Safety & Compliance for the Commercial Fleet Manager April 2014 Presented by Stacey Dove, SEE, Inc.
Risk management considerations for today: Safety status from a regulatory compliance perspective. Fleet safety & training with an emphasis on fatigue and distraction.
Exposure Roadway crashes are the leading cause of occupational fatalities in the U.S. Death from roadway crashes led all other causes, making up 22% of workplace deaths. DHHS Publication No. 2004-137 Human costs Productivity concerns Image exposure Regulatory compliance challenges Economical concerns equipment costs, insurance rates, criminal & civil litigation, fines, potential shut-down of your fleet.
Comprehensive Approach to Fleet Safety A comprehensive approach to fleet safety should include an investment in all of the following: Accountability written policy & procedure. Regulatory compliance DQ, D&A, H.O.S., Vehicle Maintenance, DVIR s, D.O.T. SMS, etc. Driver Screening employment background, driving history, driving evaluations. On-going training to improve knowledge and performance for both drivers and those who manage them.
FMCSA regulations applicability Intrastate vs Interstate intra subject to existing state law Any business operating a CMV: GVWR 10,001 pounds or greater Placarded quantities of hazardous materials Transportation of passengers 8 or more passengers including the driver for compensation 15 or more passenger including the driver not for comp
Compliance Categories Factor 1 General Parts 387, 390 Factor 2 Driver Parts 382, 383, 391 Factor 3 Operational Parts 392, 395 Factor 4 Vehicle Parts 393, 396 Factor 5 HazMat Parts 171, 177, 180, 397 Factor 6 Accident (RAR per million miles)
Factor 1 General Parts 387, 390 387.7 - MCS90 proof of financial responsibility 390.19 - MCS150 bienniel registration update BOC3 service process agents 390.15(b)(1) Accident Register Accident records 390.3(e)(1) Every employer shall be knowledgeable and comply. 390.3(e)(2) Every driver and employee shall be instructed
Factor 2 Driver Parts 382, 383, 391 382 Drug & Alcohol Testing rates, compliant program, driver & supervisor training, appropriate separation of CDL & Non-CDL pools 383 Commercial Driver s License (CDL) Proper Class license and endorsements Entry-level driver training (after June 2003) 391 Driver Qualification DQ file current & complete - including appropriate application Road tests CDL vs Non-CDL Driver renewals license, medical, mva record, driver s statement, annual review Appropriate storage of medical & D&A records National Medical Examiner s Registry
Factor 3 Operational Parts 392, 395 Part 392 ill or fatigued operators, D & A prohibitions, speed schedules, equipment inspection & use, emergency equipment, inspection of cargo securement, railroad grade crossings, stopped vehicles, fueling, unauthorized passengers, texting, hand-held cell phones, etc.
Factor 3 Operational Parts 392, 395 Part 395 Hours of Service general rules 6 month retention Supporting documentation Passenger carrying Property carrying Standard Rules 10 hour break, 11 driving, 14 consecutive, 60hr/7day or 70hr/8day 100 air-mile radius exemption (CDL local) 150 air-mile radius exemption (non-cdl local) 16 hour exemption 34 hour restart
Factor 4 Vehicle Parts 393, 396 Part 393 Parts & Accessories 393.100 Subpart I Protection Against Shifting & Falling Cargo Part 396 Inspection, Repair, & Maintenance 396.3(b) vehicle maintenance files Labeled with company unit number, make, serial #, year, tire size Include all maintenance & repair records 396.11 DVIR s (post trip) 396.13 Pre-trip 396.17 Periodic Inspection (federal annual) 396.19 Inspector qualifications
Factor 5 HazMat Parts 171, 177, 180, 397 172.404 Security Plans & Training General Awareness, Function Specific, Driver, Safety, Security, Security Plans, In-Depth Security Record keeping / manifests Hazardous Materials Certificate of Registration
Factor 6 Accident (RAR per million miles) Formula # of DOT Recordable Accidents X 1,000,000 # of miles driven past 12 months If the result (RAR) is greater than 1.5, then the best safety rating is Conditional.
Determining the Individual Factor Ratings Part 385 Appendix B - For each instance of an acute regulation or a pattern of non-compliance with a critical regulation, one point will be assigned for that Factor. However, HOS violations carry two points. Satisfactory if the acute & critical = 0 points Conditional if the acute & critical = 1 point Unsatisfactory if the acute & critical = 2 or more
Determining the Carrier Safety Rating Part 385 Appendix B Motor Carrier Safety Rating Table Unsatisfactory Conditional Overall Safety rating 0 2 or fewer Satisfactory 0 more than 2 Conditional 1 2 or fewer Conditional 1 more than 2 Unsatisfactory 2 or more 0 or more Unsatisfactory
SaferSys & CSA SaferSys https://safer.fmcsa.dot.gov/companysnapshot.aspx CSA http://ai.fmcsa.dot.gov/sms/default.aspx Example USDOT number 1052364 or 2309582
DRIVER TRAINING & ASSESSMENT Fatigue & Distraction.
Collision Costs Crash Type Cost/Crash # in 2005 Total Fatal $3,604,518 4,551 $16,404,161,418 Injury $195,258 78,000 $15,230,124,000 Property $15,114 341,000 $5,153,874,000 http://ai.volpe.dot.gov/carrierresearchresults/html/2009crashfacts/tbl71.htm
Collision Costs Crash Type Cost/Crash # in 2009 Total Fatal $7,236,000 3,380 $21,983,000,000 Injury $321,000 75,000 $16,531,000,000 Property $13,000 232,000 $2,793,000,000 http://ai.volpe.dot.gov/carrierresearchresults/html/2009crashfacts/tbl71.htm
Current U.S. Statistics Over 32,000 annual fatalities. Over 2.2 million annual injuries. Over 5.3 million police- reported vehicle crashes. Avg. over 6,145 injuries per day. Avg. of 90 fatalities per day. Avg. over 4 injuries per hour. Avg. of 1 fatality every 16 minutes. Statistics from NHTSA Traffic Safety Facts 2011
Local Annual Statistics MD - 493 traffic fatalities PA 1,256 traffic fatalities. DC 24 traffic fatalities. DE 101 traffic fatalities. VA 758 traffic fatalities. 2010 Data Statistics from NHTSA Traffic Safety Facts 2012 Maryland Annual 95,349 crashes 48,143 injuries 2009 Data Statistics from Maryland Traffic Safety Factbook 2011
The Reality of Risk 1 Deaths 32,885 62 Injuries 2,243,000 164 Total Collisions 5,389,000 290 Vehicles Involved 9,563,107 1,452 Citations Issued 59,617,668 3,169 Near Miss 104,238,000 51,100 Driver Error 1,875,372,000 Normalized Data Using Heinrich s Triangle Data from Heinrich s Triangle combined with NHTSA Traffic Safety Facts 2010 Source: http://scholar.lib.vt.edu/theses/available/etd-07272000=08470013/unrestricted/hanowski ETD.pdt
Challenges Driver education with specific regards to fatigue, distraction, risk acceptance.
What is fatigue? Fatigue is the body s response to continued physical or mental activity or sleep loss, characterized by: diminished ability to do work, loss of attention, slower reactions, poor response, deterioration of vigilance and alertness, impaired judgment, and other problems; subjective feelings of tiredness, loss of motivation, desire for rest Fatigue is not hours of service; fatigue is not simply falling asleep.
Causes of Fatigue Inadequate rest Sleep loss and/or disrupted sleep Displaced biological rhythms Excessive physical activity Excessive mental or cognitive work
Sleep Disorders Insomnia Restless Leg Syndrome (RLS) Narcolepsy Sleep Apnea
Regulatory Impact National Registry of Certified Medical Examiners May 21, 2014 compliance deadline for new or renewed D.O.T. physicals
Ways to reduce the impact of fatigue Try to minimize the impact of peak production periods with scheduling and additional staffing when feasible Check out programs health providers may offer Increase training & awareness
The Issue of Driver Distraction The issue of driver distraction is quickly becoming a major stumbling point in roadway safety as verified by a number or recent studies:
NHTSA & VA Tech - 2006 100 Car Naturalistic Driving Study Observations recorded by in-vehicle instrumentation show that almost 80% of all crashes and 65% of all near-crashes involved the driver looking away from the roadway just prior to the event.
Carnegie Mellon University 2008 Behavioral studies show that engaging in a secondary task disrupts driving performance. Listening alone reduces by 37% the amount of brain activity associated with driving (parietal lobe). Parietal lobe integrates sensory info and is critical for spatial sense and navigation. Activity also reduced in the occipital lobe (which processes visual info).
Cognitive Driving Variables Basic Assumptions All drivers face distractions every time they drive. All drivers face states of inattention every time they drive. All drivers must manage and balance these problems every time they drive. Challenges Each driver has a variable level of acceptable risk. Attentional resources & capacity are limited. Humans are serial processors. High-order self-assessment is generally not reliable. The ability to accurately identify increased risk prior to the emergency varies from driver to driver and throughout the day.
Distraction Countermeasures Once a problem is identified, the solution is to: A) remove or reduce the distraction, or B) change the driving, or C) both The driver needs to attempt to maintain an operational sweet-spot. Too much stimulus and we are overloaded. Too little stimulus and we are bored, our mind wanders.
Defensive & Distracted Driving Assessments Components: The vehicle - safety first The route - sufficient intensity & complexity to challenge the driver, statistically equivalent, multiple segments in 3 phases (normal, visual distraction, cognitive distraction) The Assessor highly trained observer, consistent rating reliability
Defensive & Distracted Driving Assessments Components (cont.): The assessment process - at the end of each segment, the driver is scored against a benchmark on six variables: speed Intersections space management low-speed frontal space vehicle handling Let s take a look at some results. time management