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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OSHA Training and “Drivers” – are They “Invisible Employees?”

A colleague sent me a link to a blog article titled; “OSHA Training: The “Invisible” Employees”.  It got me wondering whether company drivers are so-called invisible employees when it comes to being included in all types of OSHA mandated training….

Here’s an excerpt of the original article:

Hello – can you see me? I must be invisible when it comes to OSHA training. Or maybe I am just exempt from all safety training regulations? Surely not!

I mean, if there was a fire or explosion in our building, I am curious to know what the company expects me to do. Is there some kind of alarm or signal to warn us to evacuate, or a place where I am expected to assemble? How would they know I got out safely? I wonder, but yet I have never been trained about this sort of thing.

And if a nearby co-worker suffered a heart attack or other serious medical emergency, I am not sure exactly how I should react. Does our company have a procedure in place? Maybe I just call an ambulance? Does anyone here know first aid or CPR? I have no idea, as our company’s safety manager never trained me about this sort of thing either. And while I’m at it, what am I supposed to do if a tornado is reported to be headed in our direction? Do I go get in my car and drive away? Or crawl under a table somewhere? I don’t know what the company expects of me, as I have never been instructed on what to do in this situation, either. I guess maybe I’m on my own.

The posting continues on offering additional scenarios covering potential injury/illness generators that may not be fully addressed unless “all” employees are fully trained on a regular basis.

So does the fact that most drivers stay out of the manufacturing plant (in, say, a private fleet operation), keep them from getting all the training that in-plant workers receive?  What if they have reason to transit the production floor to visit HR or attend a safety committee meeting?