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Should smaller commercial trucks be subject to safety regulations?

Abstract

Motor-carrier safety is a critical and challenging issue in the US motor-carrier industry. Despite the vast safety improvements in the industry, a continuing challenge is the economic costs associated with regulatory oversight of safety inspection programs. The purpose of this article is to compute the costs and associated benefits of the Federal Motor Carrier Safety Administration's driver and vehicle inspection program of commercial motor vehicles in the 10,001- to 26,000-lb category. Our analysis reveals that for every dollar spent in program costs, the benefits are $8.86.

Keywords

Motor-carrier safety, small trucks, Federal Motor Carrier Safety Administration, cost benefit ratio

Introduction

While motor-carrier crashes have declined over time, they still entail significant economic and social consequences. There is a record of fatal large truck (trucks with gross vehicle weight greater than 10,000 lbs) crashes along with truck crashes involving injuries beginning in 1975 for fatal crashes and 1989 for injury crashes as maintained by the National Highway Traffic Safety Administration. This record shows a dramatic decline in both truck crash rates from the beginning of the time series compared with its end point in 2009. In 1975 there were 4.9 large trucks involved in fatal crashes per 100 million vehicle miles traveled (VMT). The truck fatal-crash rate peaked in 1979 with 5.6 large trucks involved in fatal crashes per 100 million VMT--one year prior to the passage of the Motor Carrier Act (MCA) of 1980. The truck fatal-crash rate, however, fell to 1.1 large trucks involved in fatal crashes per 100 million VMT in 2009--a dramatic decline of 77.6 percent since 1975 (FMCSA 2011). Equally spectacular is the decline in the truck injury crash rate. In 1989 there were 77.2 large trucks involved in injury crashes per 100 million VMT. This rate fell to 18.5 large trucks involved in injury crashes per 100 million VMT in 2009--a decline of 76.0 percent (FMCSA 2011).

Despite the significant observed declines, there is a continuing challenge for the Federal Motor Carrier Safety Administration (FMCSA) to reduce truck and bus crashes and lessen the economic costs associated with them. An FMCSA-sponsored study by Zaloshnja and Miller (2007) estimated the cost of a single fatal crash at an average of $3.6 million in 2005 dollars or $4.17 million in 2011 dollars. The estimates of the costs associated with a fatal crash include the following categories: medical costs, emergency services, property damage, lost productivity due to delays from the crash, and monetized quality of life-years lost based on a value of a life (Zaloshnja and Miller 2002). The economic cost from fatal crashes alone in 2010 amounted to over $16.4 billion on an annual basis. Accordingly, public policy regarding motor-carrier safety is an important domain.

At the present time, trucks with gross vehicle weight range from 10,001 to 26,000 lbs are subject to the Federal Motor Carrier Safety Regulations (FMCSR). As a result, the carrier/operator must register with the FMCSA and obtain an operating certificate. Its drivers must have annual physicals and medical cards. The hours-of-service regulations apply to its drivers, who must keep logbooks. The carrier/operator must keep vehicle maintenance logs. Its vehicles/drivers are subject to roadside inspections as well as compliance reviews. It should be noted, however, that drivers for carriers operating vehicles in this weight class are not required to obtain a commercial driver's license (Hummel Group 2011).

At various times, formal proposals to exempt these vehicles from federal regulations have been introduced. For example, HR 1757, proposed in March 2007, would change the federal definition of commercial motor vehicles to include only those that weigh more than 26,000 lbs. The bill's sponsor, US Rep. Dan Boren, D-Oklahoma, said the legislation would help Oklahoma farmers. "Oklahoma borders six other states, and our farmers often need to cross those state lines," Boren said. "I am hearing from farmers across my district who are already facing fines from these regulations that were never meant to apply to them in the first place" (Thomas Tribune 2007). Trucks with gross vehicle weight from 10,001 to 26,000 lbs include trucks in weight classes 3 through 6. Examples of trucks in these categories are the Ford Series trucks numbered F-350 to F-650.

The purpose of this investigation is to reexamine the current FMCSA programs and policies with respect to these vehicles. A specific objective of this article is to compute the costs and associated benefits of FMCSA's safety programs for truck vehicles in the 10,001- to 26,000-lb category. The primary FMCSA program with direct impact on the safe operations of vehicles in this class is the roadside inspection program and the associated traffic enforcement activities. FMCSA program costs include the direct costs associated with this program as well as the costs incurred by truck operators during the time the vehicles are being inspected. The benefits of the FMCSA program include savings from avoided crashes as a result of violations found during the inspections of these vehicles and the subsequent correction of the violations. The underlying assumption is that if roadside inspections detect vehicles with defects and/or driver problems, and prevent the continued operation of defective vehicles and/or drivers from continuing to operate their vehicles under fatigued conditions or under the influence of alcohol or drugs, a certain number of crashes will be avoided.

This article will next provide an overview of the FMCSA's program of roadside inspections to monitor the safety performance of trucks and buses on the nation's highways. Included is a discussion of methodologies to assess how these monitoring efforts impact truck safety. Specifically, there is an underlying connection between the detection of safety violations and the avoidance of truck crashes. The article then presents both the costs to enforce the FMCSA regulation on vehicles in the 10,001-26,000-lb category, and the benefits derived from the enforcement of the FMCSR on vehicles in this weight class. In our final section, we discuss the overall benefit-cost ratio of the current regulation of vehicles in this category and also provide study limitations, evidence on inspection performance for small versus larger trucks, and policy options.

Background: FMCSA's Roadside Inspection Program and Its Estimated Impact through Avoided Crashes

One mainstay FMCSA program to monitor and regulate the operations of motor trucks involves roadside inspections of trucks at fixed and random inspection sites across the country. During a roadside inspection, federal and/or state inspectors evaluate the vehicle and driver's compliance with the FMCSR (49 Code of Federal Regulations, 300-399). Roadside inspections have a driver aspect, a vehicle aspect, or both a driver and vehicle aspect. The scope of the inspections is determined by its level. A Level I inspection, labeled the North American Standard Inspection, includes an examination of both the vehicle and the driver. A Level II inspection is labeled a walk-around inspection that also includes an examination of both the vehicle and driver. However, the walk-around inspection includes only items that can be inspected without physically getting under the truck. A Level III inspection is a driver-only inspection, while a Level IV inspection is a onetime examination of a particular item, normally made in support of a study or to verify or refute a suspected trend. A Level V inspection is a vehicleonly inspection conducted without the driver present, usually at a terminal location, while a Level VI inspection is an enhanced inspection for radioactive shipments. In FY 2011, there were 1.144 million Level I inspections; 1.173 million Level II inspections; 1.163 million Level III inspections; 11,500 Level IV inspections; 105,132 Level V inspections; and 2,285 Level VI inspections (FMCSA 2011).

It should be noted that roadside inspections can be random events. However, the FMCSA provides its field inspectors with a computer program that assesses the risk profile of individual carriers, and targets certain carriers for increased inspection frequency on the basis of a carrier's past crash history/inspection performance. It should also be noted that roadside inspections can be conducted in association with a traffic enforcement activity. Thus, a truck might be stopped by a law enforcement officer for a speeding violation, and, once stopped, the vehicle and driver may be subject to a Level I or Level II inspection, although typically the officer would perform only a driver-only inspection in this instance.

The underlying premise is that roadside inspections of vehicles and drivers provide regulators with the opportunity to detect problems with vehicles and/or drivers. If these problems were left undetected, there would be an increased probability of a subsequent truck crash. The roadside inspection reduces by a finite amount the probability of a subsequent crash. Estimating the reduction impact of roadside inspections is the key to measuring the benefits associated with these inspections.

Previous studies have proposed methods to measure the crash reduction impact of FMCSA programs, in particular, the roadside inspection program. A seminal research effort by Moses and Savage (1997) calculated the benefits associated with several major FMCSA safety monitoring programs. For the purposes of this study, we focus on Moses and Savage's approach to calculating the benefits associated with the roadside inspection program. Moses and Savage estimated the number of crashes avoided through detection during roadside inspections of both vehicle and driver violations. Subsequently, by multiplying the total crashes avoided by a weighted average monetary cost of a truck crash with the weights determined by the distribution of crashes according to severity, they determined the total benefit of the roadside inspection program.

Moses and Savage used calendar year 1991 as the basis for their analysis. They converted the total number of "out-of-service" vehicle and driver violations discovered during roadside inspections into crashes avoided. In other words, they estimated the number of crashes that would have occurred if the driver and vehicle violations had not been detected during a roadside inspection and the vehicles and drivers had been allowed to continue operations with the identified violations left uncorrected.

As a first step in this process, Moses and Savage identified the number of inspections in 1991 involving out-of-service violations for vehicle and driver defects. Next, they estimated the crash reduction impact of each of the detected defects. They estimated from previously available engineering and postcrash inspections between a 6 percent and 11 percent crash reduction impact from brake defect detection, and a 2 percent crash reduction impact from other vehicle violations. On the driver side, they estimated that driver alcohol and drug violations had a 43 percent crash reduction impact, while other driver violations (primarily hours-of-service violations) had between a 3 percent and 4.3 percent crash reduction impact.

The next challenge for Moses and Savage was to identify a period of time during which the vehicle and driver would operate with the inspection-detected violations corrected. They consulted engineering research to determine that three months was an appropriate time for the benefits of corrected vehicle defects to be assumed, one year an appropriate time for the benefits of driver defects in the drugs-and-alcohol category to be assumed, and three months for the benefits from corrected driver hours-of-service violations to be assumed. Thus, they assumed that vehicles and drivers would operate without the detected violations during the identified time periods and experience reduced crash rates during this time.

With information on the violations detected during inspections, the crash-reduction factors associated with each violation, and the time period for post-inspection corrected operations, Moses and Savage could estimate the number of crashes avoided as a consequence of the roadside inspection program. They distributed the vehicle and driver violations identified during roadside inspections during calendar year 1991 across all carriers divided into groups on the basis of their annual fleet miles. Thus, for carriers in the 50 million or more annual vehicle mile category, the average annual vehicle had 23,000 annual miles and 3.19 crashes per million miles of operation. Obviously, carriers with fewer annual fleet vehicle miles had lower average annual vehicle miles.

For each violation detected during an inspection, Moses and Savage calculated the number of miles the vehicle would operate under corrected conditions based on the time windows discussed above. Vehicles operating with a corrected defect would experience a crash-rate reduction based on the reduction factors associated with the specific defect. Thus, for the carrier size group of 50 million or more annual vehicle miles, a driver alcohol violation during a roadside inspection would result in 12 months of corrected operations, or 23,000 miles at a crash rate 43 percent below the unadjusted rate of 3.19 crashes per million miles of operation. Using this method across all vehicle and driver violations detected during roadside inspections and distributed across all the carrier size categories provided estimates of the crashes avoided as a consequence of the roadside inspection program. Moses and Savage then estimated an average crash cost based on a distribution of crashes across severity levels (i.e., fatal crashes, injury crashes, and tow-away crashes). Applying an average crash cost to the estimated avoided crashes enabled the authors to calculate an upper-bound program benefit estimate of $219.8 million and a mid-range benefit estimate of $151.5 million for the inspection program as a result of between 1,544 (upper-bound) and 967 (mid-range) avoided crashes.

However, these benefits do not consider the program costs, both to industry and to the government for program administration. When these factors are considered, the authors note: "Over 1.1 million interstate trucks a year are subjected to 30-minute inspections, and 310,000 are delayed for up to three hours while problems are corrected. Here the benefits exceed the costs by 26 percent under the most favorable assumptions regarding the number of accidents avoided, and the costs may exceed the benefits for more mid-range assumptions" (Moses and Savage 1997).

Costs to Enforce the Federal Motor Carrier Safety Regulations

This section details the costs to enforce the FMCSA safety regulations on CMVs in the 10,001-26,000-lb category. Costs to both the government and the trucking industry are examined. Government costs are the direct costs associated primarily with the roadside inspections conducted on vehicles in this weight class. The costs to industry are based on the loss of use (or opportunity costs) associated with the detainment of vehicles and drivers undergoing roadside inspections. The following pages provide a detailed discussion of the methods used to estimate costs for both the government and industry to enforce FMCSA safety regulations on vehicles in this weight category.

Costs to the Government

The cost of enforcing the FMCSRs is borne primarily by the FMCSA through motor-carrier compliance reviews conducted primarily by federal field staff, and driver and vehicle roadside inspections conducted primarily by state inspectors and paid for by federal grants under the Motor Carrier Safety Assistance Program (MCSAP). In 2009 there were 10,092 compliance reviews conducted, while there were 3.5 million roadside inspections. We have focused on the roadside inspection program, given its dominance as the cornerstone FMCSA program (Office of Freight Management and Operations 2012). Most of the enforcement dollar cost of regulating 10,00126,000-lb vehicles is a result of the roadside inspection of those vehicles. The following section will discuss the dollar costs to the government of roadside inspection enforcement of the FMCSRs.

Source of Information on the Cost of a Roadside Inspection

Nearly all roadside inspections are performed by the states. Therefore, they are in the best position to assess the costs of performing them. The states estimate and report cost information on their motor-carrier safety programs in state commercial-vehicle safety plans (CVSPs). These plans are prepared annually and submitted to the FMCSA in conjunction with the MCSAP grant program. The plans contain financial data summarized by "National Program Element," including "Driver/Vehicle Inspections." The 2009 plans were obtained for this study. These data provide the means to derive the average cost of an inspection to the government.

Each state CVSP follows a prescribed format that includes a "Financial Management" section with a "National Program Element Budget Summary." This summary contains the estimated expenses and projected number of activities by program element in a table that includes a "Driver/Vehicle Inspections Program Element." An example of a FY2009 National Program Element Budget Summary can be found in table 1.

For this investigation, 2009 CVSPs were obtained for 46 states and the District of Columbia. For each state the program element budget summary was used to calculate the average cost of a vehicle/driver inspection by dividing the "Estimated Expenses" by the "Projected Number of Activities." For example, in the hypothetical sample shown above, the average cost of an inspection would be $100.00 ($4,000,000/40,000). Considerable variation was found in the average cost of an inspection among states. It is presumed that this is due primarily to the methods employed to conduct the inspections (fixed site vs. mobile or roadside in conjunction with traffic enforcement), the mix of the level of inspections conducted (Level I full inspections take on average twice as long as Level III driver-only inspections), and the personnel used to conduct the inspections (noncommissioned state employees vs. state highway patrol officers). For example, costs are considerably lower for inspections performed at fixed sites performing mainly Level III (driver-only) inspections using noncommissioned state employees than for inspections performed by state highway patrol officers conducting inspections at the roadside in conjunction with traffic enforcement. In spite of this variation, the CVSPs provide the single best source of cost data, since they reflect the states' best estimates of costs that reflect the mix of the types of inspections that they do and using the inspection methods and personnel that they employ. Finally, another factor that may influence variability in the cost of an inspection between states is the state's interpretation of the FMCSA guidelines specifying what costs are to be included, particularly with regard to overhead costs.

The following results were obtained by summarizing and averaging the Driver/Vehicle Inspection Program element for the 47 state reports that were obtained. The average cost of an inspection was calculated to be $65. Previously it was estimated that the number of 10,001-26,000-lb vehicles that were inspected in 2007 is 505,006.* By using the average cost of an inspection and the estimated number of 10,001-26,000-lb vehicles that were inspected, the annual cost to the government of performing inspections on 10,001-26,000-lb vehicles is estimated to be $65 x 505,006 or approximately $32.8 million.

Cost of Regulation to the Motor-Carrier Industry

The cost of FMCSA regulation of 10,001-26,000-lb vehicles to the industry cannot be measured by budgeted program expenditures as is the case with the costs to the government. Motor carriers do not budget for and pay to be regulated directly, but do incur costs associated with recordkeeping, audits, and roadside inspections. Of these costs, most are the opportunity costs stemming from the loss of travel time spent during roadside inspections. Therefore, the focus of the estimation of industry costs will be on the opportunity costs related to roadside inspections. The costs to industry of taking remedial action as a result of any violations detected during the inspections are not included in the analysis, given that the detected violations would need to be corrected regardless.

Approaches to Estimating Industry Roadside Inspection Costs

Since opportunity costs from roadside inspections are not direct out-of-pocket expenditures or charges, they must be estimated based on the loss of productivity related to detaining the driver and vehicle. In the case of for-hire carriers this removal results in a reduction in "revenue miles" that could have been traveled if the driver and vehicle were not detained. In the case of private carriers, the delays resulting from roadside inspections also have opportunity costs associated with taking the driver and vehicle off the road. Wherein private fleets do not generate reported "revenue miles," they do have measurable expenses to the business that are associated with the driver and vehicle and the operations of their fleet.

Measurement of the costs of roadside inspections to the industry differs between for-hire and private carriers because of differences in the purpose of their operations and, therefore, the associated "opportunity costs" that result from detaining the driver and vehicle. In the case of for-hire carriers, costs will be based on "lost" potential revenue miles. The use of revenue miles to estimate costs to the for-hire carrier takes into account not only the direct costs of detaining the vehicle and driver, but also the "lost" profit from their primary business when the vehicle is not on the road. In the case of private carriers, only the expenses of operating the vehicle are counted, since transportation is only a cost to the business and does not generate profits. For-hire carriers not only must recover their expenses, but also must generate profit from their motor-carrier operations.

For-Hire Carrier Costs

As was explained above, the costs to the industry differ between motor carriers that derive their income from their vehicles and drivers (for-hire carriers), and those that operate vehicles in conjunction with their main business (private carriers). When a for-hire carrier's vehicles and drivers are detained for roadside inspections, the total cost can best be reflected by estimating the collective potential revenue that could have been earned had the vehicles not been detained. In other words, the inspections reduce the availability of the vehicles for the time of the inspections, thus reducing potential revenue miles traveled. Therefore, in order to estimate the costs of roadside inspections to for-hire carriers, an industry average revenue per mile and the estimated miles not traveled as a result of a roadside inspection are needed.

The Census Bureau conducts an annual sample survey of the for-hire motor-carrier industry to provide national estimates of revenue, expenses, and vehicle-fleet inventories for the commercial motor-freight transportation and public warehousing service industries. The US Code, Title 13, authorizes this survey and provides for mandatory responses from companies with employment that provide commercial motor-freight transportation and public warehousing services--Standard Industrial Classification (SIC 42). Data collected include operating revenue and operating revenue by source; total expenses and expenses by type; percentage of motor-carrier freight revenue by commodity type, size of shipments handled, length of haul, and shipments' country of origin and destination; and vehicle-fleet inventory. The survey has been conducted annually since 1985. Reported data are for activity taking place during the prior calendar year. A mail-out/mail-back survey of some 2,500 selected firms and employer identification numbers (EINs) is used. The sample is drawn from a list of employers contained on the Standard Statistical Establishment List which contains all EINs and locations of establishments for listed businesses. An EIN may represent one or more establishments and firms with payroll may have one or more EIN. Firms are stratified by total revenue size and kind of business using data from the latest census of transportation. All firms with total revenue above applicable-size cutoffs are included in the survey and report for all their industry EINs. In a second stage, unselected EINs are stratified by kind of business and revenue, and a simple random sample is taken from each stratum.

According to estimates from the survey, US commercial trucks in 2007 traveled 94 billion miles and generated $214 billion in revenues from motor-carrier operations. Therefore the average revenue per mile was $2.28 ($214 billion/94 billion miles).

Private Carrier Costs

Private carriers operate their vehicles for their own business (e.g., transport their own products to markets) as opposed to for-hire motor carriers that use their vehicles to perform services or transport good for others for profit. When a private carrier's vehicle is detained for a roadside inspection, the cost to the business is lost availability of the driver and vehicle. The value to the private operator of the lost availability can be represented by the cost to operate it. That cost is the expense per mile to operate its fleet. The Census Bureau's Annual Survey of Transportation that collected revenue and miles also collected expenses. Although the expenses are related to transportation companies (for-hire carriers), the expenses are assumed to be similar for private-fleet operations. Using these data, an average expense per mile can be derived and applied to estimate the private carriers' costs. This is conceptually the same as the revenue per mile (less the profit part of the revenue) used to calculate the cost of inspections to for-hire carriers. The Census reported truck transportation expenses of $208.5 billion in 2007. When this figure is divided by the 94 billion miles traveled the average expense per mile is $2.22 ($208.5 billion/94 billion miles).

In order to arrive at vehicle miles lost due to an inspection, data are needed on the average amount of time per vehicle inspection multiplied by the average speed of the vehicle. We obtained this data by first identifying the nine carriers who accounted for the greatest number of roadside inspections of vehicles in the 10,001-26,000-lb category. We contacted these carriers by mail to obtain estimates of the average time a vehicle is detained during an inspection of driver and vehicle. This time not only includes the time spent by the inspector but any additional "wait time" before the inspection and recordkeeping entries made by the driver after the inspection. A consensus of 45 minutes (3/4 hour) was obtained. Since nearly all inspections occur on a highway location, the average highway speed the vehicles would have traveled if not detained by the inspection is estimated to be 60 miles per hour. By combining the average time spent in an inspection (3/4 hour) and an average speed that would have been traveled were the vehicle on the highway (60 miles per hour), the miles lost due to the inspection is estimated to be 45 miles.

Using the averages obtained above, the opportunity cost is the lost miles (45) times the average expense per mile of $2.28 or approximately $102.60 (including lost profit) for the for-hire carrier. Since profit from motor-carrier operations is not a consideration, the cost of an inspection is somewhat lower for a private carrier than for a for-hire carrier. The cost of an inspection for a private carrier is the lost miles (also 45) times the expenses per mile of $2.22 or $100.

Total Cost to the Industry

The cost to the motor-carrier industry of regulating 10,001-26,000-lb vehicles is primarily due to the lost miles traveled (opportunity costs) stemming from detaining drivers and vehicles at roadside inspections. Based on FMCSA inspection data, it is estimated that in the year 2007 there were a total of about 505,000 roadside inspections of 10,001-26,000-lb vehicles. Of these 64 percent or 323,000 inspections were estimated to be private-carrier vehicles and 36 percent or 182,000 inspections were estimated to be for-hire-carrier vehicles. The cost to the motor-carrier industry of roadside inspections is then the average expense per inspection of $100 times 323,000 (the number of private-carrier inspections) or $32,300,000 plus the average expense per inspection of $102.60 times 182,000 (the number of for-hire-carrier inspections) or $18,670,000. The total cost to the industry in 2007 is then estimated to be $32,300,000 + $18,670,000 or $50,970,000.

The estimate of cost to the industry of $50,970,000 is based on average expense and average revenue per mile derived from the Census Bureau survey of transportation companies. Since these companies are largely for-hire operations and operate large vehicles for profit, the average expense and average revenue per mile are probably greater than would be the case for 10,001-26,000-lb vehicles that are the focus of this study. Also, various industry sources place the average expense and average revenue per mile as low as approximately one half of the census figures. However, that being said, the industry sources generally only included marginal operating costs of the vehicle and did not account for the driver's time or fleet overhead expenses. Further, there is considerable variability in costs by type of operation, commodity carried, length of haul, and origin and destination of shipment. Therefore, the estimated cost to the industry of $50,970,000 in 2007 should be considered as the high end of a likely range of values that can vary considerably by operation.

Benefits from Enforcing the Federal Motor-Carrier Safety Regulations

To estimate the monetary benefits associated with the FMCSR on 10,00126,000-lb vehicles, we employ the "Intervention Model" developed by the Volpe Transportation Systems Center. Initially we describe the roadside inspection program as the source of the benefits. Next, we explain in detail the methodology used to translate the inspection activity of the roadside program into monetary benefits as a result of avoided crashes.

Safety Benefits from Roadside Inspections

One key component of the FMCSA's overall agenda to improve the safety of truck operations on the nation's highways is the Roadside Inspection Program. As discussed previously, on an annual basis an estimated 505,006 trucks in the 10,001-26,000-lb category are subject to these inspections as they operate on the nation's highways. The roadside inspections have both driver and vehicle aspects and have different levels of intensity. They range from a Level I (North American Standard Inspection), involving both the driver and vehicle, to a Level III, involving the driver only, to a Level V, focused solely on the vehicle (Volpe 2007a).

The calculation of the benefits associated with roadside inspections requires the key underlying assumption that roadside inspections by themselves constitute interventions that effectively prevent the occurrence of a crash that might have resulted in the absence of the inspections. Indeed, during the roadside inspections violations of safety regulations are detected. Some of the most common types of out-of-service violations involve the vehicle: brakes (defective and out of adjustment), excessive tire wear, inoperable lights, and oil-and-grease leaks. On the driver side, the most common out-of-service violations involve logbook violations and hours-of-service violations (FMCSA 2007b). Each of these violations contains a certain crash risk element, for instance, if the drivers continued on their trips without correcting the underlying causes of the violations, there would be an increased possibility/likelihood of a crash resulting. Thus, the intervention and detection of violations during roadside inspections reduces the likelihood of future crashes (Moses and Savage 1997).

A key objective is to develop quantitative measures of the benefits associated with roadside inspections in terms of crashes and injuries avoided and lives saved as a direct result of detecting violations during the inspections. The Volpe Transportation Systems Center has developed "The Intervention Model" to estimate the benefits in terms of crashes and injuries avoided and lives saved as a consequence of roadside inspections (Volpe 2007a, 2009). A description of the model in more detail is followed by an application of the model to estimate the annual benefits associated with the approximately 505,000 inspections of vehicles in the 10,001-26,000-lb category.

Methodology

The application of the Intervention Model relies on estimating a crash risk reduction factor for each violation found during a roadside inspection. (2) The crash risk reduction factor for each violation represents "the finite probability associated with the inherent potential of each violation to contribute to a truck crash" (Volpe 2009).

The overall estimation approach involves two steps. First, a crash risk is estimated for each violation group (individual violations are grouped into like categories as part of the methodology). The violation groups are organized into subcategories of the Behavior Analysis and Safety Improvement Categories (BASICs). Thus, for example, under the unsafe driver BASIC, subcategories are defined: careless driving, reckless driving, speeding, hazardous material-related violations, and other driver violations. A "crash risk is defined as the likelihood that the unsafe behavior associated with the violation group contributes to a crash during a truck daytrip, which is defined as a truck's travel during one day." The second step is "to determine the duration of the reduction in crash risk when a violation is recorded" (Volpe 2009).

According to the methodology, roadside inspections intercept "noncrash daytrips." These interventions reveal any violations associated with the drivers and/or vehicles subject to inspection. Truck daytrips resulting in a crash are subject to postcrash inspections during which any violations that existed prior to the crash are recorded. "Noncrash daytrips intercepted in roadside inspections and traffic enforcements and their violations are considered to be a representative sample of all noncrash daytrips, and crashes undergoing postcrash inspections and their violations are considered to be a representative sample of all crash daytrips" (Volpe 2009).

The approach requires a calculation of the number of truck crashes that involved the presence of each violation group at the time of the crash divided by the total number of postcrash inspections to "produce the frequency of the occurrence of the violation group in postcrash inspections." Further, according to the Volpe methodology: "This (percentage) was multiplied by the total number of crashes during the same time period to produce an estimate of the number of crash daytrips exhibiting the unsafe behavior associated with the violation group" (Volpe 2009). This product, the estimated number of crash daytrips with each particular violation group, is labeled C.

The next step is to calculate the number of noncrash daytrips with the presence of each violation group. The Volpe approach uses the

frequencies of (each) violation group uncovered in non-crash inspections ... [to] represent the frequencies of unsafe behaviors associate with [each] violation group occurring in noncrash daytrips. Using four years of the Motor Carrier Management Information System (MCMIS) data, the number of times [each] violation group was recorded in noncrash inspections was divided by the number of noncrash inspections to produce the frequency of the occurrence of [each] violation group in noncrash inspections. (Volpe 2009)

Subsequently, the Volpe model required estimates of the number of noncrash daytrips. Volpe developed this estimate using Federal Highway Administration (FHWA) data on the annual total number of miles driven by trucks in the United States, data from an FHWA-sponsored safety study of the mean number of miles driven per day (miles per daytrip) by shorthaul trucks, and an estimated developed by the Volpe Center of the number of daily miles driven by long-haul trucks. "The total number of miles was divided by the mean daily miles per truck to obtain the total number of truck daytrips. The estimate of the number of crash daytrips was subtracted from this to produce the number of noncrash daytrips" (Volpe 2009). For a last step, "the frequency of occurrence of each violation group in noncrash inspections is multiplied by the total number of noncrash truck daytrips to yield an estimate of the number of noncrash daytrips exhibiting the unsafe behavior associated with the violation group" (Volpe 2009). This is labeled as [S.sub.j] in the model.

Thus, the estimated crash risk for each violation group is the likelihood of a crash given the presence of each violation group ([L.sub.j] = [C.sub.j]/([C.sub.j]. + [S.sub.j])). In fact, "the recording of each violation group j during a roadside inspection or traffic enforcement reduces the risk of a crash by [L.sub.j] for the remainder of the daytrip, at a minimum" (Volpe 2009).

The second component of the methodology is to determine the duration of the reduction in crash risk when a violation is recorded (D.). This time period varies from several days to as long as 90 days, given an alcohol or drug-use violation. The overall estimated crash risk reduction due to violation group (j) is calculated as follows: [CRR.sub.j] = [L.sub.j] * [D.sub.j]. The factor [D.sub.j] is measured in days based on the violation group.

The duration of crash risk reductions ranges from 7 days (some equipment-defect categories) to up to 90 days (for drug and alcohol violations). The Volpe methodology provides an extensive discussion of the justification for the specific crash risk reduction durations chosen. The risk reduction duration for a controlled substance and alcohol violation is assumed to be 90 daytrips. The Volpe methodology notes: "The minimum driver's license suspension in all states for such a violation is 90 days. By using 90-day duration in the Intervention Model, it is assumed that a sober driver performs the trips the cited driver would have performed for the duration of the suspension" (Volpe 2009).

Regarding vehicle maintenance violations, the Volpe methodology maintains that "for a vehicle maintenance violation involving aspects of a vehicle that can be observed in a walk-around, the duration is assumed to be 7 daytrips. For other vehicle maintenance violations that require a more thorough inspection, the duration is assumed to be 37 daytrips.... These durations represent inspection intervals recommended by vehicle maintenance groups, such as the Transportation Services Division of Maryland's Department of Public Works and Transportation; Edmunds, Inc. a vehicle buyers' service; and the Boom Truck Resource Center" (Volpe 2009).

Finally, the methodology suggests that "the duration of violations in the driver fitness basic is assumed to be the mean time between Commercial Vehicle Safety Alliance (CVSA) inspections. CVSA issues decals to commercial vehicles that pass safety inspections according to FMCSA and CVSA criteria. These decals exempt a vehicle from additional inspections for the remainder of the quarter in which it was inspected, or an average of 45 days. Assuming that a driver inspection would typically occur along with the vehicle inspection, a driver could operate for an average of 45 daytrips with a driver fitness violation that occurred immediately after an inspection before the violation was discovered in a subsequent inspection" (Volpe 2009). Table 2 provides a more detailed set of violations and the estimated duration of the crash risk reduction associated with each violation.

Once the methodology has estimated a crash risk reduction factor for each violation group, the calculation of crashes avoided as a consequence proceeds in the following manner. Initially, for each violation group, the number of inspections (in this application, the number of inspections in the 10,001-26,000-lb category) in which a violation from that group was recorded (on an annual basis) is multiplied by the crash risk reduction factor for that violation group to obtain a preliminary estimate of the direct effect crashes prevented annually due to that violation group.

Adjustments are made to this preliminary figure to account for the fact that a certain percentage of the detected violations in roadside inspections are not "corrected" subsequent to the inspection, and to reflect that when a particular violation group is combined in a single inspection with multiple violations, there is an increased risk of a crash (Volpe 2009). Specifically, in order to correct for the fact that not all detected violations are corrected, the Volpe researchers examined the inspection results from trucks and drivers undergoing a second roadside inspection within seven days of the first. The researchers used inspection data from a three-year period (2004-6) to identify all cases of second inspections within seven days of the first. The results showed that the correction rate across vehicle maintenance violations averaged 69.94 percent and the corresponding figure in the driver fitness violation category was 68.82 percent (Volpe 2009). The model also included a correct factor to capture the effect of multiple violations per inspection. This factor resulted from an analysis of the postcrash inspections and the number of incidences in which multiple violations were detected during postcrash inspections. The crash risk reduction factors in the model were multiplied by correction rate factors prior to the calculation of avoided crashes.

It is instructive to provide an example of the methodology. For example, there are an estimated 76,330 crashes involving out-of-adjustment brakes ([C.sub.j]) with an estimated number of 598,114,058 noncrash day trips with out-of-adjustment-brake violations ([S.sub.j]). Thus the estimated likelihood of a crash given a careless driving violation is .000128 ([L.sub.j] = [C.sub.j]/([C.sub.j] + [S.sub.j]). The crash reduction is assumed to be 37 daytrips (D.). Thus, the crash risk reduction is .004736 (CRR = [L.sub.j]*[D.sub.j]) for out-of-adjustment brakes. In FY 2007, there were 164,650 out-of-adjustment-brake violations detected during inspections (all inspections, all weight classes). Thus, on a preliminary basis 777.4 crashes were avoided as a consequence of detecting out-of-adjustment brakes during roadside inspections. It is assumed in this case that the violation correction rate is 100 percent. If the violation correction rate were less than 100 percent, we would multiply the preliminary crashes avoided by the percentage corrected to arrive at a reduced estimate of avoided crashes. Finally, we multiply the adjusted estimate by a factor to account for the effect of multiple violations per inspection (1.027) to provide a final estimate of crashes avoided.

Estimate of Avoided Crashes

The Volpe Transportation Systems Center conducted a special run of the Intervention Model for this project. The Intervention Model was applied to all nonhazardous materials, nonpassenger inspections involving CMVs in the 10,001-26,000-lb category during FY2007. In total, there were 212,043 inspections during FY2007 of vehicles in the 10,001-26,000-lb category. There were approximately 750,000 inspections of vehicles in the 26,001-lb and above category during FY2007. However, a number of the inspections do not include information on vehicle weight. In fact, there is no information in the vehicle weight field for 58 percent of the inspection records. If we assume that the CMVs in the 10,001-26,000-lb category constitute the same percentage of inspections without weights recorded as they do of inspections with weights recorded, the estimated total number of inspections on vehicles in the 10,001-26,000-lb category is 505,006. We must make the further assumption that the pattern of violations observed in these additional inspections is the same as in the 212,043 small-vehicle inspections for which the vehicle weight was recorded.

Based on the application of the model and the total violations detected during the inspections, there were 3,882 crashes avoided as a result of roadside inspections conducted on CMVs in the 10,001-26,000-lb category. Of this total, there are 1,631 crashes avoided as a result of the 212,043 inspections for which there is vehicle weight data. The 3,882 crashes avoided estimate is based on an expansion factor of 2.38 applied to account for the set of inspections without vehicle weights. In fact, we know that CMVs in the 10,001-26,000-lb category account for 16.7 percent of the inspections for which there is weight data. If we assume that they account for 16.7 percent of the inspections with no weight data, then the total number of inspections for CMVs in the 10,001-26,000-lb category is 505,006.

An analysis of crash data for 2007 reveals that the following distribution applies to crashes involving CMVs in the 10,001-26,000-lb category: crashes involving bodily injuries (30.83%); crashes involving fatalities (2.07%); and tow-away crashes (no injuries) (67.10%). If these percentages are applied to the 3,882 crashes avoided, the following are the estimates of the crashes avoided by severity type. There are 1,197 injury crashes avoided; 80 fatal crashes avoided; and 2,605 property-damage-only crashes avoided in FY2007.

Cost Savings Benefits from Avoided Crashes

The safety benefits from inspections of 10,001-26,000-lb vehicles were estimated in the section above. That is, using 2007 inspection data and the Intervention Model there were an estimated 2,605 crashes with no injury avoided, 1,197 crashes with injury avoided, and 80 crashes with fatality avoided in 2007. In order to estimate the dollar cost savings resulting from these avoided crashes, an FMCSA-commissioned study on the costs of medium- and large-truck crashes "Unit Costs of Medium and Heavy Truck Crashes" was used (Zaloshnja and Miller 2007). This study provides the latest estimates of unit costs for highway crashes involving medium/heavy trucks by severity. Crash costs are broken out by truck type and severity of the crash including no-injury crashes, crashes with nonfatal injuries, and crashes with fatality. The injury costs represent the present value, computed at a 4 percent discount rate, of all costs over the victims' expected life span that result from a crash. They include medically related costs, emergency services costs, property damage costs, lost productivity, and the monetized value of the pain, suffering, and quality of life that the family loses because of a death or injury. As expected, fatal crashes cost more than any other crashes. The cost estimates exclude mental health care costs for crash victims, roadside furniture repair costs, cargo delays, earnings lost by family and friends caring for the injured, and the value of schoolwork lost.

Table 3 from the published study broke out the study findings by truck type and severity of the crash. The crash costs by severity for "straight truck, no trailer" are used to estimate the cost savings resulting from crashes avoided due to inspection of 10,001-26,000-lb vehicles. The costs per crash for the "straight truck, no trailer" category (10,001-26,000-lb vehicle) from table 4 are also depicted below. Using these crash costs and the estimates of crashes avoided resulting from 2007 inspections of 10,001-26,000-lb vehicles, the total annual cost savings benefits in 2008 dollars can be seen in table 4.

With an estimated cost savings from inspections of CMVs in the 10,001 26,000-lb category of $742.5 million, we can calculate an overall benefit cost ratio from the FMCSA program of regulations for vehicles in this class. With the current program costs to government and industry estimated at $83.8 million, the overall benefit-cost ratio is 8.86. That is, for every dollar spent in program costs, there are $8.86 in benefits.

Summary of Results, Limitations, Inspection Comparison for Small versus Large Trucks, and Policy Recommendation

Overall Findings

The main focus of this investigation has been to evaluate the resources expended to regulate CMVs in the 10,001-26,000-lb category versus the benefits obtained as a consequence of the regulatory efforts. The main benefits of the regulations are associated with crashes avoided as a consequence of violations detected during roadside inspections. This analysis has demonstrated that the benefit-cost ratio associated with the current FMCSA program of regulating CMVs in the 10,001-26,000-lb category is 8.86. That is, for every dollar of program cost (to government and industry), there is a return of $8.86.

Specifically, our analysis demonstrated that on an annual basis the FMCSA inspection program of CMVs in the 10,001-26,000-lb category avoided 3,882 crashes. This total included an estimated 1,197 injury crashes avoided; 80 fatal crashes avoided; and 2,605 property-damage-only crashes avoided. Based on cost estimates for crashes involving CMVs in this category, the estimated savings or benefits from the avoided crashes are $742.5 million annually.

Program costs involved costs for conducting the program as well as costs to the motor-carrier industry. The primary government costs involve the roadside inspection program. We estimated that on an annual basis these costs amount to $32.8 million. Measurement of the costs of roadside inspections to the industry differed between for-hire and private carriers because of differences in the purpose of their operations and, therefore, the associated "opportunity costs" that result from detaining the driver and vehicle. In the case of for-hire carriers costs are based on "lost" potential revenue miles. The use of revenue miles to estimate costs to the for-hire carrier takes into account not only the direct costs of detaining the vehicle and driver, but also the "lost" profit from their primary business when the vehicle is not on the road. In the case of private carriers, we include only the expenses of operating the vehicle. We estimated these costs for both for-hire and private carriers at $51.0 million on an annual basis.

In conclusion, this study suggests that significant safety benefits are derived from regulating 10,001-26,000-lb vehicles and that the roadside inspection of these vehicles is cost effective. Indeed, our estimates show a benefit of $8.86 per dollar of program costs.

It is important to explain why the Volpe methodology has a significantly more favorable cost-benefit ratio in comparison to the cost-benefit ratio cited earlier in the Moses and Savage study. First, there are significant differences in the two methodologies with the Volpe approach relying on detected violations during inspections and presence of violations in postcrash inspections to calculate crash risk reductions. Second, an FMCSA-sponsored crash cost estimation study, released in December 2006, resulted in significantly higher estimates of crash costs than were available at the time of the Moses and Savage work. Finally, some FMCSA roadside inspections are targeted to examine the trucks of carriers with the poorest safety records resulting in a higher incidence of detected defects.

Limitations

There are a number of limitations within the study methodology to be noted. First, the analysis includes neither costs nor benefits as a result of firms increasing their safety because of the threat of inspections. The inspection program may induce firms to take preemptive action, for example, fixing vehicle maintenance problems, which would both increase the costs of an inspection program and increase the safety benefits. Our approach does not include these effects, which are very difficult to operationalize and measure. Savage (2011) provides a theoretical perspective regarding how enforcement of such safety regulations can affect the broader market dynamic in ways such as this.

Second, the opportunity cost of inspections for for-hire carriers is assumed to be the foregone revenue, but this does not take into account other impacts of inspections. Idle trucks undergoing inspections have lower operating costs, so one could argue that the opportunity costs of inspections would be foregone revenue net of operating costs. The nature of driver pay agreements could impact this, for example, whether drivers are paid per mile or per hour, as well as how inspection time would affect hours-of-service limitations. Also, if an inspection only delays a delivery, it may mitigate the foregone revenue. Again, the established Volpe methodology does not address all of these nuances.

Third, the proposition that costs serve as the appropriate measure of the opportunity cost to private carriers of foregone truck and driver availability implicitly assumes that markets are highly competitive. This is a reasonable assumption for the trucking industry, but, to the extent that market imperfections exist, it constitutes another limitation of the study. Also, when looking at private trucking, we estimate the cost involved as the cost of the asset and driver times while undergoing inspection. In case of products, the true value may also include time and place utility with a topline impact as well as a cost dimension.

Fourth, the study does not address whether an exemption of under 26,000-lb trucks might increase inspections of over 26,000-lb trucks, with potential for safety benefits in that segment. Finally, our results are partially based on data that were estimated. As such, the validity of the results and conclusions are only as good as the assumptions and extrapolations from those estimates.

In sum, the established methodology is sound and captures the primary costs and benefits of exemptions, but data limitations prevent assessment of multiple secondary effects such as those discussed in this section.

Comparison of Inspection Results for Small versus Large Trucks

The cost-benefits analysis is consistent with a policy of maintaining regulations for smaller trucks. Additional insights can be obtained from comparing inspection results of commercial motor vehicles (CMVs) in the 10,001-26,000-lb range versus CMVs in the 26,001-80,000-lb range based on the reporting of violations of the FMCSR. The data included all roadside inspections conducted during calendar year 2008; the data source was the Motor Carrier Management Information System (MCMIS). Vehicle weight information is drawn from the MCMIS file, with vehicles included in the 10,001-26,000-lb category based on, where possible, the actual vehicle weight (with cargo). If the inspector records the vehicle's manufacturer's "rated weight," instead of the actual vehicle weight, we included vehicles with weights between 8,000-lbs and 26,000-lbs based on input received from state safety inspectors.

The analysis of roadside inspection data compared the performance of the two vehicle type categories by focusing on each category's rate of violation based on a number of indicators provided by the inspection data. Indicators focused on driver and vehicle out-of-service rates as well as rates of violations discovered for the primary BASICS as defined by the Comprehensive Safety Analysis (CSA) 2010 initiative within the FMCSA (Volpe 2008). More specifically, the first measure involved whether or not the individual inspection resulted in any driver out-of-service violation. The second through fourth variables involved disaggregation of the driver violations. Variable 2 looked at each inspection to see if any regulations in the fatigued driving category were violated (Fatigued Driving BASIC). Some examples of fatigued driving violations are violations of hours-of-service regulations, logbook violations, and operating a CMV while ill or fatigued. Variable 3 involved violations of driver fitness regulations (Driver Fitness BASIC). Examples of driver fitness violations include failure to have a valid and appropriate commercial driver's license and failure to have valid and up-to-date medical certificates. Variable 4 involved the use of controlled substances and/or alcohol (Controlled Substances and Alcohol BASIC). The violations in this category involve use or possession of controlled substances or alcohol. The fifth measure examined the inspection to determine if there were any vehicle out-of-service violations. Variables 6 and 7 disaggregate the vehicle variable into two subcategories: one deals with vehicle maintenance and the other deals with the loading of cargo in the vehicle. Vehicle maintenance (Vehicle Maintenance BASIC) involved the following types of maintenance violations: brakes, lights, and other mechanical defects. The seventh and final variable involves cargo loading (improper Loading/Cargo Securement BASIC). It includes unsecured loads, spilled cargo, and other unsafe handling of cargo.

Table 5 summarizes the differences in the safety performance between CMVs in the 10,001-26,000-lb rated weight category versus CMVs in the 26,001-80,000-lb rated weight category on the seven performance variables. For vehicles in the rated weight category of 10,001-26,000-lbs, there were 185,657 inspections in 2008. For vehicles in the rated weight category of 26,001-80,000-lbs, there were 610,958 inspections in 2008.

As an overview, the small CMV category (10,001-26,000-lb rated category) has a better performance in the vehicle performance categories than does the large CMV category (26,001-80,000-lb category). At most, this represents a 5 percentage point advantage for the small CMV category in terms of percentage of inspections with violations. Having noted this, it is important to emphasize that the violation rate in the small CMV categoiy is still approximately 20 percent (for the vehicle out-of-service measure). With respect to the driver performance category, the situation is somewhat reversed. The small CMV category has slightly higher (one to two percentage points) violation rates than does the large CMV category. Clearly, the overall indications point to the fact that there are substantive violations found during inspections of both small and large CMVs. These violations cover both driver and vehicle issues.

Policy Recommendation

The results of the benefit-cost model as well as the observed rate of violations associated with roadside inspections of CMVs in the 10,001-26,000-lb category provide significant justification for maintaining the current set of regulations on these vehicles. A policy option of total exemption of these vehicles from the FMCSRs does not seem warranted. We also reject a two-tier regulatory system for vehicles in the smaller weight class with fewer regulations applying to these vehicles. Besides introducing a cumbersome regulation selection process, our empirical results provide no justification for a lightening of the regulatory system for CMVs in the smaller weight category.

Overall, our recommendation, supported by the cost-benefit analysis and the violation rates of vehicles in the smaller weight category during roadside inspections, is to maintain the existing set of FMCSRs for vehicles in the 10,001-26,000-lb category.

References

Federal Motor Carrier Safety Administration (FMCSA). 2007a. "Commercial Vehicle Safety Plans (CVSPs)." https://www.fmcsa.dot.gov/documents/safetyprograms/2007model-CVSP-outline.doc.

--. 2007b. "Risk Assessment Methodology: Roadside and Compliance Review Regulations." Violation Severity Assessment Study, April, Washington, DC.

--. 2011. "Roadside Inspections by Inspection Level." http://ai.fmcsa.dot.gov/ Safety Program/spRptRoadside.aspx?rpt=RDBL.

--. 2012a. "Large Truck and Bus Crash Facts 2009." US Department of Transportation, FMCSA-RRA-11-025.

--. 2012b. "Compliance, Safety, Accountability (CSA)." http://www.fmcsa.dot.gov/ safety-security/csa2010/home.htm.

Hummel Group. 2011. Exceeding Expectations (Hummel Group newsletter), June, http:// www.taylor-ins.com/media/files/2011-06.pdf.

Moses, L. N., and I. Savage. 1997. "A Cost-Benefit Analysis of US Motor Carrier Safety Programs." Journal of Transport Economics and Policy 31 (1): 51-67.

National Highway Traffic Safety Administration. 2012. "National Center for Statistics and Analysis, Traffic Safety Facts 2009." US Department of Transportation, Washington, DC.

Office of Freight Management and Operations. 2012. "Freight Facts and Figures 2011." FHWA-HOP-12-002, pp. 54-55.

Savage, I. 2011. "A Structural Model of Safety and Safety Regulation in the Truckload Trucking Industry." Transportation Research E: The Logistics and Transportation Review 47 (2): 249-62.

Thomas Tribune. 2007. "Boren, Fallin Introduce Bill to Ease Restrictions on Farm Trucks." Thomas (Oklahoma) Tribune, April 5, 3. http://news.google.com/newspapers?nid=2i54&dat=20070405&id=7LAyAAAAIBAJ&sjid=Yw8GAAAAIBAJ &pg=2747,1069559.

Volpe Transportation Systems Center. 2007a. "Intervention Model: Technical Documentation." Prepared for the Federal Motor Carrier Safety Administration, Washington, DC.

--. 2007b. "Violations Severity Assessment Study." Final Report prepared for the Federal Motor Carrier Safety Administration, Washington, DC.

--. 2008. "Safety Measurement System (SMS) Methodology, Version 1.1, 2008." Prepared for the Federal Motor Carrier Safety Administration, Cambridge, MA.

--. 2009. "FMCSA Safety Program Effectiveness: Improvements to the Intervention Model Methodology." Prepared for the Federal Motor Carrier Safety Administration, Washington, DC.

Zaloshnja, E., and T. Miller. 2002. "Costs of Large Truck and Bus Involved Crashes." Federal Motor Carrier Safety Administration, US Department of Transportation, Washington, DC.

--. 2007. "Unit Costs of Medium and Heavy Truck Crashes." Final Report prepared for the Federal Motor Carrier Safety Administration, Washington, DC.

Thomas M. Corsi,

Corresponding Author

University of Maryland

Email: tcorsi@rhsmith.umd.edu

Curtis Grimm

University of Maryland

David Cantor

College of Business Iowa State University

Donald Wright

Volpe Transportation Systems Center

Notes

Authors received funding for this project from the Analysis Division, Office of Analysis, Research, and Technology, Federal Motor Carrier Safety Administration (FMCSA), Washington, DC. Authors take full responsibility for the research presented. All opinions expressed in this report are those of the authors and do not necessarily reflect the official position of FMCSA.

1. In total, there were 212,043 inspections during FY2007 falling into the designated category. However, a number of the inspections do not include information on vehicle weight. In fact, there is no information in the vehicle weight field for 58 percent of the inspection records. If we assume that the CMVs in the 10,001-26,000-lb category constitute the same percentage of inspections without weights recorded as they do of inspections with weights recorded, the estimated total number of inspections on CMVs in this category is 505,006.

2. Some roadside inspections are preceded by a traffic enforcement initiative. This methodology considers all roadside inspections, including those initiated through traffic enforcement actions.
Table 1/2009 National Program Element Budget Summary

National Program Element Estimated Expenses Projected Number
 of Activities

Driver/vehicle inspections $4,000,000 40,000
Traffic enforcement $400,000 2,000
Compliance reviews $600,000 500
Public education and awareness $600,000 500
Data collection $600,000 N/A

Table 2/Duration of Crash Risk Reduction for Selected Violations

Representative Violations Duration of Crash Risk Reduction
 (Day Trips)

Hours of service 30
False logs 30
Driver qualifications 45
Physical exam 45
Multiple licenses 45
Alcohol 90
Drugs 90
Brakes out of adjustment 37
Coupling devices 36
Steering mechanisms 37
Tires 7
Load securement 30

Source: Volpe 2009.

Table 3/Estimated Costs for Crashes Involving Straight Trucks, No
Trailer Category

Severity of Crash Estimated Crash Cost

No injury crashes/towaway $13,286
Crashes with injury $335,836 (a)
Fatal crashes $3,136,409

Source: Zaloshnja and Miller 2006.

(a) This is a weighted average calculated from the three injury
categories presented in table 2 of Zaloshnja and Miller's study:
"nonincapacitating injury," "incapacitating injury," and "injury,
severity unknown."

Table 4/Estimated Cost Savings from Crashes Avoided as a Result of
Roadside Inspection Program for Trucks in the 10,001-26,000-lb
Category

Severity of Crash Number of Cost per Total Savings
 Crashes Crash (in from Avoided
 Avoided 2008 dollars) Crashes

No injury/towaway 2,605 $14,349 $37,379,145
Crashes with injury 1,197 $362,724 $434,180,628
Fatal crashes 80 $3,386,933 $270,954,640
TOTAL $742,514,413

Source: Authors' calculations based on cost estimates provided in
table 5 adjusted to 2008 dollars.

Table 5/ Statistical Analysis of Inspection Data: Performance
Differences between CMVs in 10,001-26,000-lb Category and CMVs in
26,001-80,000-lb Category, 2008

 Number Fatigued Driver
 of Driver Driver Fitness
Vehicle Class Inspections Driver OOS (Basic) (Basic)

10,001-26,000 lbs. 185,657 0.090 0.054 0.037
26,001-80,000 lbs 555,252 0.080 0.056 0.027

 Substance and
Vehicle Class Alcohol Abuse

10,001-26,000 lbs. 0.003
26,001-80,000 lbs 0.001

 Number Vehicle Improper
 of Vehicle Maintenance Loading
Vehicle Class Inspections Vehicle OOS (Basic) (Basic)

10,001-26,000 lbs. 168,256 0.203 0.156 0.069
26,001-80,000 lbs 423,194 0.248 0.201 0.066

Source: Authors' calculations based on roadside inspection data, 2008.
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Author:Corsi, Thomas M.; Grimm, Curtis; Cantor, David; Wright, Donald
Publication:Transportation Journal
Date:Mar 22, 2014
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