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OCR for page 105
Potential Measures for Improving the Identification of Root Causes for Hazardous Materials Crashes 105 in all MCMIS hazmat crash reports. FMCSA could restore the rule for how the REPORT_ NUMBER field is constructed. Prior to 2001, states were instructed to use the PAR num- ber in the REPORT_NUMBER field. Although that rule is no longer required, some states embed the PAR number in the REPORT_NUMBER field. The PAR number of a crash would permit a hard link to a specific crash and not only provide more definite access to the PAR, but it would also facilitate linkages to crashes found in other databases such as HMIRS. 5.4.1.3 Add Data on Pre-Crash Conditions Pre-crash data concerning the driver and the vehicle would be entered into SafetyNet by the states. Driver information would include the driver's safety, violation, and health records. Vehi- cle information would include vehicle defects discovered at the scene. At the very least, for a crash involving hazmat, a Level I inspection would be conducted at the scene or another location, with special attention to such defects as brake adjustment and tire condition. In addition, information about the vehicle's maintenance history could be provided. This may simply reflect that the main- tenance records were current and required maintenance had been conducted. This is considered a long-term measure. At present, this information could be obtained for targeted accidents, say 100 per year as FRA does currently. If it is shown to be cost effective, the number of targeted acci- dents could be expanded over time. 5.4.1.4 Enhance the MCMIS Crash File Data Dictionary The MCMIS data dictionary could be enhanced so that it contains not only the definition of a parameter and the format for the field in the database, but also the format of the data to be entered. Specifying the format in the database does not necessarily define the data entry format as evidenced by the current dataset. A section answering some commonly asked questions would be valuable as well. For instance, if the PAR lists the carrier location as one of the carrier's freight depots, should that address be entered in the MCMIS Crash file or should the address of the carrier's home office, taken from the MCMIS Registration file, be entered? Another consideration might be related to the choice of entering a street address or a postal box number. Another example is whether an Interstate route should be designated as I-70, IR70, I070, I70, or some other format. If the use of longitude and latitude when specifying the location is adopted, then the format and accuracy also should be specified. If the coordinates were expressed in decimal degrees, then specifying the longitude and latitude to two decimal places would place the accident on a high- way, yet if specified to three decimal points the location would be shown as either being on the left- or right-hand side of the right-of-way. 5.4.2 Potential Measures for HMIRS The following potential measures apply to enhancing the ability of HMIRS to identify root causes of hazmat accidents. Provide Training for Carriers Training in completion of the 5800.1 report should be provided to carriers. Included in the course would be a unit on root cause identification. Some of the training elements given to NTSB inspectors could form the basis for this training unit. The course would be presented in a webinar format, comprised of two four-hour sessions. Use Drop Down Lists HMIRS could use drop down lists for such data as place, carrier name, vehicle type, container type, and hazmat type. This would prevent unneeded mistakes resulting from different inter- pretations of particular spelling.

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106 Hazardous Materials Transportation Incident Data for Root Cause Analysis Include a Copy of the PAR with Reports Carriers would submit a copy of the PAR for any HMIRS reportable traffic accidents. This provides another tool for PHMSA to confirm the accuracy of material in the 5800.1 report. PHMSA could check the carrier's report against the PAR to identify inconsistencies. These inconsistencies could be sent to the carrier for confirmation or clarification. Changes to the 5800.1 report could be made where needed. Ensure that Filers Fix Incorrect Data Before the Submission Is Accepted In FY09, PHMSA will introduce an online Incident Reporting System that will require filers to fix incorrect data before the submission will be accepted. However, since the carriers will also be able to file the reports via other methods, the effectiveness of these checks will be lim- ited to electronically submitted reports. Include Non-Spill Hazmat Crashes in HMIRS Most serious crashes are potential spills even if none occurs. Therefore by including all of these "serious crashes" involving placarded shipments, officials analyzing the crash data in HMIRS will be able to more effectively determine root causes. The definition FMCSA uses for the inclusion of a crash in the MCMIS database could be applied to all non-spill hazmat crashes that are not currently included among the incidents that must be reported to HMIRS. By including non-spills, PHMSA would be able to provide data on "successes"; that is, what worked well in the hazmat transportation system. For example, if a particular packaging was involved in multiple rollover crashes and resulted in fewer spills than another packaging, this information could provide valuable evidence for use of a particular packaging type. The recent requirement that Type C accidents be reported is a step in this direction, showing that it is considered feasible to include such non-spill accidents in the database. Encourage Carriers to Enter Multiple Hazardous Materials in the 5800.1 Form Carriers sometimes carry more than one hazardous material. This is true for less than truck- load cargo shipments. Therefore, carriers can easily enter this information in the 5800.1 report sent to PHMSA. Many do not break the information down, making it impossible to distin- guish good and poor package behavior. Send All Reports to the Carrier for Confirmation A report could be generated automatically after data are entered into HMIRS and a letter or email sent to the reporting carrier to confirm the data. A certain amount of time, such as one month, could be used to allow the carrier to check the accuracy of their submittal and to add information their internal investigations may have discovered. PHMSA could change the con- tent of the 5800.1 report, if required. Subject Crashes That Meet a Certain Threshold to Follow-Up Audits All crashes involving certain classes of hazardous materials could be subject to a more detailed PHMSA audit. The audit would thoroughly check the accuracy and completeness of the acci- dent description and collect additional information where required. Specific material types with a certain hazard threshold could be selected for this audit. For example, the hierarchy below could be followed with the top of the list having the highest priority for audit. Class 1: explosives, Class 7: radioactive, Class 6.2: infectious substances, Classes 2.3 and 6.1: toxic inhalation hazard (TIH), Class 2.1: flammable gas, Class 3: flammable liquid, Class 4: dangerous when wet, and Class 5: oxidizer. Provide a DOT Number for All Reports A DOT number should be reported in all HMIRS records for en route accidents. This will facilitate matching information on the same crash in other databases.