They’re two of the most important words in the vocabulary of a safety manager: due diligence. You know it. But if you want to impress upon your operations group the importance and financial significance of what fleet safety and compliance brings to the table, then bring your operations, dispatch, and driving personnel together for the following exercise.

They’ll need one tractor equipment maintenance file; one trailer equipment maintenance file; one driver’s log book file for a one month period; one driver’s qualification file; and your company’s written safety and maintenance policy, driver handbook, and accident register.

Read the details of the following incident — a hypothetical example for training purposes only — and then answer and provide all the requested follow up items to prove “due diligence.”

It’s on the TV news: “A fiery collision involving a car and two tractor-trailers early this morning resulted in the deaths of two people,” the story begins. One tractor-trailer was carrying jet fuel to the Buffalo airport. The other vehicles involved were a local motorist in a car and a tractor-trailer belonging to your company. You piece together some details: At the time of the collision, the temperature was just below freezing, so black ice may have been a factor. And it was dark: the accident happened at 5:31 a.m.

But according to police at the scene, your company’s unit jackknifed on a downhill grade and the trailer swung into the lane of oncoming traffic — in which the fuel truck and motorist were approaching.

Evidence collected by the DOT and a police accident re-constructionist team indicates that the fuel hauler was operating at an appropriate speed for the conditions, and that his vehicle’s mechanical systems were in proper operating condition. Further, based on a review of the fuel carrier’s maintenance records, the tractor and trailer unit each passed annual safety inspections a week earlier.

Fatigue doesn’t appear to be an issue. The tank driver was coming off a four-day vacation and his logbook, closely checked by the investigators, showed plenty of hours available. Fuel and toll receipts confirmed the breaks he’d logged.

The tank driver’s experience was well documented. He had a 20-year accident-free history and had been through training in defensive driving just two months earlier. He completed his annual check ride at the same time as the driver’s annual certification process. The evaluator noted no areas of concern.

All of this was clearly noted in the driver’s training file. The annual abstract review showed no moving violations for this driver. Management on completion of the annual review process and check ride had signed off and completed his “annual re-certification as qualified to drive.”

Investigators decided that the skid marks indicated that the car driver likely panicked and manoeuvred his car so that he forced the fuel hauler off the road and into the path of the jackknifed unit.

So now the investigation is focused on your equipment and driver and officers are at your door and want to see the following records and what they say about your operation.

1. Age of driver. Remember, to work in the United States, a commercial driver must be at least 21 years old.

2. Length of commercial driving experience. What is really an acceptable minimum?

3. The company’s minimum hiring standards. How many moving violations will you accept on a driver’s abstract? Is this number reasonable?

4. Will you accept any of these types of moving violations: impaired driving, dangerous driving, ADLS suspension, multiple repeat violations for excessive speeding and/or following too close?

5. Driver file: Is it complete and current? (See list of driver file requirements, right.)

6. Review of the driver’s abstract and driving infraction and accident history. Is it reasonable? Have poor driving behaviours been addressed? Is there a progressive discipline policy for drivers with repeat problem behaviour?

7. Who qualified the driver’s references and completed the orientation training?

8. Review the pre-hire road test. Were any deficiencies noted? If yes, what corrective training was done? Or do you accept a commercial licence in lieu of a road test?

9. Review the driver training program. Is the training material you use recognized, and of good quality? Was the training completed, signed by the driver as received, documented, and placed in a training record file?

10. Itemize all company-provided safety training. Example: defensive driving/night driving/handling winter road conditions.

11. Copy of drivers’ logs for the last seven days. Are they clean, or can you find evidence of falsification?

12. Do your drivers properly log all the time spent at the border, including delays ? Alternatively, do your drivers show border-crossing time as “off duty” or simply mark 15 minutes like some do. Or worse, do they even document their border crossings?

13. Can you provide the vehicle maintenance records from the original in-service date for the tractor and trailer?

14. Can you provide a current copy of annual mechanical inspection certificates for the tractor and trailer?

15. Can you provide a copy of the carrier’s written preventive maintenance policy and PM interval schedule?

16. Can you provide a copy of the vehicle maintenance policy and PM schedule for your owner-operator equipment?

17. Does your owner-operator’s maintenance file clearly demonstrate the vehicle complies with the company’s stated PM interval policy?

18. Are there back-up receipts to prove that the maintenance work noted was actually completed?

19. When and what were the last recorded tire tread depth measurements for both vehicle units? Are they in compliance?

20. When and what were the last recorded brake measurements for both vehicle units? Were they in compliance?

21. Do you have a protocol to facilitate immediate drug and alcohol testing for drivers involved in an accident while operating in the United States?

These are all the different items and file documents you could use to support a “due diligence” defence for your company and for your driver. It can’t be hastily pulled together. That’s why it’s important to involve your operations people in “what if” exercises, so when you approach them for information for a driver file or maintenance record they understand the need for complete and accurate data. Because you never know when your files will be put to the test, you want to always be ready for when the time comes.