The following principles regarding accident/incident/injury/violation prevention forms the

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1 EFFECTIVE DATE: March 1, 2015 ROSS EXPRESS, INC. DISTRIBUTION: All Employees SUBJECT: PURPOSE: SAFETY & ACCOUNTABILITY PROGRAM To ensure the safety and health of our employees. To identify and educate those employees with unsafe work performance and behavior. Working safely is not optional; it s a condition of employment. IMPORTANT NOTICE: An employee s failure to follow company and/or safety policies or procedures or failure to use safety equipment which results in an injury may result in the denial of their claim. BASIC PRINCIPLES: basis for an effective safety program: The following principles regarding accident/incident/injury/violation prevention forms the 1. Accidents/Incidents/injuries/violations can and must be reduced in number and severity. 2. We have a Zero Accident Culture - All accident/incident/injury/violation are preventable, predictable and unacceptable. 3. Accidents/Incident/injury/violation prevention is the responsibility of all employees at all levels. 4. All employees must understand that it is to their advantage, as well as to the Company s, to work safely and drive safely, and that they are expected to cooperate to this end. It is each employee s responsibility and duty to work safely. Safety training- IT IS A CONDITION OF EMPLOYMENT. 5. Employees who exhibit unsafe behavior must alter this behavior or face disciplinary action, or removal from Company s employment for their protection and the protection of the public and fellow employees. 6. Active, concerned, responsible leadership is vital to the success of this and any other program.

2 I. POINT SYSTEM FOR EMPLOYEE ACCIDENT/INCIDENT/INJURY INVOLVEMENT: A. This policy establishes a system by which points may be assessed against the accident/ incident/injury/violation record of employees. B. Accident/Incident/injury/violation records will be maintained by the Safety Director of the Company. C. Points will be assessed against an employee's accident/incident/injury/violation record according to the following schedule (as determined by the Board): Employee points system Item Points Preventable Accident/Incident/Injury/violation 3 Non-preventable Accident/Incident/Injury/violation 0 Non-Disclosure of Injury, Accident, Incident, violation or damage to Company/Customer owned property or equipment 9 D. Some Violations may result in Immediate Termination if they are deemed by the Board to be severe. E. Supervisors and Managers will be held accountable for the actions of their employees and for the safety of their operation(s) and all people working at their operations.

3 II. ACCIDENT/INCIDENT/INJURY/VIOLATION REVIEW BOARD: A. Board Duties and Responsibilities: 1. The Board is established to monitor accidents/incidents/injuries and violations involving Company employees and to determine appropriate actions to reduce/eliminate the number and severity of accidents/incidents/injuries/violations. 2. All Terminal Managers whose subordinate(s) has been involved in an accident/incident/injury or violation will in all cases, INVESTIGATE AND REPORT exactly what happened. The Terminal Managers are accountable for the safety of their subordinates and others working within their jurisdiction. Investigations will include a specific focus on PREVENTION. The Board will review the information and recommendations and in a fair and consistent manner shall assign the appropriate points to the employee s file and determine the course of action to be taken to prevent a reoccurrence. 3. The Board has final responsibility for assessing points against the accident/incident/injury/violation records of employees who are involved in or contribute to accidents/incidents/injuries/violations. In determining points, the Board may consider unusual or mitigating circumstances. The decision of the Board after a formal review and after any requested appeals are addressed, is final. In the event that the review board is at a split decision the final decision will be made by the company President. B. Meetings: Board decisions on corrective action and point assessment will be made within 5 days of incident to allow for prompt behavioral changes and retraining. However upon completion of the investigation the board will re-evaluate to ensure the appropriate penalty was handed down given the totality of investigation.

4 III. DISCIPLINARY ACTION: A. The appropriate level of disciplinary action for employees involved in chargeable/preventable incidents/injuries/accidents and violations is determined by the cumulative number of points assessed against their safety records in the 12 months immediately preceding the date of the incident/accident/injury or violation being considered. Points assessed prior to that time will not be considered. Managers and supervisors will be assessed on their response, investigation, reporting and follow-through and will be disciplined accordingly if they do not follow appropriate procedures as outlined in this policy, as it is a condition of employment. The requisite disciplinary action for the various levels of point accumulation are as follows (The Company reserves the right to deviate from this schedule as deemed necessary based on the severity of the situation and in conjunction with other offenses whether related or unrelated to safety): Points Action 3 Verbal warning and mandatory retraining/ *- counseling. 6 Written warning, mandatory retraining/ *- counseling, and suspension for three days without pay. 9 & above Suspension for up to ten days without pay and put on notice of impending possibility of termination. *- Terminal manager written counseling required when no training segment available. B. Types of Accidents/Incidents/Injuries/Violations Which Will Be Reviewed by the Board: All accidents/injuries/incidents/violations as well as vehicle and safety violations and near misses involving all Company employees will be reviewed by the Board. This includes employees who cause or contribute to the injury of another employee or non-employee. C. Process for Investigation, Submission to Board, and Determination of Disciplinary Action Accident/Incident/Injuries/Violations:

5 1. Upon Notification of Injury or Accident Supervisor shall comply with accident procedure by completion of an accident form and/or a first report form and an accident investigation form. ALL VIOLATIONS presented to the company by an employee or outside department official MUST in ALL CASES be IMMEDIATELY forwarded to the Company s Safety Director via fax or . Examples of this are (not limited to the examples) warnings/tickets issued by D.O.T. or warnings/tickets issued by a Police Officer. 2. As a part of the investigation, the involved terminal Manager must interview the injured employee to determine the employee's version of how the accident/incident/injury and/or violation occurred and how it could have been prevented. If investigating an accident or incident pictures of the scene should be taken as soon as possible. The employee will be advised that points may be assessed against his/her safety record and, based on point total; disciplinary action may be taken against the employee. 3. Based on the investigation, the Terminal Manager will prepare an accident investigation form. If the investigation indicates that negligence or misconduct on the part of another employee caused or contributed to the incident, the report should indicate such. 4. The Terminal Manager will review the documentation for completeness, accuracy, and comprehensiveness and at his discretion, may conduct his own separate investigation in conjunction with appropriate supervisors. The Terminal Manager s own investigation will be forwarded to the Board for consideration and determination of outcome. 5. Copies of all documents relating to the accident/incident/injury and/or violation and subsequent investigation will be maintained by the Safety Director. Documentation will include a record of disciplinary action taken against a contributory employee if applicable. IV. SAFETY RECORD MAINTENANCE, REVIEW AND UPDATE: A. Establishment of Safety Records for Employees: 1. The safety Director will maintain safety records for each employee. Records for new employees will be added at the time they are hired.

6 B. Record Review: 1. Annually or more frequently if necessary to include quarterly for high point offenders, as part of our safety program, management will look at points assessed as well as accident/incidents/injuries and violations to determine the performance of individuals and departments for the entire company. The Management will also review the effectiveness of this policy, and consider changes as necessary. The Company reserves the right to change this policy at any time. Our intent is to ensure that all possible steps are being taken to correct problems and ensure the safety of all. Ross Express Safe Driver/Dock/Maintenance Program Summary Any driver, dock and mechanic who completes the calendar year for his terminal (terminal calendar years are defined below) free of any accidents, injuries, incidents and violations, will be entitled to the following: An eight (8) hour paid time off Safety Day ² One free pair of Shoes for Crews safety-toe shoes Safe Driver Recognition Award To be eligible, drivers, dock, maintenance must have been employed and must perform their duties for the full terminal calendar year, defined as follows: Auburn, ME -- October 1 st thru September 30 th Bangor, ME January 1 st thru December 31 st Boscawen, NH February 1 st thru January 31st Enfield, CT June 1 st thru May 31 st Sutton, MA February 1 st thru January 31 White River Jct, VT May 1 st thru April 30 Violations include, but are not limited to, speeding, reckless driving, leaving the scene of an accident and any offenses that would result in disqualification of a CDL driver per the Code of Federal Regulations, Title 49, subpart and CSA roadside speeding violations. ² Safety Day use must be scheduled in advance cannot be used as a sick day and cannot be added to vacation time.

7 DEFINITIONS: Accident: Vehicle accident or work incident that causes damage, harm, near miss of damage or harm or one that results in a traffic violation or Company safety violation or other Company policy violation. Board: Safety Director and the involved employee s Terminal Manager whose employees are being assessed. Incident: Any behavior or action that could lead to personal injury or accident. Injury: Bodily harm that requires an injury report. Non-preventable: An accident/incident/injury/violation that is deemed by the Board as unpreventable by the employee and subsequently, not the employees fault. Preventable: An accident/incident/injury/violation resulting from not using/observing the appropriate safety precautions and procedures where the employee is shown to be at-fault. Violation: Any violation of state or federal rules, regulations or laws while in any Company Vehicle or on-duty with the company. Violation is further defined as a disregard to a Company policy. EFFECTIVE DATE: March 1, 2015 RESPONSIBLE DEPARTMENT: Safety Department President Ross Express