Industry Experience

Several interviews were conducted with individuals having intimate knowledge of existing databases such as HMIRS, MCMIS, and TCAD. These interviews were conducted to determine potential challenges with data collection, understand how the data are analyzed, and gain insights into how the data could be used to enhance the industry’s safety

performance.

4.6.1 PHMSA’s Hazardous Intelligence Portal (HIP) Designers Interview

The Hazardous Intelligence Portal (HIP) is PHMSA’s current effort to provide a platform to collect and share hazardous material intelligence from several groups

representing different transport modes within the U.S. Department of Transportation. HIP currently collects data from 15 sources; and it is anticipated that additional sources will be incorporated into the portal in the future. This effort was undertaken to organize a dashboard-type view of key data regarding the multi-modal transportation of hazardous materials by company, enable comprehensive queries of data from multiple sources, and improve the prioritization and efficiency of inspections by regulatory agencies.

As part of this effort, HIP designers have worked closely with HMIRS data to update Form DOT F 5800.1. The main focus in updating Form DOT F 5800.1 is to increase data quality through both increasing data governance (only allowing acceptable answers) and replacing most freeform questions with drop-down list selection, yes/no, and

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check-box answers. They indicate that the main limitations for using the PHMSA data for risk assessment include:

 Insufficient commodity flow data to provide cargo tank exposure estimates (for which the incorporation of RFID tags on cargo tanks may be a solution).  Incorrect and incomplete damage reporting.

 Inability to correct for this inconsistent reporting because they do not investigate cargo tank (highway) accidents.

 Significant underreporting of accidents with no follow-up to ensure accidents have been reported after initial notification has been provided.

By contrast to their ability to determine standard industry injury and fatality rates, PHMSA is unable to determine baseline rates for tank damage and hazardous material spills.

Furthermore, based on their experience with the current database, PHMSA identified the following future potential challenges:

 Reconciling differences between and performing analyses on combined data from old and new versions of data-reporting forms.

 Transferring accident reports from paper to digital in which the inclusion of free- form answers introduces a significant amount of difficulty.

 Cleansing data so that new reports match previously submitted reports (again this typically arises with the presence of free-form answers).

4.6.2 FMCSA’s Hazardous Materials Division Interview

The interview with a representative of FMCSA identified the following two sources that will enable cargo tank exposure estimates:

 The Motor Carrier Identification Report (Application for U.S. DOT Number) (MCS-150) currently collects information including the annual number of miles traveled from 60,000 carriers who transport some quantity of hazardous materials.

 The Combined Motor Carrier Identification Report and Hazardous Materials Permit Application (MCS-150B) also collects information including the annual number of miles traveled from motor carriers who transport certain types of

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hazardous materials requiring a safety permit. Note that those carriers who have registered with the MCS-150B are a subset of all carriers transporting hazardous materials as some hazardous materials are not part of the HM Safety Permit program. For example, transporting liquid propane gas containing less than eighty-five percent methane does not require a safety permit.

 FMCSA’s Unified Registration System (URS) will replace the MCS databases and, in addition to the annual number of miles traveled, will include the quantity and type (type and specification number) of cargo tanks that a motor carrier uses. However, only carriers who transport cargo tank trailers and cargo tank motor vehicles will be required to list the quantity and type of tank. Carriers who transport portable tanks will not be required to identify the quantity and type of portable tanks they transport.

The interview also considered the possibility of local law enforcement officers providing much of the information needed for an accident damage database. Unfortunately there are not enough individuals with the appropriate training and the expertise to reliably enter accurate and consistent accident damage information in a report. For example, although there are approximately 33,000 police jurisdictions across the United States, only 7,500 to 10,000 state level motor carrier inspectors are trained through the motor carrier safety assistance program. Furthermore, additional training would be required to obtain basic hazardous materials bulk package knowledge and even fewer individuals have been trained to conduct post-crash root-cause analysis. Inspectors are typically not allowed to provide comments beyond their level of training; therefore, many would not be permitted to inspect the package. Consequently, the data required for an accident damage database would not be recorded unless a supplemental report was initiated. On the other hand, basic police reports may indicate that a cargo tank was involved and, if so, would include carrier

information. Thus, police report data could be used to identify those carriers who have had incidents and are required to submit Form DOT F 5800.1.

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4.6.3 RSI-AAR Tank Car Accident Database Feedback

Since 1970, the database has been periodically evaluated for its effectiveness in aiding the industry in achieving various improvements in the safety of hazardous materials

transportation by rail. The rail industry associations that sponsor that database indicate a savings of at least 11 times the cost of the implementation since inception. Periodic cost- benefit analyses have consistently indicated positive returns on investment in terms of improved safety and business operations. Furthermore, industry-managed database has contributed to a greater degree of trust in the industry and contributed to consensus in regulatory proposal development. Regulators have been provided with analyses using data recorded in the TCAD to assess the need for and nature of new regulations. This has resulted in more pragmatic, effective, and fact-based regulatory proposals.