Safety audits can be scary, but they aren’t a crap shoot
March 1, 2001
Much of the time I've spent with trucking companies has been to assist them with government safety audits. While many carriers have been audited several times, one never quite gets used to them.For th...
Much of the time I’ve spent with trucking companies has been to assist them with government safety audits. While many carriers have been audited several times, one never quite gets used to them.
For those who have not faced an audit, there is often an up-front sense of trepidation.
This is understandable.
After all, government is a big club with unlimited resources; they can also wield a pretty big one, too, if necessary.
The primary key to a successful audit is, first, compliance with the regulatory environment you operate in. Second, being able to back up your case by having proper and effective policies and procedures in place, along with the required documentation.
The current safety audits being conducted in Ontario are markedly different from those that were first done 10-plus years ago. At this stage, carriers should know what will be expected of them and what the auditor will want to see.
It’s not a crap shoot in the sense that audits now are conducted in a very orderly fashion, consistent across the board, and with specific points assigned where specific documents are in place and compliance with the law is determined.
To summarize briefly, the facility audit looks at two specific areas: drivers and vehicles.
There is an additional third area (that is optional) that examines various, non-mandatory safety programs.
The two mandatory areas are each worth 50 per cent of the audit score, unless the operator wishes to use the optional safety program area. If so, drivers and vehicles are each worth 45 per cent and safety programs 10 per cent.
The driver audit is heaviest on hours-of-work compliance, with an additional component ensuring that drivers are qualified.
The vehicle profile includes roadside inspections, maintenance records, driver trip-inspections, and annual vehicle inspections.
The safety program component is an examination of what I consider something every company should have in place; items such as CVOR abstract monitoring, regular driver abstracts, evidence of road-testing, accident files, and instruction in hours-of-work and trip inspections. Basics such as these can get you a full 10 per cent of the audit score.
There are a number of tips I would offer with respect to safety audits.
First, in advance of a random audit, the ministry will contact you; at that point, you will likely be given a listing of some of the drivers and vehicles they will be looking at.
Some of the audit is actually done before the auditor even arrives. They will check a driver’s qualification, for example, by pulling his licence abstract.
A vehicle may have been involved in an accident – and the auditor will have a copy of the accident report. As you can see, there is a lot of computerized information they have access to on both drivers and vehicles.
Consider some of the obvious things you should do in advance.
Look at the specific drivers and vehicles they ask for. Make sure that all information with respect to them is properly organized and in the proper files.
One of the key things to do is review a current copy of your CVOR abstract and then start doing the necessary homework. What the ministry will be looking for in relation to your CVOR isn’t rocket science.
Convictions, accidents, and vehicle inspections recorded on the abstract all show time-and-date information. In a nutshell, you will want to look at all driver information shown on the CVOR to see that associated logs, trip inspections, and so on, match up.
If they don’t, you may get the notion that you’re “headed south” on that portion of the audit.
Consider a vehicle inspection where it resulted in an out-of-service defect. On the driver side of things, certainly his log should show that he was at the location of the inspection at the date and time noted.
Second, his duty status must indicate that he was “on-duty not driving.” For the vehicle, first ensure that you have a copy of the inspection report (CVIR), preferably, in the vehicle file.
Check the inspection start and finish time, and then go back to the driver’s log to confirm the time span.
Pull the associated vehicle file. In that file, you should ideally have, along with the CVIR, a copy of the driver trip inspection for that day. Are the defects noted on his or her inspection report?
If these types of up-front crosschecks show all information to be in place, you’re headed for a good audit finding.
Here are some other tips.
The key thing to be pounded home to drivers is to do what you log and log what you do.
Take the circumstances where a driver shaves a couple of hours to get home so his log will show 13 hours of driving rather that 15 which puts him over hours.
The auditor will determine that the log is false. That driver then scores zero on the audit because of that one instance.
If you have a small fleet with only a handful of driver logs being examined, a few of those, and your audit score plummets.
Much better that the driver shows he was over hours and take a hit for such.
This has turned into a biggie.
There are too many times that drivers are not showing fueling on their log, (just ignoring the time), or when they do show it, it’s in an “off-duty” status.
Now there are certain fuel stops where they are off-duty. (When someone else fuels the truck.)
And again with fuel receipts, the greatest majority are time-marked and become easy pickings for auditors to view against the driver log. Check it before the auditors.
It is in your best interest to emphasize, and explain, to drivers the importance of ensuring that all associated documents and on-road receipts contain time-and-date information. These must, in turn, match their daily logs. n
– Blair Gough is a consultant to the trucking industry and can be reached at 905-689-2727.