Understanding the FMCSA Safety Management Cycle SEPTEMBER 15, 2014

Transcription

1 Understanding the FMCSA Safety Management Cycle SEPTEMBER 15, 2014

2

3 Understanding the FMCSA Safety Management Cycle SEPTEMBER 15, 2014

4

5 FEDERAL MOTOR CARRIER SAFETY ADMINISTRATION

6

7

8 FMCSA Safety Management Cycle

9 The Elements Policies And Procedures Defines The What And How Of A Motor Carrier s Operations. Policies Establish The Guidelines For How Motor Carriers And Their Employees Behave In A Given Situation. Procedures Explain How To Accomplish Policies.

10 Elements Roles And Responsibilities Clearly Defines What Each Employee Should Do To Successfully Implement The Policies And Procedures. Qualification And Hiring Discusses Recruiting And Screening Applicants To Fulfill The Roles And Responsibilities For Positions.

11 Elements Training And Communication Outlines A Motor Carrier s Communication Of Its Policies, Procedures, Roles, And Responsibilities So That Everyone Understands The Expectations And Has The Adequate Skills And Knowledge To Perform Their Assigned Function. Monitoring And Tracking Concentrates On The Need To Have A System In Place To Monitor And Track Employee Performance That Enables Companies To Be Aware Of Their Employees Safety Performance And Compliance With Its Policies And Procedures And How They Execute Their Roles And Responsibilities.

12 Elements Monitoring Represents The Motor Carrier Looking At The Performance Of The Operation, And Tracking Is Assessing The Data Collected Leading To Meaningful Action. Meaningful Action Gives Motor Carriers The Tools To Correct Or Improve Employee Behavior, Including, For Example, Refresher Training And Positive Reinforcement Such As Rewards Or Bonuses, In Order To Improve The Motor Carrier s Overall Safety Performance.

13 Assessment Steps Assess Why The Breakdowns Are Occurring Identify Safety Improvement These Problems. Practices (SIPS) To Address SIPS Are Identified Within Each SMP And Motor Carriers Can Implement Them To Begin Improving Their Safety Performance. Select And Prioritize Safety Improvement Practices To Address Improving Safety Compliance, Create An Implementation Plan Appropriate For Company Size And Available Resources, Implement The Plan, And Monitor And Track Progress And The Effect On The Company s Basic Percentile Ranks Over Time.

14 What Should You Be Doing? Review Each SMS Category - Behavior Analysis and Safety Improvement Categories (BASICs): Unsafe Driving Hours-of-Service Compliance Driver Fitness Controlled Substances/Alcohol Vehicle Maintenance Crash Indicator Take Out Your Policy And Procedure Manual Do You Have A Policy And Procedure Manual? If Not, And You Are Lancer Insured, The Lancer Safety Book Provides A Simple And Direct Link To Each Of The Elements Previously Reviewed

15 Investigation Results Recent Investigations in CA- of 15 investigations: 2 satisfactory, 11 conditional, 2 unsatisfactory Time frame to receive results? days to respond to FMCSA- When will they come back to re-investigate you? Can you be written up for time between investigation and contested issues during the reinvestigation? Fines- how much is a satisfactory worth?

16 Appointment Letter

17 APPOINTMENT LIST

18 Begin With Maintenance Policy and Procedures for: PM, Recalls, Routine Repairs, Large Repairs, Body Work Can you track all requests, parts, receipts, outside vendors work and is it documented in you Vehicle File? How Do You track DVIRs and information/repairs that result from them How is this linked to Driver training, supervision and after trip information How is your disciplinary process connected to problems with maintenance including the driver, operations and mechanic Do you evaluate your outside vendors?

19 Unsafe Driving Can your document how your driver recruiting, hiring, training, discipline programs link to the specific issues found in Unsafe Driving This is generally related to speeding, not wearing a seat belt or unsafe lane changes Do you Review each and every citation ( both FMCSA and moving) Can you demonstrate how your training and retraining program have made an impact on your SMS score for Unsafe Driving and your video, GPS information Are any of your accidents related to these events/inspections and can you demonstrate how you are managing the information you receive as well as the information from your daily operation.

20

21 Hours of Service Compliance Driver Logs- Who is responsible for errors? What is your policy for correction and discipline for drivers who never seem to get it right? Do you link the time of a trip, to the mileage and speed via EZ Pass etc? Is there a difference between Form and Manner and ongoing HOS issues? How does your training and discipline program link to these issues?

22 Driver Fitness Can you connect the dots between the regulations ( DQ files etc) and your daily operation for CDL and Medical renewals? Do you check to see if every driver has their CDL and medical card with them every time they leave the yard? What is your process for reminding the drivers of their responsibility to remain legal in regard to their CDL and Medical? Do you monitor medical conditions that are noted on the Medical as well as the length of the medical approval?

23 Controlled Substance/Alcohol Who is responsible for your program? Who monitors it ( for all types of tests) Are your Pre-employment tests results received and reviewed before you send a driver out Random selection AND random testing both have to reviewed and monitored on at least a quarterly basis If the consortium makes an error who is responsible?

24 Crash Data/Claims Does your policy and procedure manual as well as your ongoing operations review(s) include the how and whys of any claim ( small or large) Do you monitor the claims you manage yourself? How do they relate to the other problem areas of your operation, both SMS related and internal, ( non SMS) issues How many claims/crashes are related to a driver or a group drivers and how do you relate that to you hiring, training and disciplinary program? Time of day, day of week, type of vehicle, location, repeat type of event(s), passengers in vehicle or not, weather, season( month). Is there a year to year comparison?

25 ADA Can you demonstrate how your ADA training, lift equipped buses, reservationists, operations and dispatch all work together and communicate the information about every trip? New? Sensitivity? How does customer service training, communication training and staff communication play out in your operation? Do you have an ADA procedure manual for EVERY employees? Do you have information or a link for customers to identify their need for special assistance. Annual report?

26 Other Issues How do you manage driver training for vehicle type, model, size and features. Can you demonstrate the impact of the training either via success or crashes/errors Can you trust that your non-driving staff are as comfortable with your policies, procedures and operations as your driving/maintenance staff?

27 Comments from Recent Investigations Did Driver falsified logs when he as a volunteer drove a van with some students--church school, van was not a CMV, he was not directly compensated but he was able to get lunch and attend the function for free? Company leased a unit for 5 weeks, unit had annual inspection that was current at time of the lease--inspector wanted to see copy of annual inspection--leasing firm would not share it with insured or inspector... Violation or not?

28 Recent Comments What is your plan when a trip which may exceed 10 hours- is that a violation? When is a cracked rim a cracked rim? Do you need a hotel receipt if the group pays for the hotel? Does a driver need to be a mechanic or have tools with him during an inspection

29 Final Issue(s) Can you articulate YOUR safety and compliance PROGRAM? Are you prepared to demonstrate all of this without forms but via your operations manual, daily review of operations, documentation of ongoing assessments of issues? Do you link customer compliments and complaints to your quality review process? Do you link your claims ( small and large) to your quality review process?

30 QUESTIONS?

31 THANK YOU!!

32 Bob Crescenzo Lancer Insurance Company Ken Presley United Motorcoach Association