Approaches to Data Collection

The following three dichotomies were considered to facilitate decisions regarding the different approaches for development of such a database:

 Voluntary versus mandatory data reporting.

 An extension of Form DOT F 5800.1 versus a new program.  Government-sponsored versus industry-sponsored program.

4.7.1 Voluntary Versus Mandatory Data Reporting

4.7.1.1 Voluntary Data Reporting

In this approach companies transporting hazardous material(s) would decide whether or not to participate in the data reporting process. There could be guidelines or incentives but the decision to participate would be strictly voluntary. By its nature, voluntary reporting results in self-selection which might introduce some biases into the dataset that could be difficult to account for during data analysis. Voluntary reporting may be successful if incident information cannot be traced back to the individual or company because concerns about possible repercussions regarding the accident would be minimized. Individuals or companies submitting voluntary reports would need to recognize sufficient value from participation in the program. If the program was augmented by incentives such as an improved federal safety rating, the perceived value of participation might be enhanced. A successful voluntary program in which there was substantial stakeholder participation with a

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large number of high-quality reports could offset the uncertainty related to the self-selection bias. Furthermore, a successful program might result in greater accuracy in the submitted data because of the vested interest of the contributors.

4.7.1.2 Mandatory Data Reporting

Mandatory data reporting would involve a statutory or regulatory mandate that requires certain information to be reported to an organization that would compile and manage the database. Since the approach is mandatory, the vested interest of individual contributors may be lower; therefore, efforts to ensure compliance would be required. Providing incentives would encourage contributors to increase data accuracy and improve compliance. A successful mandatory program would have near 100% reporting with high accuracy, resulting in a bias-free analysis.

4.7.2 Extended Form DOT F 5800.1 Versus New Program

4.7.2.1 An Extension of Form DOT F 5800.1

The Form DOT F 5800.1 records approximately 70 percent of the information identified as necessary to evaluate bulk package accident performance and estimate

component-specific conditional probability of release. In order to increase the capability of Form DOT F 5800.1 to calculate bulk package performance, the following additional fields would need to be recorded:

 Bottom accident damage protection.  Rollover accident damage protection.  Presence of jacket.

 Jacket material.  Jacket thickness.  Insulation type.

 Type of damage (replaces “Type of Failure” in Form DOT F 5800.1).  Whether the type of damage sustained resulted in failure.

 Damage location (on the bulk package).

 Damaged components (replaces “What Failed” in Form DOT F 5800.1).  Whether the damage sustained by the component resulted in failure.

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In order to calculate various conditional probabilities, these new data fields would also need to be linked to crash reports in PHMSA’s HMIRS database. An extension of Form DOT F 5800.1 may be desirable as it would minimize the additional burden on individuals and companies required to file reports. However, this option does not address carrier and shipper concerns about data confidentiality and the improper use of data and analyses in ways that could harm contributors. This might influence the degree of candor in reporting. One possibility that may enable the collection of additional data while

maintaining the current level of reporting is the development of a possible “no-fault” appendix form, specific to the highway mode. This form could be used to collect additional data to describe the results of a root-cause analysis and the tank damage observed as a result of crashes. Using a “no-fault” form would protect against improper use of data and analyses in ways that could harm contributors.

4.7.2.2 New Program

In contrast to an extension of Form DOT F 5800.1, a new program could be set up to independently collect all the information necessary to compute the conditional probability of release. If not linked to PHMSA’s HMIRS database, the anonymity of reporting could be preserved if the new program only collects information related to accident damage and not accident identification information such as date, time, location (of accident), and

carrier/shipper information. Furthermore, a new program may have more flexibility in terms of adding or removing information fields in the future.

4.7.3 Government Versus Industry Sponsored

4.7.3.1 Government Sponsored

In a government-sponsored program, either agency staff or a contractor would develop and manage the database. Such a program could be subjected to Freedom of Information Act requirements and may be less flexible to changes but would have the stability and resources of a government program.

4.7.3.2 Industry Sponsored

In an industry-sponsored approach, data would be collected and housed by an industry association, a consortium of industry associations, or by a contracted private firm, research organization, or university. Industry would decide how to respond to requests for

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data analyses, including requests from government agencies. An industry group or consortium could hire a contractor to collect, compile, and analyze additional information from different sources such as police accident reports. Since this approach relies on industry funding, the value of such a database would need to be accepted by the majority of industry potential participants. Such an approach may result in greater potential anonymity because procedures and policies can be implemented to protect the information against the improper use of data and analyses in ways that harm contributors.