Safety Policy Expiration Date

EdiscoveryWhen did you last review and revise your company’s driver/vehicle safety policy?  What is it’s “expiration date”?

Creating an effective, enforceable safety policy to govern how drivers drive, how vehicles get maintained, what to do in the case of a crash and so on is vitally important for a host of reasons:

  1. Education:  you need to communicate your expectations as a management team so that the drivers know what to do and how to do it.
  2. Compliance:  your standard provides a benchmark for enforcement of minimum acceptable performance
  3. Anticipates contingencies:  well crafted and communicated policies enable managers to deal with the vast majority of situations that may arise during a day, week or month without having to seek guidance from above while providing an escalation path for true exceptions

One thing that the best policy can’t become is “timeless” — the world changes around us continually and as new technologies are introduced and case law is established our policies need to be reviewed to determine whether these changes warrant a revision to the policy.

Setting an artificial “expiration date” on driver/fleet safety policies would be one way to assure that the review is scheduled, budgeted and completed on a periodic basis.  Assuming that policies will be reviewed and revised “on the fly” as changes occur may be fruitless as the demands of the moment may rob even the most dedicated manager of the time needed to complete the review/revisions in a timely fashion.  By scheduling the review in advance, the manager can take a deliberate approach to the review.

ANSI Z15 2012 coverSelf Audit Against an Industry Standard

One way to assure that any policy review is comprehensive would be to conduct a self-audit of the existing policy against a published industry standard or benchmark.  The ANSI Z15.1 “sets forth practices for the safe operation of motor vehicles owned or operated by organizations” and was most recently revised in 2012.  The standard covers seven key areas including “Definitions, Management, Leadership and administration, Operational environment, Driver considerations, Vehicle considerations, Incident reporting and analysis.

While the standard may not cover all details of a specialty operation with unique exposures to loss, it does provide a baseline for comparison.  For the vast majority of fleets, it will cover those critical areas that are found in most driver/fleet safety policies.

Fleets who discover gaps in their current policy can document why the gap exists and whether the gap should be filled or ignored (i.e. the fleet doesn’t engage in that type of operation or the scenario will not present itself in the context of the fleet’s current or anticipated operations, etc.)

Realignment of Policies with Priorities

Many progressive fleet managers and safety managers take time during these reviews to realign safety goals and tactics to assure seamless compliance from both managers and Motivating Drivers to be saferdrivers — in the past, policies were often mis-aligned where drivers were expected to do X while managers told them to do Y. Recrafting the policy to make it work saves frustration, restores confidence in safety leadership and enables people to actually perform properly instead of ‘deceptively’ (either the manager or driver breaks the rules when goals are misaligned with policy).

This is also the time to address the effectiveness of the current policy as measured by past enforcement efforts — if the policy is unenforceable, or very difficult to monitor compliance, then a fresh discussion about compliance monitoring is appropriate.  A policy that is not followed, nor enforced isn’t much of a policy when called to testify on a witness stand following a tragic, and arguably preventable, collision.

All the News Fit To Print…

Another way to address periodic reviews/revisions is to keep a file of news articles announcing changes to regulations or laws that may affect your fleet operation.  Additionally, if any guidance is published about these changes by memorandum, keep a copy of each memo handy to incorporate into the review/revision at the scheduled date.

As the changes are incorporated into the new policy, keep a list of changes made to this edition so that it’s easier to communicate a short list of changes along with the final, revised policy.  This can boost your education efforts since most people would not want to have to re-read the entire policy solely to determine what has been updated.

Summary

Our company helps fleets to re-engineer their existing programs to get stronger results from the vendors they already use. Sometimes they’ve invested millions into programs that worked well for the pilot and then fell flat. Refreshing their approach and assigning Some parallels worth examininganalysts to “work the data mountain” into “urgently actionable” conclusions instead of frustrating “background noise” can rescue ROI from the gutter. Most of this comes from management teams who “wrote policies and bought silver-bullet systems” then stuck the notebook (policy) on a shelf and turned their attention back to their “day to day” after the vendor sales team leaves the building. Building discipline to deal with the mundane and tedious separates the winners from the whiners.

When was the last time your team reviewed your policy from start to finish?  Maybe you can leverage a standard like Z15 to help complete the review quickly, and focus on communicating the policy changes to your drivers and managers as a way to increase safety awareness and shake off complacency before any further collisions take place.

If you need help in conducting a review, call on us, we’re here to help.

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Proposal To Eliminate DVIR when No Defects Discovered

The Federal Motor Carrier Safety Administration (FMCSA) issued a press release today, August, 1st announcing a proposal to drastically cut the paperwork and record keeping burden of many motor carriers.  According to the release the proposed rule would maintain safety inspections while eliminating unneeded paperwork that merely documents that “no problems were discovered” during pre and post trip inspections of Commercial Motor Vehicles.

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Highlights from the release:

Current federal regulations require commercial truck drivers to conduct pre- and post-trip equipment inspections and file Driver Vehicle Inspection Reports (DVIRs) after each inspection, regardless of whether or not an issue requiring repairs is identified. DVIRs are the 19th-highest paperwork burden, based on the number of hours needed to comply, imposed across all federal agencies and only 5 percent of reports filed include defects.

Under the proposed change announced today, commercial truck drivers would continue conducting pre- and post-trip inspections. However, DVIRs would be required only if defects or deficiencies were discovered by or reported to the driver during the day’s operations.

“We can better focus on the 5 percent of problematic truck inspection reports by eliminating the 95 percent that report the status quo,” said Federal Motor Carrier Safety Administrator Anne S. Ferro. “Moving to a defect-only reporting system would reduce a significant paperwork burden facing truck drivers and save the industry billions without compromising safety.”

Federal regulations require that every commercial vehicle in the U.S. undergo a thorough annual safety inspection conducted by a certified commercial vehicle mechanic. In addition, state and federal inspectors conduct unannounced, random inspections of commercial vehicles at terminals, weigh stations, truck stops along the roadside and at destinations. Vehicles that fail random safety inspections are immediately placed out of service and not allowed to operate until the identified safety problems are addressed. In 2012, approximately 3.5 million random inspections were conducted.

The FMCSA will collect and review comments on the proposed rule, which is available at: www.fmcsa.dot.gov/rules-regulations/administration/rulemakings/proposed/Driver-Vehicle-Inspection-Report-NPRM.pdf.  If you have an opinion on this proposed change, make sure to be heard!

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Google Glass & Driver Safety: What Do You See Ahead?

Preemptive action is being considered by the UK Department for Transport in light of the impending release of Google Glass technology.

Google Glass is a wearable computer with an optical head-mounted display (you see data floating in front of your face because its being displayed immediately in front of your right google-glass-drivingeye). Google Glass enables users to interact with the Internet via natural language voice commands so you could get turn by turn navigation to your destination, check for traffic congestion ahead, note detours and construction zones, get weather reports, sport score updates, record videos (it has a camera built in) and much more.

The chief safety concern is that wearing these glasses while driving could introduce new and dangerous distractions to the wearer.

This has prompted action by the UK Department for Transport whose spokesman has said

We are aware of the impending roll out of Google Glass and are in discussion with the Police to ensure that individuals do not use this technology while driving.

It is important that drivers give their full attention to the road when they are behind the wheel and do not behave in a way that stops them from observing what is happening on the road. A range of offences and penalties already exist to tackle those drivers who do not pay proper attention to the road including careless driving which will become a fixed penalty offence later this year.

We are aware of the impending roll out of Google Glass and are in discussion with the Police to ensure that individuals do not use this technology while driving.

In addition to this proactive stance, West Virginia state representative Gary G. Howell has introduced an amendment to the state’s law against texting while driving that would include bans against “using a wearable computer with head mounted display.” In an interview, Howell stated, “The primary thing is a safety concern, it (the glass headset) could project text or video into your field of vision. I think there’s a lot of potential for distraction.

Technology journal “CNET” reports that “In the past Google has offered that it doesn’t see Glassing and driving as dangerous…: ‘We actually believe there is tremendous potential (with Glass) to improve safety on our roads and reduce accidents. As always, feedback is welcome.'”

Several articles on this topic suggest that the general public and at least one car manufacturer (http://www.foxnews.com/leisure/2013/07/30/mercedes-benz-intergrating-google-glass-into-its-cars/) are looking forward to using Glass while driving.

PedestriansWith all the statistics on distracted driving collisions that come from holding a cell phone or checking email while driving, would the design of “Google Glass” make a significant difference in allowing drivers to navigate among pedestrians, cyclists, roundabouts, intersections and stop lights while checking stock tips?

Is the ability to record videos using Google Glass a redemptive quality in that the system could record, save and transmit collision videos directly to the claims unit of the driver’s insurance carrier? Is there an app for that?

Hmmm. What do you think about this device and it’s potential impact on safety?

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