The key element of Ontario's CVOR system that serves to get the attention of an operator is the warning letter alerting the carrier of an unacceptable level of compliance. While such a letter may be s...
The key element of Ontario’s CVOR system that serves to get the attention of an operator is the warning letter alerting the carrier of an unacceptable level of compliance. While such a letter may be sent for any particular reason, for the most part it is sent when the overall violation rate of the carrier rises to above 34 percent of the set threshold level, combination of accidents, convictions, and roadside inspections with out-of-service defects found.
It is important such letters not be ignored. They should be viewed as giving the operator “the jump” on further action. It allows you to develop your own internal action plan to improve compliance rather than having to develop and sign off on one at an interview with the Ministry. Here’s what I would suggest upon receiving such a letter:
First, if the letter notes that fines assessed have been unpaid, verify the accuracy of this information. Better still, pay a visit to any Provincial Court and get a copy of your ICON. This is the data record of all matters that are before the courts and those where a fine has gone into default. If everything checks out with that record, pay those outstanding matters. Having those hanging around is simply waving the red flag.
Second, review a current CVOR abstract. Verify that all information is correct and you’re not carrying someone else’s baggage. While this doesn’t happen often, we have seen instances of such, particularly where the CVOR is extensive. Verify driver names and vehicle plate numbers.
The warning letter received is a form letter and will make reference to all event factors (convictions, accidents and inspection rates) as being unacceptable. Usually this is not the case and the problem is focused. Take a hard look at the record and find out where the real problems are. There may have been a period of several accident events, a string of bad luck so to speak. But if accidents are indeed a problem, determine the nature of accident involvement, not simply whether your driver was at fault. Were they preventable? Is there a pattern to the time of accidents, locale, type of load, or type of accident? I recall years back a large US-based carrier that focused on training drivers as to the most appropriate spots to park at truck stops. Their efforts paid off and in the first year saved the company $70,000 in damage claims.
The nature of convictions will often yield interesting information. Again, look for patterns, trends and changes over the past two to three years. Close scrutiny can generally point to a lack of training, perhaps of drivers or maintenance personnel. In yet other instances a review will show a lack of driver discipline or control. And be sure to look for those convictions that you were unaware of, such as the moving violations, log and trip inspection convictions where the driver knew he or she was in the wrong and simply paid the ticket. At six CVOR points a pop, it doesn’t take many to put a small to mid-sized operator at the compliance threshold. As an aside, I would strongly recommend that all carriers make it a “hard policy” that they be informed of all citations received by drivers.
Vehicle inspections have been a particular focus of the Ministry. Also where defects are found and charges laid, the total accumulated points can be very high. For example, three out-of-service defects along with a brake charge and perhaps a trip inspection charge against the driver will result in 13 CVOR points if convictions are registered. Toss in a fail to display an annual inspection decal and add another three points. The bottom line is to get a good handle on both periodic and routine maintenance, and pound into drivers the critical importance of conducting trip inspections.
Once all the preliminary assessments have been done, develop an action plan, modify it if need be, but stick with it. Develop your criteria and plans as to how accidents are going to be reduced. Set targets for reducing convictions, picking a couple of types where you plan to virtually eliminate them in future. With vehicle inspections plan to scrutinize every roadside report and where there was a defect found, why it occurred and how it would be prevented in future. Focus particularly on vehicle trip inspections, perhaps randomly asking drivers to conduct one in the presence of your mechanic.
Remember, it’s your action plan. It’s not the elements of it, or how you do it that count the most. It’s whether it works.
One of the more important positions in the Ontario Ministry of Transportation as a direct interface with the trucking industry is the Head of Carrier Control and Sanctions. There has been a recent change.
Mike McKay has replaced Marg Mooney who retired from the Ministry. Mooney was one of the key staffers involved with the development of the CVOR system and more recently the sanctioning process .
McKay started out as an on-road officer, worked in the old Investigations and Prosecutions Office during the 1980s, was a facility auditor during the 1990s, and then moved into administration of the facility audit program. It seems to me he has audited or knows about nearly every carrier on the continent. The breadth of his experience will serve him well in a role that requires understanding and fairness.