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4 CHAPTER 2 ALTERNATIVE COMMERCIAL VEHICLE INSPECTION STRATEGIES SURVEY METHOD in large part, are driving jurisdictions to adopt more alterna- tive inspection strategies. The highlights of the survey results The researcher team coordinated the survey that was admin- include the following findings: istered under this project with a survey that was being admin- istered by the Commercial Vehicle Safety Alliance (CVSA) A trend toward conducting roadside inspections at mobile on behalf of FMCSA. The FMCSA project is exploring what or virtual inspection facilities, as opposed to fixed weigh role existing or emerging wireless technology can play in the stations; commercial vehicle safety inspection process. Vehicles are targeted for inspection predominantly to Once the survey questions were finalized, staff from CVSA find "high-risk" drivers. Identifying at-risk vehicles and developed an on-line version of the survey. The survey was carriers is a lesser priority to enforcement personnel-- distributed to 69 CVSA member jurisdictions via e-mail. as is identifying high-risk cargo; Respondents simply needed to click on a link to the survey Jurisdictions use a broad range of tools used to select a that was included in the e-mail message in order to respond vehicle for inspections, including visual inspection of the to the questions. A total of 25 responses were received-- vehicle, electronic screening technologies (e.g., PrePass), representing a 36% response rate. weigh-in-motion (WIM) sensors, and advanced sensing The final survey that was distributed included 28 ques- technologies (e.g., detecting radiological, biological or tions, primarily multiple choice, for respondents to reply to. chemical cargo); Several of the questions were open-ended and provided respon- Approximately 58% of the respondents use an electronic dents an opportunity to provide more detail about what enforce- screening algorithm (e.g., ISS, SafeStat) to help them ment strategies they are using, how effective these strategies determine which vehicles to target; and are, and the areas that they wish to improve. When asked what technologies are needed in the future, The survey results were augmented with interviews with a the majority of respondents indicated the need for series of stakeholders. The interviews included a geographic enhanced on-board sensors that would notify field per- and demographic cross section of the enforcement commu- sonnel of potential problems with the vehicle or driver. nity, as well as the motor carrier and motor coach industries. Interviews were conducted with the following: The survey results are tabulated in Appendix C. Representatives from 11 state agencies responsible for the regulation of the motor carrier and motor coach DISCUSSION industries; Four state trucking associations; On the basis of survey results and supporting interviews, Two national industry associations--one representing there appears to be consensus that alternative inspection tech- the motor carrier industry and one representing the nologies are necessary and the desired trend for future motor coach industry; and enforcement activities. State personnel perceive these alter- Representatives from FMCSA. native technologies as a key strategy to "do more with less" as they are confronted with rapid growth in commercial vehi- Some of these interviews were conducted exclusively for cle traffic and stagnant or declining enforcement resources. this project, while others were done in conjunction with related The industry perceives these alternative strategies as a means studies. to "level the playing field" and ensure that carriers that are not meeting their safety obligations do not receive an unfair com- PRINCIPAL RESULTS petitive advantage over those that do. There also appears to be consensus among the stakehold- The survey results confirmed that a majority of jurisdictions ers that the current alternative inspection strategies for select- are struggling to keep pace with increasing commercial truck/ ing commercial vehicles and drivers for an inspection are bus traffic and shrinking enforcement resources. These trends, insufficient. Seventy-four percent of respondents indicated

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5 that they rely on a visual inspection of a vehicle/driver to more frequently are at a disadvantage as compared to determine the type (level) of inspection that should be per- carriers operating in states with less frequent updates formed, even though a majority (58%) of them use a screening that enjoy a "grace period" between when a crash or algorithm as part of their roadside operations. This indicates inspection occurring and their being reported to FMCSA that roadside personnel do not have sufficient confidence in the and included in the screening algorithm calculation. roadside tools to use them exclusively. Industry representa- tives noted a similar level of skepticism regarding the current It is important to note that the state personnel also noted a set of screening tools. In particular, industry representatives concern about data quality. Obtaining more robust data (67%) noted the following concerns: was listed second only to decreasing crashes (88%) as a prior- ity for a respondent's inspection program. The "rules of the game" (e.g., how the selection algo- Further, the survey results indicate that the alternative strate- rithms work, the data used in the current screening algo- gies currently available may not meet the operational realities rithms) are not widely known and/or understood by the of roadside enforcement. Sixty percent of respondents indi- industry; cated that their "jurisdiction's commercial vehicle inspection The current inspection selection aids may not identify program (is) aimed at identifying" high-risk drivers. Unfortu- the correct vehicles for targeted enforcement; nately, there currently is no driver-focused alternative strat- Quality issues (e.g., associating a crash with the wrong egy and only 8% of respondents indicated that their current motor carrier) in the data used by FMCSA to calculate selection tools are most effective at identifying high-risk driv- the screening algorithms undermines the accuracy of the ers. FMCSA currently is working to develop a driver-focused screening decisions; algorithm (Inspection Selection System-Driver [ISS-D]) and The lack of "at fault" determinations for the crash data is augmenting the Commercial Vehicle Information Systems used in the calculation of screening algorithms is unfair & Networks (CVISN) architecture to improve the sharing of and may result in a carrier being targeted for enforce- commercial vehicle driver data. ment actions based on incidents that were beyond its The survey also indicated that states are modifying their controls (e.g., having its vehicles rear-ended by another enforcement strategies to include mobile and virtual enforce- vehicle); ment operations. These operations--made possible through Once a carrier is deemed "high-risk" by the screening in-vehicle and roadside-based technology--are allowing algorithm and targeted for enforcement, it is difficult to jurisdictions to expand their enforcement efforts off of the be removed from the list because the "high-risk" deter- highways and onto smaller roads, including roads that are mination is a "self-fulfilling prophecy" in that a roadside known bypass routes around fixed inspection stations. Stake- inspector will be predisposed to look for a violation on holders have recommended that FMCSA support the devel- a vehicle of a "high-risk" carrier; and opment of virtual roadside sites through the development of The varying frequency in which states submit their deployment templates and identification of "best practices." safety data to FMCSA creates an "uneven playing field," The movement toward mobile inspection facilities also reveals whereby carriers operating in states that update FMCSA a need to improve wireless communications.