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30 Hazardous Materials Transportation Incident Data for Root Cause Analysis FMCSA has the following suggestions for improving the effectiveness and quality of data collection, and in all cases the administrator believes that suggestions must be tailored to individual states: Provide continuing funding and technical assistance to the states. Improve data collection by police officers by providing in-depth training by qualified indi- viduals. Improve data handling and processing at the state level by developing programs to meet indi- vidual state needs. Improve data handling and processing at FMCSA by recognizing and correcting system bugs immediately. Maximize electronic data collection and processing, as well as integrating other databases such as driver history, CDLIS, etc. When asked if additional training was needed for MCMIS, the administrator answered yes but stated that FMCSA already has an extensive training program. They attempt to train personnel at each step of the process of data acquisition, from the officer who collects the data (through direct training, visor cards for police vehicles, and train the trainer) to the state personnel who extract and upload the data, to FMCSA personnel who prepare the file. When asked if improvements should be made to MCMIS to improve data collection for hazardous materials crashes, the FMCSA database administrator responded that it would be unrealistic to collect any additional hazmat data such as quantity and package type than is cur- rently collected. 3.4.3 Interviews with Agencies Maintaining Databases (FRA) The interview was conducted with an FRA official responsible for administering the RAIRS database. When questioned about whether the RAIRS database includes the consideration of root cause analysis and/or root cause releases, the official responded that the RAIRS database and normal accident reports have had limited use for root cause analyses (RCAs) because they are "event" reports rather than detailed investigations of specific incidents. Their principal purpose is to enable accumulation of a statistically valid database on accidents for analysis of historical trends. The official added that about 150 accidents per year are subject to more inten- sive investigation out of a total of about 3,000 annually. Nevertheless, even these more detailed analyses are not fully developed, in-depth RCAs. In 2008, these reports were made available online, in addition to databases which have been available for many years. There are also some concerns about the consistency between railroads in how they interpret primary and secondary causes. Even within a railroad, there can sometimes be problems. Such inconsistencies can interfere with, confound, or complicate analyses. The official pointed out that root cause analysis now falls within the new Risk Analysis Divi- sion. Although the risk analysis initiative is new, it may lead to suggestions for changes. When asked about barriers, either institutional or other, to implementing these changes, the FRA official replied that one barrier relates to regulations. There is a statutory limit to what rail- roads must report so significant changes are not easily implemented. The two paths for significant changes would be via rulemaking process or the Rail Safety Advisory Committee (RSAC). When questioned, the official pointed out that there have been suggestions external to FRA to change or improve the database with respect to root cause analysis. They have received inquiries from labor about more detail regarding operations data such as RCL (remote-controlled loco- motives). NTSB has suggested expanding the cause codes. There is a notice of proposed rule-