Operational Policy 5 - Inspection Selection

CSA 2010 and other critical traffic safety improvement initiatives in the US and Canada are built on the foundation of effective roadside inspections and traffic enforcement. While there are current FMCSA data quality programs that have been designed to improve the timeliness, accuracy and completeness of both crash and inspection reporting, as lead agencies we must make certain that violation data is also accurate, uniform and consistent for all roadside inspections. The Carrier Safety Measurement System (SMS) and proposed Safety Fitness Determination (SFD) methodology that have been developed under CSA 2010 both rely heavily on roadside inspection and violation data. The SMS uses roadside inspection results to identify a motor carriers? specific safety problems and select the appropriate intervention strategy, in a method similar to how SafeStat results are used today. However, in the CSA 2010 Operational Model these roadside inspection and violation results are an input into the SFD process and may directly impact a motor carrier?s safety rating.Furthermore, as we deploy more advanced technology and targeting techniques at the roadside and in a motor carrier?s place of business, it becomes even more important that the underlying data resulting from our actions is accurate and timely. Additionally, international agreements between the United States and Canada allow the use of this roadside enforcement data to measure carrier safety fitness and to formally recognize each other?s work through safety rating reciprocity. As a result, the importance of the data being produced from these activities is critical. If these data are not effectively monitored for quality control and enhanced when necessary it will result in significant consequences such as lost time and misdirected resources for enforcement agencies and industry alike. Therefore it is of significant importance that CVSA, as an international organization, advocate policies that promote consistent and uniform application of commercial vehicle safety regulations for all of its members. An early step in enhancing the consistent application of safety regulations is identifying and developing specific policies that guide the inspector on how a vehicle or driver should be selected for an inspection. Furthermore, those policies should be based on several internationally regarded principles that promote the integrity of both the data and the member?s program itself. However, at the present time CVSA provides little guidance to member jurisdictions in regards to how vehicles are selected for inspection.

To help promote both the integrity of a member jurisdiction's data and their program, we suggest that there be an amendment to the Operational Policy 5 that promotes the development of policies that guide the inspection selection processes of jurisdictions and inspectors.

I recommend that Operational Policy 5 - Inspection Selection be changed as follows... SELECTING VEHICLES FOR INSPECTION The Alliance recognizes that among its members, there are varying degrees of authority designating how member jurisdictions select vehicles for inspection. Consequently, there is no single CVSA policy recommending a selection method for all jurisdictions. Therefore, to maintain international program integrity, CVSA jurisdictions are encouraged to actively review their policies that govern when and how vehicles should be selected for an inspection and ensure that those policies remain current, valid and consistent with national/international program objectives. In the process of reviewing inspection selection policies, individual jurisdictions should consider the following concepts. This list is not exhaustive, nor is it meant to be a set of minimum criteria that a jurisdiction must adopt as its inspection selection policy. Rather, it is a set of guidelines that should be used to provide assistance to member jurisdictions when reviewing and updating inspection selection policies. The following items should be considered when reviewing and adopting inspection selection policies in individual jurisdictions: 1. The consistent use of standardized electronic vehicle screening systems such as ISS, Query Central, and CVISN. 2. The consistent use of methods to identify companies for inspection based on insufficient data. 3. The importance and continued integrity of the jurisdiction?s authority to conduct inspections, specifically the jurisdictions compliance with legal/regulatory considerations that govern the stopping and holding of vehicles and drivers. 4. The significance of the inspection as evidentiary documentation of violations, or the lack thereof, as identified during the inspection process. 5. In the specific case of Level V inspections, the fact that inspections should only be done on vehicles on the ?ready line awaiting dispatch? or ?vehicles not slated for maintenance.? 6. The lead member jurisdiction?s authority to mandate specific minimum requirements for partner agencies in regards to inspection selection policies to ensure a uniform selection process within that jurisdiction. 7. Internal business processes or procedures that ensure that inspectors, and/or sister jurisdictions, are compliant with inspection selection policies, including training and penalties/disciplinary measures for non-compliance. 8. The importance of the processes by which data is collected. 9. A consistent and uniform inspection selection process and the analysis and understanding of how such processes impact end uses of data. 10. The importance of distinguishing between the ?screening process? related to observed conditions that trigger inspections and the performance of the inspection itself.