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Saturday, February 27, 2021

Maintenance of Safety Records in Preparation for an Audit….By: Sonia Nanda

With any trucking company, regardless of its size or length of haul, the “A” word seems to shake up the management and owners.
It is a true pleasure to be able to sit down and write this article and hopefully dispel a lot of the fear that has spread throughout the industry. The first and most important point I would like to emphasize is that maintaining safety records should start at the time you start the company and not at the time you receive a letter for an audit. In fact, if you are constantly maintaining and monitoring your company’s safety records, while working to improve your safety rating, the chances of being audited are quite low (but not zero). Let’s go back to when you first applied for your NSC certificate (Safety Fitness Certificate/CVOR) or you’re DOT/MC Number. At the time you applied, you answered several questions that pertained to driver qualification files, vehicle condition, maintenance of safety files, monitoring of hours of service, and safety polices. It is imperative to remember that when you marked “yes” to all the questions that were asked, you thus completed a legal document stating that those processes were in place. At that point, the processes should already have been implemented. In my experience, 9 times out of 10, when I see a client regarding an upcoming audit, none of the requirements have been implemented and no monitoring has occurred. Most people tell me they had no idea what was required of them in the first place. As a transport company, you should be familiar with your provincial safety information, which is available on line. If needed, bookmark this page so that it is readily available. For BC residents, the Carrier Safety Guide is available online and you should familiarize yourself with your obligations as an NSC holder.
When you start your company, I like to think of it as starting with a “clean slate” and it is your opportunity to develop and grow your business and implement safety practices that are beneficial for your drivers, your company and for the communities in which you operate. In addition, when starting your company, you should register to view your safety profile (and if transporting to the USA, register to view your CSA results also) and be able to review at set periodic intervals your progress. Things that should be kept in mind include: What are the driver contraventions like? How many and how frequent? How many scale inspections? How many were OOS or fail at roadside? Why? Analyzing such reports regularly will enable you to see a clear picture of your company. But analyzing is just the first step; you also need to take action when something is incorrect or in need of updating. In an audit situation, there are various areas of a company’s safety records that are looked at. I like to think of it as pieces of a pie.
Section 1: Driver Qualification Files
This encompasses all driver records, employment applications, driver abstracts, licensing requirements, drug testing results, tickets, and most importantly, disciplinary documentation. One common mistake I always see is a “temporary driver” hired for an emergency job for a few hours and no driver abstract is on file because usually there is no application. The answer I typically get is, “It was an emergency and I needed a driver to take the load.” For that one trip, as a company owner, you are taking a huge risk because you have no knowledge of the following: does he have a valid license? Has his license ever been suspended or cancelled? And, what was his driving history? The risks you have taken for that “emergency” far outweigh the short term need your company may have had at that time. Another common problem in drivers’ files is excessive contraventions, which include hours of service violations and log falsifications. Just checking your log books is not enough. What you need to do is ask yourself, “What have I done as a company to educate, train or discipline my drivers?” Do you have proof of that documentation on file? Have you taken those steps within the appropriate time frames and acted accordingly? If you look back at your implementation of disciplinary policy, is your driver improving? These are questions you need to ask yourself on a regular basis to ensure your driver files are adequate. Therefore, when driver qualification files are being audited, there are many aspects that are looked at and reviewed to ensure you are following your obligations. I would like to stress there are many areas to be discussed in depth and be elaborated on, but for the purposes of this article, an overview is appropriate.

Section 2: Vehicle Records
There are many areas looked at in this section: valid registration records for power units and trailers, valid CVIP’s and historical MVI’s, CVSA inspections, maintenance records and PM records and schedules. In this section, a large number of companies have misunderstandings about what is required. The common response I always hear is, “I have owner operators and I am not responsible for the maintenance to their unit because that is their responsibility.” Wrong. First step back and take a look: Whose authorities are they using? Yours. If an accident were to occur because of mechanical defects, it is the company’s responsibility. Owner Operators must provide proof of their repairs to the company on a regular basis (within the required guidelines) and as a company, you must ensure regular maintenance, as well as preventative, is occurring. Ask yourself that, as a carrier, do you have a scheduled system to advise you of MVI’s coming in due or PM maintenance that needs to be done? Technology in our industry has jumped by leaps and bounds and there are a variety of software systems that automate all your schedules for you so that you can maintain your fleet in a less labour intensive manner. It is also important to look at your profile report. How many roadside inspections occurred this month? How many OOS/fails? Is it the same drivers or owner operators who are having issues? Is it a company unit or an owner operator? Are there consistent trends that can help you see where you need to improve? Are you constantly encountering vehicle condition violations? If so, why? I hear many companies tell me, “I can’t believe I got an ‘out of service.’ I had just had a full inspection at my mechanic shop.” If that was the case, then why did it occur? Did you speak with your mechanic? What exactly was done and how often is this occurring? Bottom line, companies need to analyze what is going on within their company. Improving your vehicles’ safety performance will not magically happen unless you delve a little deeper. Your carrier profile should be your main tool to tell where you need to improve. And, ensure your drivers hand in all their roadside inspections, not only because it is required by law, but because you need to see what, if any, violations occurred. That way, you can take corrective actions to repair the vehicle and ensure the driver is also aware of the issues and consequences. I also hear companies always tell me, “Are you kidding? A preventive maintenance schedule? Who is going to pay for that? There is no money left for me to spend on a PM plan.” Even though performing regular scheduled maintenance may seem like extra money being spent, it has been proven there are long term positive effects.  By fixing “minor” problems before they turn into “major” OOS issues, you can alleviate a lot of costly repair charges, towing charges, and fines. So, in the long run you will be saving money. Talk to your mechanic about what can be done. Also, speak to your safety inspectors at your office, get to know them and you will realize that they are there to assist you. And, if they do come into audit your records, at least you have taken the appropriate steps to follow your requirements.

Section 3: Hours of Service Records
I have saved the most controversial section for last. One thing I want to stress is that in order to improve in this section, you must get to the root cause. It is not good enough to just check log books. You need to ask yourself who in your organization is dispatching the drivers? When drivers are dispatched, do you know how many hours they have available to them at that point? Do drivers call in to dispatch at regular intervals so you are monitoring where they are and how much time they left before they need to rest? Are they handing in all their required mandatory supporting documents on time so you can ensure you are checking their logs and their logs are accurate? If a driver has gone over hours, when did your company find out? What did your company do about it? Did the driver need more training? Is this a consistent problem, where does disciplinary action need to be taken? If so, are you monitoring to ensure the driver has improved?
When your logs records are audited, supporting documents must be provided and yes, fuel with time must be provided. For a full list of required supporting documents, please refer to the Carrier Safety Guide for further details. I hear from many carriers that, “My dispatchers are too busy and they don’t have the time to be checking how many hours a driver has logged. That is a driver’s responsibility, not mine.” Again, I have to disagree. It is the same responsibility of the company (if not more) to ensure that their drivers are not fatigued and driving over hours. There are many ways to monitor this, from using an Excel template to calculate HOS, to GPS tracking and EOB recorders. At the end of the day, it needs to be done if you want to ensure your records can stand up to the audit. One important point to stress with this section is that what has happened in the past has happened. You cannot scramble weeks before an audit to try and get logs ready for an audit without knowing what has taken place. You must monitor daily, weekly, and monthly to ensure your log books stand up to the audit. And, disciplinary policy must be meaningful, consistent, and be implemented within the specified time period and must account for the drivers’ violations in detail. So, in a nutshell, you need to implement processes to ensure you are monitoring your records and if you have, you should be ready for the audit with open arms!

In summary, there is a lot more that can be discussed and elaborated upon, but I can only hope that carriers realize certain key points:
-If you haven’t implemented appropriate safety practices to cover the above, you need to do so now!
-If you are in the business of commercial transport, safety is part and parcel of your business. Focus on time and resources to ensure safety. At the end of the day, it will affect your business and your bottom line.
– There are many resources available, from people to technology, to help you. But remember, at the end of the day, it is your company and you need to be aware of what is going on.
Finally, one thing that must be realized is that if you are being audited, there is a reason for it. Rather than taking the negatives, look at the positives it can provide. This is a signal that you need to improve, and if you take action now, you can save expenditures and lives down the road. Use the audit as a purpose for learning and improving because at the end of the day, this is your livelihood. Is it not worth the effort?