If there’s one there’s one thing Gino D’Andrea has learned during his 14-year career with TACC Construction, it’s that your ability to handle big jobs well depends on doing the little things right. TACC installs city watermains and sewers around the Toronto area, jockeying huge sections of concrete pipe weighing as much as 22 tonnes each into trenches 15 meters wide and seven meters deep. A work crew’s productivity hinges on moving only as much earth as is absolutely necessary. The more productive a crew can be, the sooner TACC can close up its deep groove in the soil, lay down pavement, and get the water and traffic flowing.
“Jobs of that scale, you can’t be making things up as you go along when you’re on site,” says D’Andrea, a former project superintendent who manages the company’s fleet operations. “The way you stay on time and on budget is by making sure everyone knows what to expect from day to day, and by always thinking ahead about what you’ll do when you run into surprises.”
The company’s proficiency is rooted in a roll-up-your-sleeves style of project planning. D’Andrea, TACC Construction chief operating officer Carlo DeGasperis, and other supervisors sweat the details of a job long before anybody sweats on site. “We never want to put someone in a position where he’s making decisions that might compromise safety because we overlooked something in the early stages,” D’Andrea says.
Risk is something TACC tries to control more tightly than any other aspect of its work. The company operates about 170 pieces of construction equipment-backhoes, bulldozers, cranes, graders, and the like-and a small fleet of trucks and trailers to support them, all out of a single facility based in Woodbridge, Ont. “The trucks were always a bit of a challenge for us,” D’Andrea explains. “We have a safety and maintenance program for our heavy equipment, but it’s not regulated in the same way the Ministry of Transportation regulates the trucks and drivers. We were running our trucking operation to a high standard, but it was to our standard. We didn’t know exactly what the province required.”
In the mid-1990s, when several high-profile accidents in Ontario turned a harsh light on trucking industry safety practices, TACC decided not to wait for an auditor to darken its doorstep.
The company hired an outside consultant not only to explain the rules but to show how to follow them. Phil Slater, president of Brampton, Ont.-based Slater Safety Systems, started with a review of TACC’s safety polices on vehicles and drivers, and making sure drivers were properly trained in load security, hours-of-work rules, and trip inspections. He created checklists and filing systems to help managers wrangle the paperwork associated with compliance, and installed software that alerts managers to critical events in areas where a provincial auditor can lay charges and levy substantial fines, like when a vehicle requires inspection or a driver’s licence is about to expire. Since no one person at TACC is in charge of compliance on the trucks and drivers, Slater had to break up the job into smaller chunks and delegate them among several people.
“The nice thing about TACC is that a safety culture was already there when we showed up,” Slater says. “Everybody knew their individual job, and no one wanted to get their compliance program organized just for the sake of passing a test.”
It’s not typical of a lot of fleets similar in scope to TACC. Because they operate locally, with few trucks and limited exposure to on-road enforcement, many believe they’re below the radar and will never face a facility audit. They thrum with activity when that notice arrives, as managers and clerks scramble to whip up loose ends. Everything else in the office grinds to a halt.
Indeed, most truck operators are tagged for compliance reviews because their accident reports, driver and vehicle roadside inspection reports, and police reports on traffic violations indicate a safety problem. So if you’re not having accidents, if you’re not failing inspections, the chance that you’ll be selected for an audit is slim, says Greg Catteeuw, director of compliance and regulatory services with the Manitoba Dept. of Highways.
The reason, he notes, is simple: like other enforcement agencies, his department has a small number of inspectors relative to the thousands of trucking companies out there. He wants to focus his resources on “high-risk” companies and leave the others alone.
But red flags can arise from unexpected places. A disgruntled driver calls in and gripes about logbook falsification. A four-wheeler with high-level connections complains about the way a truck was being operated on the highway. Any of these could result in the call that a safety auditor is on the way.
“My advice is to go to the furthest extent possible to find out what the government has on your company,” Slater explains. It probably knows more about you than you think. Any encounter between a truck and the authorities will be recorded in a provincial database, and not necessarily your carrier abstract.
The Ontario Ministry of Transportation, for instance, has a program called Safetynet that provides “a detailed record of every interaction you have with them, much more detailed than your CVOR (Commercial Vehicle Operator Registration) record,” he says. “For example, if a driver goes into a scale and has a CVSA Level 3 (driver only) inspection, it may not show up on your CVOR. But it will on your Safetynet report, which the facility auditor most certainly will have when he matches the date and time of that inspection to the driver’s logbook. The bottom line is you want to see the same documents the auditor has.”
You also want to make sure the information the authorities have is accurate. In some form or another, data about your safety performance is available to anyone-including customers, insurance companies and the press-and it’s in your best interest to make sure agencies have it right.
Sometimes the audit trigger is a lack of data. Most provincial databases highlight companies that have not been inspected. If you’re not running over scales, not being pulled over, you’re going to be conspicuous by your absence. Are your trucks just not crossing scales, or are they going around them?
Enforcement agencies start to wonder. “The only way to find out is to start pulling over your trucks every time they see them, or to get in there and audit your operation,” Slater says. “That’s essentially what happened with one client of mine. They were hit for no particular reason other than they had no exposure to enforcement.”
Not that an audit is necessarily a bad thing for a trucking operation. “The focus of a facility audit is on management practices,” says Peter Hurst, director of truck safety compliance with the Saskatchewan Dept. of Highways. “We view incidents that happen out on the road-out-of-service violations, driver logbook problems, accidents-as symptoms of a problem with the way a company is being run. They either don’t know the rules or choose not to follow them, and there’s no excuse for either one. But if fleet managers can come out of an audit with a better understanding of how to run a safe trucking operation, then the audit process is a positive experience.”
TACC is going to find out if that’s the case: the company recently requested a facility audit from the MTO. D’Andrea says TACC made the invitation for two reasons: first, to validate the investment it’s made in compliance management, and second, because the company competes for provincial infrastructure contracts. Eligible bidders must have a “satisfactory: audited” rating, determined by the results of the compliance review. TACC is hoping for an “excellent” rating, which fewer than 120 commercial vehicle operators in Ontario currently hold.
“We’d rather invite the ministry in here than be perceived by them or anyone that we’re content with a satisfactory-unaudited rating,” D’Andrea says. “We think the way we’ve learned to manage our trucks now is worthy of a high rating. We’ve got our ducks in a row.”
Enforcement agency officials say they recognize that many trucking operations are naive about their responsibilities with respect to compliance. At small companies, managers wear lots of hats. Payroll comes once a week, while a safety review may happen only once a year, if ever, so it goes on the back burner. They don’t have time to learn the rules, let alone learn how to follow them.
Lack of familiarity can lead to a company being intimidated by the compliance review process.
“A lot of carriers are apprehensive about contacting the office and saying ‘I don’t know how to comply,'” says Michael Lamm, a team leader in the enforcement office of the U.S. Federal Motor Carrier Safety Administration in Washington, D.C. “They’re afraid that we’ll hold something against them.” In fact, Lamm says, what the agency wants is to help.
“We would rather talk to them on the phone and send them information in the mail and have them call back so we can explain on the phone than go out and do a compliance review, fine them, and take money away from their operation.”
There is a cost-in time, money, and planning-to set up a proper record-keeping program and to stay on top of it. But like any big job, the sweat you pour into the details before ever breaking ground will pay off in a shot of confidence when the inspector finally does come knocking on your door. Just ask Gino D’Andrea.
-with files from Oliver Patton
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