OMB_package_supporting_statement for CISS FEB 2015 - Final A _GT

SUPPORTING STATEMENT

FOR

P.L. 89-663, Title 1, Section 106, 108, 112. - COLLECTION OF CRASH DATA

OMB Control Number: None

A. JUSTIFICATION

1. Explain the circumstances that make the collection of information, necessary. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the collection of information.

Motor vehicle crash information is collected to support the establishment and enforcement of motor vehicle regulations that reduce the severity of injury and property damage caused by motor vehicle crashes. The Department’s strategic goal that is supported is “safety, by working towards the elimination of highway safety related deaths, injuries and accidents”.

The National Highway Traffic Safety Administration (NHTSA), under the National Traffic and Motor Vehicle Safety Act of 1966 (Public Law 89-563, Title 1, Sec. 106, 108, and 112) (Attachment 1) is charged with the collection of crash data that support the establishment and enforcement of motor vehicle regulations that reduce the severity of injury and property damage caused by motor vehicle crashes. Crash Investigation Sampling System (CISS) will be the mechanism through which NHTSA collects nationally representative data on motor vehicle crashes.

1. Indicate how, by whom, and for what purpose the information is to be used. Indicate the actual use the agency has made of the information received from the current collection.

Crash Investigation Sampling System (CISS) data will be used to describe and analyze circumstances, mechanisms, and consequences of high severity motor vehicle crashes in the United States. These descriptions and analyses in turn will help to describe the magnitude of vehicle damage and injury severity as related to traffic safety problems. It will give motor vehicle researchers an opportunity to specify areas in which improvements may be possible, design countermeasure programs, and evaluate the effects of existing and proposed safety measures. Users include virtually every program area in NHTSA, other federal agencies such as the Federal Highway Administration, Federal Motor Carrier Safety Administration, state and local governments, domestic and foreign motor vehicle manufacturers, insurance and consumer organizations, safety research organizations, universities, foreign government agencies, and individual citizens.

NHTSA has undertaken a modernization effort to upgrade our data systems by improving the information technology infrastructure, updating the data to be collected and reexamining the sample sites. The goal of this overall modernization effort is to develop a crash data system that meets current and future data needs. The current Crashworthiness Data System (CDS) of the National Automotive Sampling System (NASS) will end on December 31, 2015 and the new system (CISS) will begin data collection on January 1, 2016 for a period of five (5) years. The new system will begin pilot testing data collection procedures on July 1, 2015 while new CISS sampling sites are phased into operation.

The implementation plan is to begin phasing in the first twelve (12) CISS data collection sites in 2015. The plan is to pilot test at five (5) new CISS data collection sites in 2015 and bring up an additional seven (7) sites by the end of 2015. Twelve (12) more sites would be brought up in 2016, with a goal of twenty-four (24) sites fully operational in January of 2017. It is estimated that approximately 4,000+ cases will be investigated each year. The number of collection sites and estimated annual case investigations recommended for CISS are not considered ideal. In NHTSA’s 2016 budget, an additional $11.5 million was requested for data collection. With additional funding, the strategy is to add more sites to CISS.

2. Describe whether, or to what extent, the collection of information involves the use of automated, electronic, mechanical, or other technological collection techniques or other forms of information technology.

Most of the data collection burden will come from in-person or telephone interviews with vehicle occupants that take about twenty minutes. This cannot be automated because each crash is unique; therefore the amount collected is zero percent. Also, information from this interviewee, scene inspection, vehicle inspection, and other occupants will almost always cause the interviewer to ask additional questions.

Training sessions are used to inform researchers of new and improved interview techniques and to test their interview skills.

The burden on police, medical records personnel, and tow yards is usually providing access to existing records and crash vehicles.

2. Describe efforts to identify duplication. Show why any similar information already available cannot be used or modified.

This item does not apply since no similar information is available.

2. If the collection of information impacts small businesses or other small entities, describe any methods used to minimize burden.

The crash researchers minimize the burden by establishing rapport and trust with tow yard operators. Typically, the researcher knows the operators and simply asks for the location of the vehicle and permission to inspect it.

2. Describe the consequence to Federal program or policy activities if the collection is not conducted or is conducted less frequently.

NHTSA needs nationally representative, real-world crash data to support creation or modification of Federal Motor Vehicle Safety Standards (FMVSS), which cover areas such as air bags, safety belts, safety glazing, and rollover protection. CISS data will help NHTSA staff determine which systems work well and which do not. Rulemaking often follows, and the crash data is required to defend this rulemaking in court when necessary, or to prevent the rulemaking from even being challenged in court.

If these rules were not made, there would be a significant increase in highway crash deaths and injuries.

7. Explain any special circumstances that require the collection to be conducted in a manner inconsistent with the guidelines set forth in CFR 1320.6.

The procedures specified for this information collection are consistent with the guidelines set forth in 5 CFR 1320.6.

8. Provide a copy of the Federal Register document soliciting comments on extending the collection of information, a summary of all public comments responding to the notice, and a description of the agency's actions in response to the comments. Describe efforts to consult with persons outside the agency to obtain their views.

NHTSA has undertaken a modernization effort to upgrade our data systems by improving the information technology infrastructure, updating the data to be collected and reexamining the sample sites. The goal of this overall modernization effort is to develop a crash data system that meets current and future data needs.

NHTSA published a notice in the Federal Register with a 60-day public comment period to announce this proposed information collection on May 12, 2014, Volume 79, Number 91, pages 27047 and 27048. See Attachment 2.

NHTSA published a notice in the Federal Register with a 30-day public comment period to announce forwarding of the information collection request to OMB for approval on September 8, 2014, Volume 79, Number 173, pages 53250 and 53251. See Attachment 4.

NHTSA received two comments in response to the 60-day notice. NHTSA’s response to the comments is discussed below. See Attachment 5 for these comments.

1. Motor & Equipment Manufacturers Association

The Motor & Equipment Manufacturers Association (MEMA) supports the information collection request (ICR) from the National Highway Traffic Safety Administration (NHTSA) titled “Crash Investigation Sampling System (CISS)” because it is necessary for the proper performance of the agency’s functions and the information will have practical utility. More details about how the CISS will be carried out should be subject to a future public review and comment.

MEMA provided NHTSA with comments in 2012 about the importance of modernizing our nation’s crash data systems. These are important tools for both government and industry to improve safety on our nation’s highways. Updates and improvements to crash data are absolutely necessary to support government actions, policies, and analyses. The motor vehicle component manufacturer industry is dedicated to supporting the efforts of NHTSA to pinpoint and analyze critical safety issues so that suppliers can continue to innovate advanced safety technologies that reduce injuries and fatalities. Improving our collective ability to quantify the experiences of real world crash scenarios helps all stakeholders in developing the appropriate solutions.

2. Volkswagen Group of America

The Volkswagen Group of America (VGA) supports the NHTSA’s data modernization effort to collect data under CISS program. The following section addresses the comments submitted by the group:

“VGA propose CISS to cover accidents with vulnerable road users in order to build a representative in-depth sample of these accidents”.

NHTSA’s Response:

The CISS sample has been designed with the flexibility to collect in-depth data on virtually any crash mode including pedestrians, bicyclists, motorcycles, and large trucks. NHTSA currently plans for the first CISS module in 2016 to be a follow-on light passenger vehicle study. However, as funding becomes available in subsequent years NHTSA hopes to initiate special studies modules focusing on more rare crash modes.

“VGA propose to include Functionality Capacity Index (FCI) variables in the in-depth data of CISS”.

NHTSA’s Response:

FCI is being considered as an additional data element for injury codes in the redesigned CISS.

“VGA propose to include variables coding the presence and if possible triggering / status of advanced driver assist systems in CISS”.

NHTSA’s Response:

NHTSA will collect information on presence and activation of driver assist systems in CISS.

“VGA propose, the information about ESC equipment should be included in CISS”.

NHTSA’s Response:

Although electronic stability control (ESC) was mandated on all light vehicles model year 2012 and newer, it is one of the technologies NHTSA will consider including in the CISS data file.

“Volkswagen proposes to collect data to assess crash avoidance technology; this data could be included in an accident event/sequence structure similarly to what is currently presented in NASS-CDS.

Volkswagen also proposes that CISS cases or a representative subset thereof are made available in a computer file format that can be used as input simulations”.

NHTSA’s Response:

NHTSA intends to expand the collection of precrash data and scene information in CISS. Scaled scene diagrams will be available along with .csv files of the collected scene information for use in reconstruction software. New precrash elements such as ‘Pre-First Harmful Event Maneuver Sequence’ will be added to the dataset to describe the actions of the vehicle prior to the crash to better assess crash avoidance countermeasures. CISS will continue to collect event data recorder (EDR) data and provide the elements from CFR49, Part 563 in the dataset and make the .cdr file available to users. NHTSA also has the ability to create speed analysis and animations of select high interest cases should funding for detailed reconstructions become available.

9. Explain any decision to provide any payment or gift to respondents, other than remuneration of contractors or grantees.

No payment or gift will be provided to any respondent.

10. Describe any assurance of confidentiality provided to respondents.

The identification in any data files of interviewees by name or other identifying labels is not permitted and is not entered into any system of records. The CISS files are not a system of records that are subject to the Privacy Act. No names of individuals will be entered into automated or hard copy case files. Reports of crash data collections must be made available to the public in a manner which does not identify individuals (Public Law 89‑564). Thus, cases will not be retrievable by any unique number, symbol, or other identifying variable assigned to the individual. The safeguards for privacy which will be afforded by the CISS files are greater than those afforded by the Privacy Act because the personal information which the Privacy Act is designed to protect will be deleted from all CISS files. Each respondent is read or provided with a copy of the NHTSA approved confidentiality pledge which states, "The National Highway Traffic Safety Administration (NHTSA) is authorized by Congress (Title 49 U.S.C., Section 30166 and 30168 and Title 23, Section 403) to collect statistical data on motor vehicle traffic crashes to aid in the development, implementation and evaluation of motor vehicle and highway safety countermeasures. CISS is the mechanism through which NHTSA collects nationally representative data on motor vehicle traffic crashes. Your cooperation in this study can aid us in improving highway safety conditions. Your response is needed to ensure the validity of this study. A representative of NHTSA who is involved in the quality review of the data may contact you only to verify that an interview did occur. Otherwise, any information that identifies you will be held CONFIDENTIAL."

It is anticipated that information on 4,200 motor vehicle crashes will be collected and entered into the CISS file every year. For each of these crashes, every precaution is taken to safeguard against personal identifying information from appearing in the database. The potential that a person can uniquely be identified by the crash and vehicle characteristics from the more than 700 data elements collected is not likely. The reason for this is that the geographic location of the crash will not be automated in the CISS file. Without the geographic location, the suspected crash could not be matched to a specific police report. Throughout many police jurisdictions in the country, a police report will only be released to the crash victims, lawyers of the victims, or insurance companies.

11. Provide additional justification for questions on matters that are commonly considered private.

Experience in motor vehicle occupant interviewing has demonstrated that discussion of the crash is not a private subject with the respondent if the subject of culpability is excluded. Culpability will not be discussed in the CISS interviews.

The CISS program seeks to identify injuries and correlate those injuries to interior features of the motor vehicle. This allows NHTSA engineers and the motor vehicle industry to evaluate the performance of interior components to improve its design to protect the motoring public from harm. All data collected for occupant assessment and injury is voluntary. Permission must be obtained from the victims to review that portion of their medical record which contains only crash-related injury information. Simply stated, if the respondents don’t cooperate then no data is collected. Therefore, all information from respondents will be acquired with their permission. Sensitive or private personal information is not recorded in the database available for government research and public perusal.

NHTSA is recognized by the Department of Health and Human Services as a Public Health Authority, allowing the medical community to provide access to its records. Medical records are the primary source of data on the nature and severity of injuries.

See Attachment 6.

12. Provide estimates of the hour burden of the collection of information on the respondents.

The estimated number of respondents is obtained by multiplying the approximate number of crashes investigated each year by the average number of interviews per crash. Based on existing data from the National Automotive Sampling System, each crash involves approximately 2.25 victims. The respondents are contacted only once unless reinvestigations are warranted because of data falsification.

In addition to interviews, researchers must obtain official records to complete the case report. These include police crash reports and medical records. The estimate of burden to police jurisdictions is obtained by multiplying the average number of visits per year by the average burden hours per visit by the number of police jurisdictions. Based on existing data, sampled jurisdictions are visited approximately 52 times per year (once per week) and require approximately 3 minutes of staff time. Non-sampled jurisdictions are visited twice annually and involve approximately 15 minutes of staff time. The estimate of burden to hospitals is obtained by multiplying the average number of records per year by the average number of burden hours (approximately 5 minutes per record) for record processing. The burden to tow fatalities is estimated by multiplying the estimated number of visits to these facilities for vehicle inspections per year by the burden hours per visit.

ESTIMATE OF REPORTING BURDEN
a. Respondent Burden
Crashes Per Year	Average Number of Respondents Per Crash	Estimated Number of Respondents	Average Number of Hours	Burden Hours
(A)	(B)	(A)*(B)=(C)	(D)	(C)*(D)
4,200	2.25	9,450	.45	4,253

Source: National Automotive Sampling System (NASS)

ESTIMATE OF REPORTING BURDEN
b. Police Jurisdiction Burden
Average Number of Visits Per Year	Average Number of Hours Per Visit	Number of Police Jurisdictions		Burden Hours
(A)	(B)	(C)		(A)*(B)*(C)
52	0.05	181	Sampled	471
2	0.25	340	Non-sampled	170

Source: National Automotive Sampling System (NASS)

ESTIMATE OF REPORTING BURDEN
c. Hospital Burden
Average Number of Records Per Year	Average Burden Hours Per Record		Burden Hours
(A)	(B)		(A)*(B)
7,288	0.08		583

Source: National Automotive Sampling System (NASS)

ESTIMATE OF REPORTING BURDEN
d. Tow Facilities Burden
Average Number of Visits Per Year	Average Burden Hours Per Vehicle Inspection Visit		Burden Hours
(A)	(B)		(A)*(B)
7,515	0.017		128

Source: National Automotive Sampling System (NASS)

ESTIMATE OF REPORTING BURDEN
TOTAL BURDEN HOURS (A)	5,605
AVERAGE COST PER HOUR (B)	$25
COST ASSOCIATED WITH BURDEN HOURS (A)*(B)	$140,125

13. Provide an estimate of the total annual cost burden to respondents or record keepers resulting from the collection of information.

Interviewees keep no records of the interview. Hospitals and police simply allow access to copy their existing records. Tow yards merely direct the researchers to the crash vehicles. Therefore, there are no recordkeeping costs to any of the respondents.

14. Provide estimates of annualized costs to the Federal government.

The following figures come from the FY-2013 Budget Execution Plan.

FY-2013	Estimated Cost Per Year ($K)
a. Data Collection Operations (contracts)	10,806
b. Administrative Salaries, Overhead, Printing of Forms	534
c. Analysis	1,190
TOTAL	12,530

15. Explain the reasons for any program changes or adjustments reported in Items 13 or 14 of the OMB Form 83-I.

There are neither changes nor adjustments.

16. For collections of information whose results will be published, outline plans for tabulation and publication.

There will be two CISS files made available to the public each year after completion of quality control. These files are for clinical review and analysis. CISS data file and accompanying documentation will be released annually which is available on the Internet in August for the previous calendar year. For example, data collection during calendar year 2016 will be available for public release in August 2017. Copies of the data base have been acquired by motor vehicle manufacturers, highway safety research organizations, and insurance and consumer groups, who use the data for their own analyses. NHTSA uses the data files to answer hundreds of questions received from federal, state and local governments, businesses, and private citizens.

17. OMB approval of the information collection, explain the reasons that display would be inappropriate.

NHTSA will display the expiration date for OMB approval.

18. Explain each exception to the certification statement identified in Item 19 of OMB Form 83-I.

No exceptions requested.

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