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28 Hazardous Materials Transportation Incident Data for Root Cause Analysis
Regarding ways to improve HMIRS, Shipper 2 believes that the highest priority should be to
make the data contained therein more accurate and consistent, only adding more reporting ele-
ments if they have a direct connection to establishing root cause. Improved accuracy could per-
haps be accomplished by having PHMSA request that the reporting entity update the HMIRS
record after a certain amount of time has elapsed since the date of the accident. Techniques to
improve data consistency might be to utilize tools that facilitate more automated data entry (e.g.,
Web-based data entry) and to employ checks and balances in judging whether reported infor-
mation makes logical sense. Part of the problem with reporting, the company believes, is a lack
of education on the part of shippers/carriers/LSPs in terms of the importance of filing accurately
with HMIRS, how best to accomplish this task, and pitfalls to avoid. To that end, PHMSA could
provide better training to these stakeholders.
Although perhaps a bit removed from the task at hand, the shipper's vision for HMIRS is that
motivation for reporting should be based on industry desire to put improvements in place to
mitigate future risk rather than feeling obligated to report in order to achieve regulatory com-
pliance. To that end, the company would recommend that the federal government produce data
that not only accentuates failures, but successes as well.
3.4 Interviews with Database Managers
The research team also conducted interviews with selected agencies that are responsible for
managing key databases. The agencies include PHMSA, FMCSA, and FRA. The complete inter-
views are found in Appendix B (available on the TRB website at www.TRB.org by searching for
HMCRP Report 1).
The discussion below presents a summary of findings deemed most significant.
3.4.1 Interviews with Agencies Maintaining Databases (PHMSA)
The PHMSA officials indicated that reports go right into the database, which includes high-
level quality control processing. They employ character-to-character checks to ensure that their
process translated the paper form properly.
During this process, they examine the form for personally identifiable information (PII), busi-
ness rule inconsistencies, invalid dates, and invalid commodities (by cross-checking with the
commodities in the database). To determine if they were caused by the hazardous materials,
fatalities and injuries are validated by PHMSA using their own subprocess. Additional checks
include cases such as when the report shows that 5.5 gallons were spilled from a 5-gallon con-
tainer. PHMSA will go back and ask the filer whether there were multiple packages that failed
and request that they file a supplemental report or they will sometimes use an e-mail reply as
confirmation to correct the data themselves. They look for city/county inconsistencies. If a ship-
per is an individual, they will not put that name in the database.
The PHMSA official believes there would be a benefit from more verification, not just form-
based validation. Sometimes important information such as costs, injuries, or other important
information is left off. Sometimes this is because many big companies hire spill centers to com-
plete the forms for them. Rather than checking all submittals, the officials believe that checking
the significant or serious incidents would provide the most benefit.
With respect to underreporting, PHMSA staff use a Web crawler and look for incidents, which
they put in the HMIRS. In addition, they match things up with the telephonics [National
Response Center (NRC) record]; if there is no match, it is flagged. They wait 60 days and then
marry up the unreported incidents (URIs) to telephonics.
