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Summary of Interviews with Carriers, Shippers, and Database Managers 29 Both highway and rail show a greater incidence of URIs than expected by the modal distribu- tion of incident reports. For example, 91% of all URIs are highway incidents whereas 86% of all reported incidents are highway incidents. For rail, it is 9% and 4%, respectively. Air has nearly 0% of the URIs (only 1 incident), but 10% of the reported incidents. The official was not sure as to which mode had the most complete incident reports, but indi- cated that many highway incident reports were not completed. The PHMSA official had the following suggestions for improving data collection effectiveness and quality. 1. More companies should report online to reduce errors and 2. More business rules should be used in online tools so a filer could not submit an inaccurate report. Another official indicated that there are two aspects to the reporting requirements, the reg- ulations and the report itself. The rulemaking aspect is an impediment, primarily because it is the rule itself that specifies who has to report. This official said it took 10 years to change the form the last time, making sure all stakeholders were heard, etc. To simply change the form itself, all that is required is to go through Office of Management and Budget's (OMB) information collection procedures, which include 30-day and 60-day notices and the justifi- cation required by the Paperwork Reduction Act. During the conversation, this interviewee determined that if the specification of who has to report was added to the form itself, PHMSA would no longer have to go through the rulemaking process to make changes in the form and that they could do so more often and more quickly. 3.4.2 Interviews with Agencies Maintaining Databases (FMCSA) The interview below was conducted with a key administrator responsible for the management of the MCMIS database at FMCSA. When accident reports are received, states upload crash reports through SafetyNet. States extract the data, either through an automated system or manually. That is, the data can be extracted using a computer program, or the cases can be keyed in directly. Certain fields are mandatory, such as carrier name and address. All fields are required, although blanks in non-mandatory fields do not result in rejecting the case. FMCSA evaluates the accuracy of the submitted records through the following: 1. Use of a data quality module, 2. UMTRI evaluations of the completeness and accuracy of the MCMIS Crash data, 3. On-site data reviews, 4. NISR (contractor) evaluations of state crash report forms for compliance and accuracy, 5. NISR evaluations of state extraction logic and methods, and 6. Crash data collection training for enforcement personnel. In addition, FMCSA utilizes the State Data Quality Improvement Program to help insure completeness and accuracy. The program includes the following: 1. Independent evaluation of the completeness and accuracy of the MCMIS Crash data, 2. On-site (at the state) reviews of state processes, 3. Evaluation of the accuracy and sufficiency of state crash forms to collect the MCMIS data, 4. On-site (at the state) evaluation of the data extraction logic and methods, 5. On-site (at the state) training for enforcement and other personnel, and 6. Three-day Data Quality and Training Conference in San Antonio for representatives of all the states.