Responsibility for fleet safety and regulatory compliance can be one of the toughest jobs in a dairy or ice cream company. It’s often not viewed as an important component in making a company successful or profitable. It is quite common to see these functions as second-tier management functions that are handled at the supervisor level.
If your company fits that second-level or supervisor-level description of fleet safety and compliance management, then please believe me when I say you are already on the brink of potential bankruptcy and/or being shut down by regulatory authorities. You just don’t know it yet.
In 2012 and beyond, fleet safety and satisfactory regulatory compliance are incredibly important to both your company’s success and its very survival.
In my experience there are actually two major parts to any successful fleet safety compliance management program. One is the fleet’s integration of fleet insurance administration and negotiation of premiums with fleet safety management. Over time, consistently good safety performance and operating practices along with driver training and performance requirements can yield substantial reductions in premium costs.
The other part, which is rapidly becoming the federal Motor Carrier Safety Administration’s new “Godzilla” in the room, is MCSA’s new Compliance, Safety, Accountability program. It’s generally referred to as CSA.
The Aug. 15, 2011 Transport Topics article by Daniel Bearth stated “data from inspections, crashes involving commercial trucks and compliance reviews are assigned points and used to compile scores in seven Behavior Analysis and Safety Improvement Categories. The seven Basics are unsafe driving, fatigued driving, driver fitness, controlled substances/ alcohol, vehicle maintenance, load securement and crash indicator.”
He went on to write that violations are assigned severity weights. Carriers with CSA scores that exceed certain levels are targeted for interventions that can include warning letters, fines and on-site investigations that can lead to a driver or carrier-out-of-service orders.
Without question, improved driver and fleet safety performance are commendable goals. But as you’ve heard before, the devil is in the details. As an example, I am told there are 37 proscribed steps to a Level 1 roadside inspection. A “condition of vehicle and fitness of the driver report” contains several hundred required items of information.
Examples of other major flaws in the CSA abound (in my opinion) and the MCSA is in no rush to fix or eliminate them. A driver or company can be disqualified to drive or operate a fleet based on their scores. By now, every CDL driver and fleet manager should understand that every violation counts on their respective score. Let it get to a certain number and your fleet is shut down or a driver has lost the right to drive.
Currently, incidents such as a “truck-involved accident” now go on the fleet’s record with or without responsibility assigned. The kid in the hot Mustang may have caused a jack-knife which caused a multivehicle accident, but the fleet’s score simply has another strike added.
Drivers have been required to perform and fill out pre-trip inspections on their truck or tractor/semi-trailer before departing. Now however, under CSA, if a driver is stopped for no brake lights, clearance lights out or other similar reason, that violation goes on his personal score record, even though they were working when he did the pre-trip. In my view that’s just not right. But here again, the MCSA folks aren’t rushing to fix that and many other similar problems and issues.
As I have said, if you don’t already have extremely knowledgeable senior managers responsible for and working in these areas of enhanced driver and fleet safety management and regulatory compliance, your company and its CDL drivers are on the brink of major instances of fleet inspection that may result in substantial “loss of income” problems for CDL drivers suspended from service.
The same can be said for the company as well. Not only is there risk of your fleet being suspended from operation: but those events are now posted, along with the carrier’s safety rate, for all to see. I can tell you that fleet insurance carriers are watching for those carrier safety rates. Rest assured that a bad one is only going to raise your premiums, if they don’t drop you completely.
CSA was probably a great idea, but the current state of that regulatory compliance is far from it in many ways. Pay close attention to MCSA activities and proposed regulatory changes along with new regulatory proposals.
Good luck generally comes to those best prepared. So get prepared if you are not already.