FHWA s s New NBIS Performance Metrics
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1 FHWA s s New NBIS Performance Metrics Pacific Northwest Bridge Inspectors Conference April 2011 Barry B. Brecto Senior Bridge Safety Engineer FHWA Office of Bridge Technology
2 Why? FHWA saw need Bridge failure high risk States concern about FHWA consistency I 35 W and OIG audits Congress said to improve our oversight
3 How? Applied Team Approach Representation Divisions Resource Center HQ Pilot Programs 12 Divisions, and States Training and Documentation All Division & FLHD Bridge Staff
4 Pre 2011 Oversight Approach Recommended scope of annual reviews Review of files, procedures and documentation Site visits NBI data checks Interviews High degree of variability Annual summary reports
5 What s s Different? Consistency across the Nation Use of statistical samples Application of risk considerations In definitions and process Compliance status monitored quarterly Final compliance report on December 31 st
6 Specific Aspects 23 Individual Metrics Relate to specific requirements of the NBIS 3 Assessment Levels Defines specific review criteria and data sources 4 Levels of Compliance Defines specific compliance thresholds Risk Consideration Structurally deficient, fracture critical, scour critical bridges = higher risk and lower tolerance Clearer Reporting & Oversight
7 Metrics: Generic Definition Quantified NBIS requirement by which one can make an assessment of compliance Specific Metric (#6) 23 CFR Inspection frequency (a) (1) &(2) Routine inspection Have all bridges been inspected at a regular interval not exceeding 24 months? Have criteria to determine level and frequency for bridges that require inspection at less than 24 months been established?
8 Specific Metrics: Organization Program Manager qualifications Team leader qualifications Load Rater qualifications Underwater diver qualifications Routine inspection frequency Extended inspection frequency Underwater frequency Extended underwater frequency Fracture critical frequency Damage, in depth, special frequency Inspection procedures Load rating procedures Posting procedures Bridge files Fracture critical procedures Underwater procedures Scour critical POAs Complex bridge procedures QC/QA procedures Critical findings procedures Inventory upkeep Timeliness of data updates
9 Assessment Levels: Minimum General knowledge and awareness of the state s program in relation to the metric Analysis of NBI data In depth Larger sample sizes More interviews Review calculations Research of records and/or history Intermediate Sampling of inspection records or files Analysis of NBI data Visits to bridges Interviews Documentation of qualifications
10 Assessment Levels: Metric 6: Inspection Frequency Example Minimum Intermediate In-depth Knowledge/awareness of bridge inspections scheduling process. Run standard NBI reports. Run standard NBI reports. Review sample of records (MOE of 15%, LOC of 80% ) including a historical review of reports, to ensure frequency in records matches NBI data. Include SD and load restricted bridges, as well as bridges that require inspection <24 months. Include some site visits. Perform intermediate level of review - increase sample size.
11 Compliance Levels: Compliance Adhering to NBIS regulation. Substantial Compliance Adhering to NBIS regulation with minor deficiencies. Deficiencies to be corrected within 12 months or less, unless deficiencies are related r to issues that would most efficiently be corrected during next inspection. Non Compliance Not adhering to NBIS regulation. Identified deficiencies may adversely affect the program. Failure to adhere to an approved plan of corrective action is also considered non compliance. Conditional Compliance Taking corrective action in conformance with FHWA approved plan of corrective action (PCA) to achieve compliance with NBIS
12 Compliance Levels: Metric 6: Inspection Frequency Example Compliance Substantial Compliance Non-compliance Conditional Compliance Yes 100% of all SD or load restricted bridges inspected per established frequencies. At least 98% of all other bridges inspected in accordance with established frequency. At most 2% of all other bridges have been inspected no more than 4 months beyond the scheduled inspection date. <100% of all SD or load restricted bridges inspected per established frequency. Less than 98% of all other bridges inspected per established frequency. Greater than 2% of all other bridges have been inspected >4 months beyond the scheduled inspection date. Any bridge delinquent for inspection by > 4 months. Adhering to approved plan of corrective action.
13 Compliance Determinations: Compliance Level Compliance Substantial Compliance Non Compliance Conditional Compliance Required State Action None Submit Improvement Plan (IP) for Approval Submit Plan of Corrective Action (PCA) for Approval Achieve Progress Milestones in Accordance with PCA; Periodic Reporting
14 Compliance Determinations: For Each Metric Progressive Throughout Year Final Determination Made After Assessment Complete State Notified of Determination State Submits IP/PCA, If Necessary National EOY Summary for All States
15 Compliance Determinations: Benefits Standardized, data driven driven assessments Defined compliance criteria; factor in risk Uniform approach applied to all States Agency wide coordination for consistency Enhanced follow up and monitoring within FHWA More accountability for compliance
16 New NBIP Oversight Process: Five Year Cycle
17 Question: How will this affect States workloads?
18 Question: How will this affect States workloads? Answer: There should not be much change. This process change is directed at FHWA.
19 Question: How is NBIS compliance related to federal funding? In an extreme case of noncompliance when does funding stop, and who makes those decisions?
20 Question: How is NBIS compliance related to federal funding? In an extreme case of noncompliance when does funding stop, and who makes those decisions? Answer: Complying with the NBIS is an essential part of the Federal aid program. Non compliance can lead to suspending project authorizations, if corrective measures aren t undertaken. The local FHWA Division Office ultimately informs the state, after coordinating within FHWA.
21 Question: Isn t this raising the bar for the States inspection programs?
22 Question: Isn t this raising the bar for the States inspection programs? Answer: Each metric is directly linked to the existing NBIS regulations. The NBIS regulations have not changed.
23 Question: Why do some metrics have zero tolerance, like inspection frequency for SD or load restricted bridges? Is this realistic?
24 Question: Why do some metrics have zero tolerance, like inspection frequency for SD or load restricted bridges? Is this realistic? Answer: The NBIS regulation does not recognize any tolerance. It uses not to exceed. The tolerances were established carefully, after considering risk for each situation. We believe less tolerance for higher risk structures is warranted.
25 Question: How will FHWA assure states are reviewed consistently, and not unfairly placed in noncompliance by an overzealous DBE?
26 Question: How will FHWA assure states are reviewed consistently, and not unfairly placed in noncompliance by an overzealous DBE? Answer: The new process has documented metrics with defined levels of compliance. National training on standardized procedures has been provided to all DBEs. The 4 new Bridge Safety Engineers are tasked to assist in implementation and provide national uniformity.
27 Additional Questions
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