ICR Supporting Statement: Section A
State of the Practice of Ignition Interlock Programs
The National Highway Traffic Safety Administration (NHTSA) of the U.S. Department of Transportation (USDOT) is seeking approval from the Office of Management and Budget (OMB) to conduct a survey of state administrators and staff of alcohol ignition interlock programs. NHTSA’s mission is to save lives, prevent injuries and reduce economic costs due to motor vehicle crashes. In support of this mission, NHTSA’s Office of Behavioral Safety Research studies behaviors and attitudes in highway safety, focusing on drivers, passengers, pedestrians, and motorcyclists, and it uses the results to develop and refine countermeasures to deter unsafe behaviors and promote safe alternatives. Alcohol-impaired driving is a significant concern. Thousands of individuals are killed every year in traffic crashes that involved an alcohol-impaired driver. For example, in 2014, there were 9,943 people killed; in 2015, there were 10,265 killed, and in 2016, there were 10,497 people killed in traffic crashes involving an alcohol-impaired driver.1 These alcohol-impaired-driving fatalities accounted for 28 percent of all motor vehicle traffic fatalities in the United States in 2016.
Interlocks are an important countermeasure to prevent Driving While Impaired (DWI), which is defined as driving while having a blood alcohol concentration (BAC) of 0.08 grams per deciliter (g/dL) or higher. An interlock is an alcohol-detection device designed to prevent alcohol-impaired individuals from starting their vehicles. An interlock will prevent the engine from starting unless the driver provides a breath sample that registers an alcohol concentration (BrAC) lower than a pre-specified level. (Typical levels are 0.025 g/dL.) Installed on the dashboard and wired to the ignition, interlocks are assigned as a condition of probation to drivers arrested or convicted of DWI. Interlocks have been used in impaired driving programs for nearly 30 years. Research on their effectiveness demonstrates that interlocks reduce recidivism during the time a device is on the offenders’ vehicle (for example, see Goodwin et al, 2015).
All states allow the use of interlocks as a criminal or administrative sanction for DWI.2 States manage interlock services through their interlock programs. Interlock programs administer the functions involved in program management, such as contracting with interlock vendors, enrolling and monitoring3 program participants, and coordinating with stakeholders such as the police, legal system (DWI courts, probation offices), and departments of motor vehicles.
This research will examine States’ interlock programs with the goal of learning various strategies for administering programs, solutions to common issues, and promising practices. The research will seek information from interlock program administrators and staff to update an online inventory of interlock programs. The previous inventory is out-of-date (see http://www.iiip.tirf.ca/inventory/index.php). The current effort will collect information using a 15-minute on-line questionnaire concerning basic information on individual programs and a follow-up phone conversation lasting no more than one hour.4 The results will be compiled in an online “inventory” documenting the state of the practice of interlock programs and made available on the Internet. The inventory is relevant to interlock program administrators and State Highway Safety Offices, especially as many jurisdictions are expanding their programs to cover more DWI offenders. Overall, the results will support NHTSA’s and the States’ efforts to reduce impaired driving and prevent alcohol-impaired crashes.
The inventory will include information on:
DWI and interlock law – to be obtained from available secondary sources;
Program processes, resources, and practices – to be collected from the online questionnaire and group interviews
Program features from the perspective of model guidelines or “’key features” – to be obtained by researchers and from the questionnaire and interview; and
Program data on the number of DWI arrests, convictions, recidivism rates – to be collected from the online questionnaire and group interviews
Title 23, United States Code, Section 403 gives the Secretary authorization to use funds appropriated to conduct research and development activities, including demonstration projects and the collection and analysis of highway and motor vehicle safety data and related information needed to carry out this section, with respect to all aspects of highway and traffic safety systems and conditions relating to - vehicle, highway, driver, passenger, motorcyclist, bicyclist, and pedestrian characteristics; accident causation and investigations; and human behavioral factors and their effect on highway and traffic safety, including distracted driving. [See 23 U.S.C. 403(b)(1)(A)(i), 23 U.S.C. 403(b)(1)(A)(ii), 23 U.S.C. 403(b)(1)(B)(iii)].
NHTSA was established to reduce the number of deaths, injuries, and economic losses resulting from motor vehicle crashes on the Nation’s highways. NHTSA is authorized to conduct research as a foundation for the development of traffic safety programs. A key issue addressed in NHTSA programs is alcohol-impaired driving. This collection is central to NHTSA’s mission as it supports programs to prevent impaired driving, and will assist NHTSA in its responsibilities to: (a) report on the effectiveness of impaired driving countermeasures, and, (b) provide information to partners working to reduce impaired driving.
The information will be primarily used by interlock program administrators. It will also be used by State Highway Safety Offices and NHTSA. These entities will use the information to advance their understanding of the processes involved in interlock program administration and identify areas of improvement in interlock management. The information will reveal ways of improving programs’ breadth of reach to offenders, efficiency, and effectiveness. The information can reveal factors that strengthen a program as well as those that are burdensome or counter-effective. The information will enable promising practices to be shared among different programs, will support the ability of programs to coordinate on problem-solving, and help strengthen partnerships. The inventory will also support stakeholders besides States and their federal partners involved in improving impaired driving programs. The results may also be of value to legislators working on impaired driving legislation, researchers and safety advocates. These stakeholders include the GHSA, State highway safety offices, Mothers Against Drunk Driving (MADD)5 and the Association of Ignition Interlock Program Administrators.6
The questionnaire will be on a website housed by the researcher.7 The program administrators may take the survey at their convenience. The estimated time to complete the survey is approximately 15 minutes.
No up-to-date inventory exists, and it is important to produce one. To reduce the burden of collection on individuals and interlock programs, the researchers will first obtain information that is publicly available, for example, State and Federal sources documenting legislation on impaired driving and interlock use. After public sources are exhausted, the researchers will seek input from interlock programs.
This project does not involve small business. However, the project does involve small government entities. To minimize burden to these entities, the on-line questionnaire can be conducted at the respondents’ convenience. The group phone interviews will also be conducted only when convenient to the respondents.
Alcohol-impaired driving results in thousands of people killed and severely injured every year. The monetary costs to society are staggering, and the emotional and social cost are devastating. A key effort undertaken by NHTSA is to deter impaired driving. This survey supports that effort by helping administrators plan and manage programs. The current inventory is out-of-date and cannot support interlock administrators, whereas an up-to-date inventory supports interlock delivery. Without this information, the state of the practice of interlock programs will not reach its potential. Another consequence of not collecting this information is that the Federal government would not meet its obligation under NCREP. NCREP, described above, is a Congressionally mandated partnership between NHTSA and the GHSA for implementing research projects based on topics put forward by State Highway Safety Offices.
We do not foresee any technical or legal obstacles for reducing burden.
Data collection is scheduled to begin in January of 2019. Delay in approval of this request will likely result in contract modifications and additional costs to the government.
No special circumstances require the collection to be conducted in a manner inconsistent with the guidelines in 5 CFR 1320.6.
The Federal Register published the 60-day on August 24, 2017 (Vol. 82, No. 166, Pages 41090-41091) that notified the public of NHTSA’s plan to collect information and enabled a 60-day public comment period.
There was one response to the 60-day Federal Register Notice, from the Transportation Departments of Idaho, Montana, North Dakota, South Dakota, and Wyoming. The departments noted their support of the survey and had three recommendations. They recommended that the questionnaire be provided to the headquarters of each State transportation department and “any other department in the State where the Governor’s Highway Safety Representative” prior to distribution to allow senior management time to review the questionnaire and provide guidance to staff. Second, they recommend avoiding questions that involve a responder’s “judgments” about a department doing a “good job.” Third, the departments noted that other approaches to deterring impaired driving (for example, “24-7” sobriety programs) warrant support.
NHTSA concurs with these comments. Through our Regional Offices we will forward the questionnaire and the topics in the group interview to State highway safety departments, or other departments where the Governor’s Highway Safety Representative is based. NHTSA also concurs with the request to avoid questions that involve personal judgment about a department or policy. The questions will strictly focus on features and practices of the interlock program. NHTSA acknowledges its support for other strategies for deterring impaired driving, such as “24/7 Sobriety” programs. NHTSA has many initiatives in impaired driving.
The Federal Register published the 30-day Notice on July 17, 2018 (Vol. 83, No. 109, Pages 34152–34154), which announced that this information collection request will be forwarded to OMB.
No payment or gift will be provided to respondents of this study.
The information collection is from interlock program personnel. The name of the program administrator is typically provided on State program websites. Nonetheless, this personal information is not of research interest and no personally identifiable information (PII) will be stored, analyzed or reported in the project’s findings or publications
The study does not contain any questions of a sensitive nature or matters considered private.
A maximum of 52 programs (for the 50 States, Puerto Rico and District of Columbia) will be asked to participate. The expected average completion time for the online questionnaire is 15 minutes (0.25 hour), and 60 minutes for the semi-structured interviews, resulting in an estimate of 273 total annual burden hours if all 52 programs participate (Table 1). As the number of individuals per program varies from about one-to-five people, the actual burden hours will be reduced proportionally by the response rates and the number of staff per program. Most programs have fewer than 5 individuals and none are likely to have more than 5.
Table 1. Calculation of Burden Hour
|
Respondents |
Minutes per respondent |
Estimated burden hours |
NHTSA Form 1450 Online Questionnaire |
52 |
15 |
13 |
NHTSA Form 1451 Discussion Guide |
260 (max) |
60 |
260 (max) |
TOTAL |
|
|
273 (max) |
There are no recordkeeping costs to the respondents, and no preparation of information required or expected of respondents. Participants do not incur either (a) capital and start-up costs, or (b) operation, maintenance, and purchase costs from participation in the study.
It is expected that a State interlock program administrator/manager will respond to the on-line questionnaire (Form 1450) and that interlock program staff will take part in the telephone interview (Form 1451). At $34.41 for State Government Managers (akin to the level of a program administrator) and $26.63 for Probation Officers8 (akin to the level of interlock program staff), the estimated opportunity cost to respondents associated with the data collection is:
Online Questionnaire
$34.41/hour x 0.25 hour/response x 52 responses = $447.33
Semi-Structured Telephone Interview
$26.63/hour x 1 hour/response x 260 responses = $6,923.80
The total opportunity cost to respondents for this data collection is $7,371, if all possible respondents in Table 1 respond.
The estimated contract cost to the government for this one-time information collection is to 7DTNH2212H00371L, Task Order 6, held with the Traffic Injury Research Foundation (TIRF). The estimated cost in terms of government time is approximately 80 hours for the Contracting Officer’s Representative (COR) for about $4,000 in wages. Since data collection is expected to take less than a year, the annualized cost is the same. The estimated one-time cost to the Federal government for collection of information is $51,206.49. Table 2 provides a breakdown of costs for the online and interview data collection.
Table 2a: Online Questionnaire and Semi-Structured Interviews
Cost Element |
Cost |
IRB Approval |
$3,000 |
Collect data for the inventory; host online questionnaire (Reference Task C.4.8 in the Business Proposal) |
$18,148.23 |
Interviews (involves development of discussion guides) (Reference Task C.4.9 in the Business Proposal) |
$47,706.49 |
TOTAL ESTIMATED COST TO GOVERNMENT |
$68,854.72 |
The collection of this information is associated with a new project. As such it requires a program change to add the estimated 273 hours for the new collection to NHTSA’s existing burden.
The draft technical report is schedule for five months upon completion of data collection. The technical report will include frequencies and cross-tabular analyses of the responses to the online questionnaire and input during the telephone discussions. The report will not include any personally-identifying information. The schedule assumes a data collection start in January 2019. Delays in approval of this ICR could delay publication of the final technical report and will likely result in contract modifications and additional costs to the government.
Findings will be disseminated through internal briefings to NHTSA and technical reports for stakeholders. The reports will be available to the public on the NHTSA website.
NHTSA will display the expiration date for OMB approval.
No exceptions to the certification are made.
1 National Center for Statistics and Analysis. (2017, October). DOT HS 812 102. Alcohol-impaired driving: 2016 data (Traffic Safety Facts. Report No. DOT HS 812 450). Washington, DC: National Highway Traffic Safety Administration. Retrieved from: https://crashstats.nhtsa.dot.gov/Api/Public/ViewPublication/812450
2 The Association of Ignition Interlock Program Administrators is a platform for interlock programs.
3 When a device detects a positive BrAC, it will record it as a “fail” and prevent the vehicle from starting. Program administrators may issue additional sanctions when an offender’s record reveals a fail(s).
4 The number of participants in a phone interview depends on the number of people working in the program and choosing to participate.
5 For example, see MADD (2016). How Technology Has Stopped 1.77 Million Drunk Drivers. Available at http://www.madd.org/drunk-driving/ignition-interlocks/reports/ for information on ignition interlocks.
6 The website for the Association of Ignition Interlock Program Administrators is available at: http://www.aiipaonline.org/index.html
7 A previously used form to collect data is available at http://www.iiip.tirf.ca/inventory/index.php.
8 US Department of Labor, Bureau of Labor Statistics (accessed March 26, 2018). May 2016 National Occupational Employment and Wage Estimates – Mean Hourly Wage (All Occupations). http://www.bls.gov/oes/current/oes_nat.htm
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