Six steps to address the challenges spotted in CSA warning letters
September 1, 2011
Now that CSA data is being used to measure fleets and drivers who travel US highways, the Federal Motor Carrier Safety Administration is preparing to deliver the first 50,000 warning letters to those who are already approaching (or passing) a...
Now that CSA data is being used to measure fleets and drivers who travel US highways, the Federal Motor Carrier Safety Administration is preparing to deliver the first 50,000 warning letters to those who are already approaching (or passing) a number of related thresholds.
The content will obviously vary from one envelope to the next. Some documents will come in the form of a basic warning, a call for a corrective action plan, the news of an on-site review or various steps in between. But every letter will still share one thing in common.
They will all tell stories about safety-related challenges.
A tool that has become known as the Safety Management Cycle is one of the keys to tackling any of the challenges that emerge, or even creating a safety program from scratch. A careful look at each step in this cycle can identify unwanted gaps in policies and procedures, and spot a number of underlying issues along the way.
Policies and procedures The Safety Management Cycle is built on a foundation of policies and procedures for a good reason. When combined and uniformly enforced, documented steps offer employees a step-by-step guide to follow on the job.
A well-written policy or procedure is clear and concise, making sure that everyone can understand the company’s position on a particular issue or concern. Put another way, its readers will know what to do and when to do it.
Roles and responsibilities Those who are involved in any part of a safety program need to understand what is expected of them, and how they will be held accountable for various responsibilities. For example, what happens once a driver’s truck is cited for a mechanical defect? Who reports the defect, fixes the problem and documents the work? For that matter, who is responsible for learning why the defect emerged in the first place?
Qualification and hiring As important as that understanding may be, employees need the skills to perform their individual roles. This ultimately means finding the right person for the job.
But a job’s demands can also change over time, especially in an evolving industry like trucking.
Every worker – regardless of their existing experience – is expected to adapt to changing roles, industry practices and regulations. That means employees might need to be requalified to perform a number of tasks.
Consider those who monitor driver logbooks as an example. An existing safety manager may have a complete understanding of the hours-of-service rules that apply to a fleet’s traditional shipments between Toronto and Montreal, yet be unaware of the different rules which apply to the team drivers who cross into the US. This will obviously present a problem if the fleet begins to deliver shipments to California.
A well-structured and documented safety program identifies the specific skills that employees need to have in their evolving roles, as well as any gaps that might exist. With that information, managers even have the tools they need when deciding whether to hire a new employee or reassign people to different tasks. Training and communications Regardless of the safety management program that is introduced, training in the related policies and procedures will be a key to success.
Ongoing communication with every member of the team will also help to make sure that everyone is informed about changes that are introduced along the way.
A documented training program covers every step along the way, and demonstrates due diligence when someone is asked to prove that employees had the skills to perform their roles.
Monitoring and tracking Once a safety management program is put in place, ongoing monitoring can help to ensure ongoing success. One of the most important tools for this task will come in the form of statistics.Details on the number and type of violations, crashes and incidents can be used to establish benchmarks and set targets, clearly defining success and setting individual milestones along the way.
That data can be collected through everything from the CSA reports to provincial safety ratings or internal fleet documents. Insurers, meanwhile, can help identify targets and the best practices that can help to make these targets a reality.
Meaningful action As important as the structure of a safety program may be, its ultimate success will depend on meaningful action. Those committed to making goals a reality – and take the steps to make them happen – will be less likely to receive CSA’s warning letters in the first place.
– This month’s expert is Dave Roth. Dave is the Ontario regional manager of safety and training services for Markel Insurance Company of Canada and has more than 20 years experience in managing safety and operations in the trucking industry. Markel Safety and Training Services, a division of Markel Insurance Company of Canada, offers specialized courses, seminars and consulting to fleet owners, safety managers, trainers and drivers. Markel is the country’s largest trucking insurer providing more than 50 years of continuous service to the transportation industry.