Alternative Compliance Strategies for Motor Carriers

smc 1According to an article in the October 6th online issue of Fleet Owner (click here), the FMCSA is considering comments on whether to construct a plan for alternative compliance strategies for regulated motor carriers.

The article’s tag line sums it up nicely: “Agency to look into whether carriers should get credit for adopting technologies or advanced safety programs

Based on comments from Jack Van Steenburg, Fleet Owner reports an agency interest in “…recognizing carriers for steps they take to increase safety that aren’t required by regulation. Alternative compliance might involve use of safety technologies or perhaps safety management practices – driver health and wellness programs, fatigue management programs or use of the Pre-employment Screening Program – that go beyond what is required.

Simply put, if a carrier goes well beyond the minimums and invests in safety (i.e. wellness, crash reduction, etc.) then their improvement in their Bookend BASICs (Unsafe Driving and Crash Rate) ought to reduce their likelihood of audits or interventions by FMCSA.

Large_Trucks_Cover_Front-300x287Central to this issue is the determination of what sorts of programs would potentially qualify carriers to get relaxed scrutiny?  If select technologies or products are highlighted, it could be boon to those manufacturers or resellers.

Countering this idea is the notion that fleets who already go beyond the minimum standards in their quest to reduce crashes also already benefit from lower SMS Scores and would fare well under the newly proposed Safety Fitness Determination (SFD) rule which would assign an “absolute rating to each carrier, not a relative score as seen today under [the present] CSA [program]“

I would suggest to FMCSA to consider the value of setting up a voluntary certification program (either self-certification through an online application and validation process or one administered by a third party agency such as CVSA, et.al.)

The Transportation Research Board produced a Commercial Truck and Bus Safety synthesis (#12) on “Commercial Motor Vehicle Carrier Safety Management Certification” waaay back in 2007.  We would expect that the article’s findings should remain reasonably consistent over time.

The stated objective of this synthesis report is:

…to (1) document current information on existing commercial motor vehicle (CMV) safety certification, self-evaluation, benchmarking, and best practices programs, (2) identify major common elements and protocols, and (3) critically assess evidence for the crash-reduction effectiveness of the programs….One of the potential applications of safety management certification and self-evaluation programs is as a supplement or alternative to governmental regulatory approaches to carrier safety management. The synthesis specifically examines the possible relationships between (a) results of certification and self-evaluation programs and (b) the more conventional compliance programs.

Synthesis 12Based on these comments, I would think that the entire document would be very pertinent to this present-day discussion.

When I first read this Synthesis article back in 2007, I investigated several of their recommended sources for certification.  Of most interest were the International Organization of Standards (ISO) 9000 certification and the Canadian Standards Association Safety Management System’s standards (“B619-00
Carrier Safety Management Systems”) (Click HERE).

Interestingly, the Minnesota DOT had produced a report as early as 2003 praising ISO 9000’s effects on accident reduction (CLICK HERE).

Trucksafe1Also noted in the original Synthesis report was the Australian Trucking Association’s accreditation program “TruckSafe” (Click HERE) which (as of 2002) had documented that participating, accredited members were “… involved in 40% fewer accidents than non-participating carriers and that participation is also associated with lower worker compensation and maintenance costs

Admittedly, certification programs are not a panacea to permanently solve a fleet’s crash problems. Clearly, a fleet’s management team that becomes dedicated to meeting a higher minimum standard will go through many steps to increase management oversight and control. That stair step improvement process alone would reduce crashes, but could that improved level of performance be sustained indefinitely by merely becoming certified? That’s a good question to ask, but a poor reason to ignore the immediate benefits of certification as a possible mechanism to provide “alternative compliance” with the FMCSRs.

If you are involved with fleet safety, fleet insurance or fleet risk management, I’d urge you to consider the benefit of investigating certification programs — voluntary, self-directed or as part of an association or official standards program.

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Preventing the tragic consequences of unsecured loads – Department of Transportation

Yesterday (10/7/2014), the Department of Transportation posted a blog article that was very interesting.  Here is a link to the source document – Preventing the tragic consequences of unsecured loads – Department of Transportation.

SafetyFirst has previously published “ten-minute training topics” on load securement and on dealing with “road debris” crashes.  While most commercial drivers are well trained and experienced in securing the cargo they carry, some drivers may be in a rush or may make risky assumptions:

  • “it’s a short trip – nothing will go wrong”
  • “this junk is pretty heavy — it’ll stay put without moving around”
  • “I don’t think we need to use a tarp — this stuff won’t fly out at road speeds, besides we won’t be going that fast”

Many drivers do take chances, and tragically it can lead to crashes, damages, or injuries.  Take a look at this short video from the Washington State Patrol:

MVR as Medical Cert?

Did you realize that individual state governments are in process of holding the details of FMCSA regulated drivers’ medical records?  And that these details will be provided through enhanced MVR reports?

Heavy Duty Trucking provided an excellent overview of this new approach in a recent article (click HERE)

E-DriverFileOur E-DriverFile program was modified and tested to receive the new medical details two years ago!  We’re ready to pass this information as individual states complete their processes to collect and distribute this sensitive information to regulated motor carriers.

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Autonomous Technology for Backing

There are a growing number of manufacturers developing autonomous driving features. Some focus on enabling the vehicle to drive down the road with the driver relaxed or reading a book.  Others have different goals or benefits.

One project being developed by ZF Friedrichshafen AG enables their “ZF Innovation Truck” to be piloted remotely through a touch-sensitive tablet device.

I could imagine a time where a tractor trailer driver has to back into a narrow space with obstacles on either side.  Instead of using mirrors and spotters, he or she could hop out of the cab and use their tablet device from outside the rig.  This would enable them to visually inspect clearances while maneuvering the rig into the precise spot needed.

Check out the video.

Additional details on this project can be found in the September 2014 issue of FleetOwner magazine (page 46 – Technology Column)

53 foot trailer

Commercial Vehicle Insurance

SafetyFirstAn interesting article titled “Insurance: You Can’t Avoid Risk” appears in the September 2014 issue of FleetOwner.

This article caught my attention at the second paragraph:

Crashes involving trucks and the resulting insurance claims can grab quite a chunk from the bottom line of any motor carrier [or any company operating a fleet of vehicles – SF]. According to data compiled several years ago by the Federal Motor Carrier Safety Administration (FMCSA), the cost of a crash involving one Class 8 tractor pulling a single 53-ft. trailer runs to $172,292.  If just one person gets injured in such a crash, the average cost balloons to $334,892.  And if a fatality occurs in such a crash, the average cost skyrockets to over $7.6 million.

The article also comments that insurance costs to cover premiums and out of pocket costs can be as much as 4% of the total cost of operation (TCO).

PoliceFleets looking to reduce their costs can ask for discounts and creative payment plans, but in order to materially reduce insurance expense, the only long-term solution is to earnestly work to reduce their risk of loss through aggressive and tailored crash-avoidance strategies.

Naturally, we can’t control how the general public drives on any given day, but as transportation safety professionals, fleet management teams can work with their commercial drivers, insurers, and current safety vendors to increase results.

Ideas to consider:

  1. Smash through the most common barrier to results: complacency. Many fleet teams think they’ve done all that they can and sometimes it can be hard to re-evaluate and re-tool programs to get better results.  “We’ve always done it this way” and “don’t fix what isn’t broken” are dangerous phrases if you’re sincere about enhancing risk results. It’s easy to assume that everything is working well and focus on trying “new stuff” just because it’s new and trendy, but sometimes it’s the underlying (un-sexy) tasks that are slipping through the cracks.  Be honest in evaluating what’s working and what could work better.
  2. Increase vigilance and safety awareness – just as consciously scanning the road ahead for possible hazards and motorists who may cut off trucks is critical to safe driving, management teams also have a responsibility to forecast ways to increase safety in their operations and processes.  Careful analysis of past crashes and understanding what might have contributed to them happening from a process and systems standpoint may uncover opportunities to improve your management strategy.
  3. Develop an even stronger communication strategy with drivers – not just talking at them or demanding more from them, but also learning to listen carefully to their feedback about what’s working and what’s failing to work as well as it could or should. Understanding what processes and systems keep drivers from excelling at their job and helping them with appropriate assistance could be an area to leverage.
  4. Integrate technology where it will help the most.  Technology can be applied in most fleet operations to help deliver insights into ways to increase efficiency or improve safety factors.  The trouble is that for most fleets technology can be disruptive as well. There’s a learning curve to adopting new systems and there must be vigilance in translating these data packets into meaningful management action.  If the follow up isn’t helpful to drivers or other team members, then it may not be worth the effort. One example could be adopting an online education program to refresh drivers on basic safety issues.  If the program is difficult to access, or the videos are tedious, too long, boring or poorly executed then drivers won’t pay attention or change habits.  Investing in a system that is easy to use and has interesting, short programs may be a better course of action.
  5. Actively monitor / manage your CSA scores.  While the CSA score isn’t the best indicator of operational excellence, your team shouldn’t ignore this score, either.  The Bookend BASICS have been discussed elsewhere on this blog — Unsafe Driving and Crash Rate.  When the bookends are firmly managed, the stuff in the middle tends to sort itself out, too.
  6. Don’t be shy in asking for help from your insurer.  Most insurers offer loss control support in various ways — consultants, technical bulletins, and other resources are available but only if you ask for them.  Agents can review your current policies to make sure you have appropriate coverage, and help you navigate the service offerings that come with your policy to be certain you’re getting the maximum benefit for the cost you’ve already agreed to pay.
  7. Leverage your existing safety vendor relationships. Many fleets already work with safety support vendors on issue ranging from log auditing to DQF maintenance.
    1. Are you using the most current service offering from each vendor?
    2. Are there new benefits or features that you could be using?
    3. Does your vendor offer a support network, webinars, or other meetings that could introduce new ideas or help you network with peers in order to increase safety results?
  8. Join, and participate in, a vehicle safety networking group.  Hearing about other peer’s experiences can help you save time, get to decisions more quickly and leverage other professionals learning lessons (why make the same mistake, or why not benefit if they’ve already proven something works well?)  Of course, this commitment works best when you’re an active participant – sharing with the group your own experiences.  It won’t work as well if you join and then lurk in the shadows quietly.

Managing insurance costs is important.  You want to have the right coverage for when things go wrong unexpectedly, but you also want to do whatever is practical to avoid claims or keep their costs as low as possible.

There are many safety articles at this blog site to give you more ideas on ways to prevent crashes.

Let us know what you do that works well at your fleet!

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Crash Management Costs on the Rise

The September issue of Automotive Fleet provided some interesting insights in the general rise in post-crash costs affecting corporate and light duty fleets.  In short, crash management costs have risen by 6.2 percent from 2012 to 2013.ramp collisions

The details are what makes the article interesting.  Changes in car design to incorporate more exotic (and expensive) materials (i.e. aluminum, magnesium and carbon fibers) which reduce weight to increase fuel economy are costly to repair or replace.  The number of parts (sub-assemblies, wiring harnesses, etc.) have also increased making repairs more cumbersome for mechanics, and parts availability has added delays in getting vehicles back on the road.

recallPutting added stress on already overworked repair teams are the floods of car and light duty truck recalls.  Pressed to prioritize, parts makers will push the first available components to “new-vehicle production”, the second batch to support recalls and then, finally, to support the replacement part market.

Technology — from hybrid drive trains to safety features like side impact airbags — also complicate and delay repair projects which drives up costs.  Changes in vehicle manufacturing also have an affect on costs — hot stamping of critical components (transforming low-tensile strength steel into high-strength steel) means that the entire assembly must be replaced instead of cutting away the damaged portion and welding in a piece of steel (the structural strength would be compromised).  This can affect pillars, body panels and structural components.

On the flip side, there are ways to contain costs.

The very best way is to never have the crash in the first place!  Fleets with robust safety programs generally have fewer crashes than fleets with “token” safety processes.  How much of a difference did safety make over the past three years?

  • In 2011. the average fleet had 27% of it’s drivers involved in a crash, but safety-centric fleets had only 25% of their drivers become involved in a crash.
  • A two percentage point difference isn’t much, but in 2012 the gap had widened to 11 points (28% of drivers without safety programs versus 17% of drivers in robust safety programs had crashes.)
  • In 2013, the gap was at 12 percentage points (25% versus 13%).

Key tactics to increase safety results?

  1. Tighten hiring standards as much as possible.  Drivers with extensive histories of tickets and crashes are likely to continue in that mode.  A risk scoring model may help you to identify drivers with chronic patterns of poor driving.
  2. Monitor performance of drivers for complaints, near miss activity, GPS data, newly received tickets, how’s my driving hotline issues, etc.
  3. Drivers who haven’t been through driver education in a while, those who’ve recently had tickets, crashes or complaints should all receive a periodic training module to help break up any complacency around driving safely.  Short, tailored programs on specific topics that have been matched to the issues of each driver is a good strategy.  Sitting through long-winded, tedious presentations that run more than 12 minutes is likely to put your drivers to sleep.
  4. Periodic reminders to all drivers to remain vigilant and to refresh basic understanding of the potential consequences of crashes (personal well being, etc.) can help bolster your communication plan.

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