Not getting caught behind the requirements. When it comes to Random controlled substance and/or alcohol testing, the motor carrier is required to ensure the minimum annual percentage testing rates are being met. Currently under FMCSR 382.305, the minimum annual rate for alcohol is 10% and for controlled substances, it is 50%. It is possible to request that the testing rates be raised is you are not in a random pool with other motor carriers. A motor carrier may consider requesting that their rates be raised to 15% for alcohol testing and 60%-65% for controlled substances. This way you’re not behind in the final months of the year.
December 2011 -
Recognition for Excellence. In many aspects of today’s life we only hear negative feedback. We fail to give praise when it’s earned ranging from our kids getting good grades at school to our employees putting forth extra effort. Sometimes you can get many more months of that “extra effort” when you praise a driver in front of their co-workers. You may consider a driver recognition awards program based on monthly or quarterly periods. One of my clients implemented an awards program this year with excellent responses. This is the best year of compliance we’ve ever had. Simply put-an earned pat on the back is all some folks need once in awhile.
November 2011 -
Reasonable Suspicion Testing. This is one of the best tools a motor carrier has available to keep impaired drivers off the road. It’s also one of the most underutilized. Supervisors need to become familiar with their driver’s habits and normal behavior so they can recognize when something isn’t right. Spend some time around the drivers so you can observe their normal behavior so if it happens, the unusual will stand out. Take the extra time to observe drivers the morning following major events such as televised athletic championships and extended holidays. Documentation of your observations is extremely crucial to a reasonable suspicion testing program. Remember these documents are confidential!
October 2011 -
Spot Checks. Commercial Vehicle Enforcement troopers and other enforcement officials aren’t the only one who can randomly inspect drivers and their vehicles. One successful tool I’ve used is unannounced driver and vehicle inspections. These inspections can occur in the yard, jobsite, and even roadside in the same manner as an enforcement stop. On more than one occasion I’ve called a driver and said I’m a quarter mile behind you and instructed them to stop in a safe location. This gives you the opportunity to realistically evaluate your drivers in a real world setting. It’s also not just for identifying non-compliant drivers, but the chance to commend the team players and leaders in safety and compliance.
July 2011 -
Better safe than sorry. For anyone who is responsible for maintaining driver qualification files, it can difficult at times to stay on top of things. There are 3 documents that must be either completed or obtained annually. They are the MVR, the Driver’s Certification of Violations, and the Annual Review. I suggest these performed once every 6 months. A lot can happen to a driver’s eligibility status in 6 months, much less 12. Also this helps to prevent missing the annual requirement and being in violation during an audit.
June 2011 -
Pre-Trip inspections. A driver’s day of operation begins with this procedure, which is why it’s imperative to be thorough. This is the carrier’s, and the driver’s opportunity to locate defects before hitting the road. Also BEFORE someone from enforcement discovers it for you. I recommend that a checklist to be used and that a driver develop a thorough inspection process. The driver then needs to use that same process each and every time with management’s support. Management should also develop a system to verify that proper pre-trip inspections are being performed and drivers are held accountable for when they’re not.
The life of the company may be on the line if compliance isn’t taking place.
May 2011 -
If once a year is compliant, then twice is even better. What I mean by this statement applies to three annually required documents in the driver qualification files. The FMCSR’s require that annually a motor carrier shall make an inquiry to obtain the motor vehicle record (MVR), shall review the MVR (Annual Review) to determine whether the driver meets the minimum requirements, and shall require each driver it employs to prepare and furnish a list of all violations of motor vehicle laws (Driver’s Certification of Violations). I suggest that these documents be requested & completed at least once every 6 months for two reasons. Reason #1-By doing so, a motor carrier can prevent the possibility of missing the every 12 months requirement, and Reason #2-A suspension, revocation, or cancellation could be placed on a driver’s CDL just weeks or days after obtaining a valid MVR. Why risk waiting an entire year to discover that your driver’s CDL is invalid. Better you catch it instead of an enforcement official during an inspection.
April 2011 -
Everyone involved in the motor carrier industry ranging from the owner-operator with a single truck to a fleet of a 1,000 plus is familiar with the Driver Vehicle Inspection Report (DVIR)/ Post-Trip Report. As we know this DOT report is required at the conclusion of work and usually at the end of a long, hard day. Unfortunately the DVIR has become one of the most pencil whipped documents involved with our industry.
On the flip side, the DVIR is one of the easiest documents to complete following the completion of a proper post trip inspection once drivers and management understand the elements involved. When a driver completes their DVIR and there are not any defects noted, then only a single signature is required from the inspecting driver. Things are a little different when a defect is noted because a total of 3 signatures must appear.
When an inspecting driver does note a defect such as a broken headlight, then he or she must sign the DVIR as the inspecting driver (signature #1). Before that vehicle is driven again, the defect must be corrected, “Above Defects Corrected” checked and then the repairman must sign the DVIR (signature #2). Before the vehicle is driven following completion of the repairs, the reviewing driver must sign the DVIR also (signature #3). If a defect was noted and repaired, but any of the three signatures are missing, then a violation exist that can appear during an audit.
The key thing to remember here is the complete documentation of all defects and their repairs. Remember, if it’s not documented, then it didn’t happen.
Be Safe and Think Safe Out There.
March 2011 -
On April 1st the new CVSA Out-of-Service Criteria will go into effect for 2011 and will be in effect until March 31, 2012. There are always changes that are essential for motor carriers to be aware of that will affect your drivers, vehicles, & Haz-Mat operations. I recommend that you contact your local Texas DPS Commercial Vehicle Enforcement office and request a trooper to attend your next safety meeting. These troopers can provide you and your drivers with information on the changes along with a refresher on the most common Out-of-Service violations they encounter. Another positive aspect about inviting troopers to attend your safety meetings for a question and answer session is that it shows drivers and management alike that in the long run, safety is what everyone wants. Currently one of my clients makes a request and if scheduling permits, a C.V.E. trooper attends and speaks to the drivers on a quarterly basis.
Remember-Be proactive and not reactive.
February 2011 -
The ability to follow instructions and take initiative. These are just two of many very important traits a professional driver must have. You as a motor carrier can test a driver in these two areas when they begin their application of employment and other new-hire paperwork. I recommend, if it’s possible, to set aside an area for applicants to start their application for employment. In addition to the instructions on the application, you may consider posting additional instructions stating the application must be filled out in its entirety. You might post details that are required such as the previous employers full address and phone numbers, previous driving experience and not to leave any blanks. In this area provide a phone book, dictionary, and possibly an internet connection to obtain information. Afterwards, examine the application and other paperwork you require to determine if they have the ability to follow instructions and the initiative to submit complete and correct paperwork. If an application poses a difficulty, it’s a safe bet that logbooks or haz-mat shipping papers will also.
Note: The February tip reflects back on the June-2010 tip of the month.
