HNI recently held a workshop called FMCSA Safety Audit Requirements and How to Prepare
, featuring FMCSA and Wisconsin State Patrol officials talking about new policies and procedures in place.
It was brought to our attention that not only is FMCSA's auditing process changing, but so are the techniques used by the auditors.
With CSA being the most common reason for a visit from FMCSA, most carriers will not receive a "full compliance review" but instead will receive a "focused review." This is usually listed at a "non-ratable review." That means the inspector cannot issue a satisfactory rating -- but he or she can reduce a fleet's rating to conditional or unsatisfactory.
This will occur if they discover a violation (or violations) during the review which in a full compliance review would cause the carrier to receive a conditional or unsatisfactory rating (for instance, hours of service violation that results in a pattern of non-compliance or more than 10% for any one type of violation).A Closer Look at the Maintenance Basic
Another interesting thing was how FMCSA is focusing on best practices and procedures internally so inspectors are more effective at ensuring compliance.
For instance, take the Maintenance Basic and DVIRs. With the information gathered from CSA, the FMCSA is looking at the percentage of defects in the maintenance area vs. the number of inspections. If done correctly, common sense would dictate that the percentage of defects uncovered in the DVIR process should have similar results to those uncovered during a roadside inspection.
The reality is that the DVIR process shows a significantly lower percentage of defects than those discovered during a roadside inspection. This is telling us that drivers are either not listing defects or that they do not understand the DVIR process.
Many drivers think that the DVIR process is a "post trip inspection" where you list what you discover during an actual inspection, whereas the regulations state:396.11
a) Report required. (1) Motor carriers. Every motor carrier shall require its drivers to report, and every driver shall prepare a report in writing at the completion of each day's work on each vehicle operated...
And:b) Report content. The report shall identify the vehicle and list any defect or deficiency discovered by or reported to the driver which would affect the safety of operation of the vehicle or result in its mechanical breakdown. If no defect or deficiency is discovered by or reported to the driver...
This means the driver is to fill out the report and list anything that he/she was aware of or was notified was wrong with the unit(s) that day!DVIRs Done Right
So, what is a carrier to do? During the event, a number of people described their processes for ensuring DVIR completion and accuracy. Some ideas to consider:
1. Make sure your drivers are properly trained and that the culture of your company requires proper pre-trip and DVIR procedures, with no exceptions allowed.
2. Have a process in place that ensures that whenever a mechanic performs a repair that should have been listed on the DVIR but wasn't, the mechanic should immediately report this to the safety director.
3. Have someone assigned to notify the driver when there is a DVIR error, meet with him or her, and make sure he or she receives proper training (along with documentation) to ensure this does not happen in the future.
4. Use your supervisors as a check and balance. Get out there and make sure your drivers are doing thorough pre-trip inspections, and periodically do spot checks on the truck for any issues that may have been overlooked.
5. Have some fun and make it a challenge. Randomly put some sort of a sticker or marker on various locations on units that a driver will see if he/she does a pre trip inspection (Make sure you keep track and note where and when they were placed). Anyone who finds a sticker is to call in or stop by safety and report it. Each month have a drawing from those who turned in their stickers (if you didn't find all or missed one your disqualified for the month) and give away a prize. Contact drivers who do not call in and make them show you how they do pretrip inspections and make sure they understand that not doing them is not acceptable.
Best practices don't have to be complicated.
It's not just about CSA. We don't want people needlessly injured, roadside breakdowns (along with the roadside repair expenses), and customer service failures related to our equipment. We want to know when something is wrong. It's usually cheaper to fix something then to let it develop into a larger issue.
In short, it's worthwhile to develop a simple process that ultimately not only helps you to be compliant but also saves you money and improves your efficiencies over time. Don Jerrell is associate vice president of HNI, an insurance and business advisory firm. Related Stories:3/22/2012 How Do You Know Your Drivers Are Doing Proper Inspections?4/30/2012 How Automated Pre-Tripping of Trailers Could Help Fleets with CSA7/5/2012 Top 5 Vehicle Maintenance Violations 5/14/2011 CSA and the Maintenance BASIC