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.

53 foot trailer

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