDU) program. Many of you have updated this program to address recent changes on Compass Portal and we see your data flow in. If you have already done the update (since 12/1/2016) then you are all good, otherwise you will need to update your copy of VDU. It should pop up on your screen asking you to update so go ahead and do that. Our support team are contacting our customers about this.

In the meantime we will continue to monitor Compass Portal and keep you updated on it’s health.

We don’t have great news this Monday morning regarding the FMCSA Compass Portal as it appears to have taken a step backwards over the weekend where  we saw intermittent behavior and were forced to stop gathering your daily  inspection, violation and crash data. Today on Monday Dec 5th, problems continue such that when we log into Compass Portal we receive the following message (you will see similar behavior although problems are changing constantly):

“The USDOT #nnnnnn you entered could not be found, Please check the entered information”

This occurs for all DOT’s. Just this morning the FMCSA posted the following message:

The MCMIS system is down and will remain down possibly all day December 5th 2016.

Note that Vigillo’s servers have remained online and accessible during all of these problems and unless you have the Vigillo Daily Update feature you will see no problems as your data is updated monthly and Vigillo already has all of that data as shown in your scorecards.

If you have the Daily Update feature then you will be using the Vigillo Data Updater (VDU) program. We disabled VDU last night (Sunday Dec 4th) because of Compass Portal problems and we will automatically turn it back on when the FMCSA becomes available again.

This month’s SMS Monthly update is later in the month on the “Week of December 12th” so hopefully these problems will be addressed by then.

We will keep you updated throughout the day and we will automatically turn your Daily Update data back on once it becomes available again from the FMCSA.