Knowing what to do and getting it done are two different things By Carmen Daecher

As I've said before, policies are a great way to establish standards for performance and in defining organizational commitment for good performance. I have not seen policies at any motorcoach company that do not incorporate complying with regulations as a basic standard of behavior. Yet, more times than not, I find motorcoach companies, no matter how well intended, failing to properly comply with regulations.

I do not believe that this is because management consciously disregards them. Rather, the everyday pressures of accommodating customers take any manager in many different directions. No matter what is planned, many unplanned events always delay getting done what we had "planned" to do.

If you as an organization fail to comply with DOT, OSHA, and EPA regulations, it should be considered the same as a driver failing to meet expectations. No matter what the reasons, it is a preventable occurrence. And once the reasons are known, steps should be taken to prevent reoccurrence. But many times, failure by management to comply with regulations is not addressed the same way as when drivers are involved in accidents or when employees break company rules. The question is why?

Poor performance by the organization is just as serious as poor performance by any individual. And even if it is a manager that is not performing well, why should this be considered less urgent than when drivers or other employees do not perform well?

I have seen the results of not complying with regulations many times. Less than satisfactory compliance reviews by the Department of Transportation or by the Department of Defense have caused many companies to lose business. Insurance companies get "nervous" when they find poor compliance in organizations that they insure. And now, with the results of compliance reviews on the web, potential customers can know of an organization's poor performance thanks to their ratings.

Inevitably, when I seek reasons from motorcoach companies for this poor performance, I hear excuses such as "I didn't have enough time" or "I have the paperwork somewhere, I've just got to find it."

While none of these excuses are acceptable, the key to preventing these episodes is to establish well-defined procedures that allow for enough time to properly comply with regulations and file keeping. Here are some suggested procedures that you might follow to make compliance an easier part of your everyday hectic life:

• Have every applicant fill out an application and have someone verify that it is completely filled out before they leave your facility.
• If the candidate is being considered for possible hire, have someone order MVRs from every state in which they have resided for the past three years within 24 hours of your receipt of their application.
• Designate someone to initiate past employment and positive drug test inquiries within 24 hours of your receipt of a prospective employee's application.
• Document all training, no matter when it is provided. Maintain a separate file for training documentation for each employee.
• Carefully review the results of the DOT required physical for drivers. Be sure that no issues such as hypertension have been identified or have gotten past examining physicians.
• Maintain a separate database of employees showing expiration dates for licenses and medical certifications. Provide each employee 60 days notice of pending expirations. Specify suspension of employment activities if renewed licenses or medical certifications are not received within two weeks of expiration.
• Perform annual reviews for all drivers at one time. Every eleven months, have all drivers fill out and sign an annual certification of violations form and request MVR's for all drivers to review with these forms.
• At the beginning of each quarter, determine necessary numbers of drug and alcohol tests to comply with random testing requirements. At the beginning of the fourth quarter, all employees who must be tested should be completed by the end of November. Maintain separate files for each quarter of the calendar year in which you collect information showing required number of random tests, a random selection list of employees to be tested and confirmation of tests administered.
• Designate an employee to review all driver logs for completeness and accuracy on a weekly basis. Document the absence of logs or inaccurate/incomplete logs in each employee's personnel file. Require corrections or submissions of logs within one week. Suspend drivers who do not comply.
• Review at least ten percent of drivers' logs each month for possible falsifications using toll receipts, fuel receipts, itineraries, etc. Perform this review for a different group of drivers each month. In this way, at least once a year, all drivers' logs will be reviewed for falsification.
• Review operations/dispatch protocols on a quarterly basis to ensure that drivers are not receiving unreasonable assignments as it relates to hours of service. Document any inappropriate assignments and document procedures to prevent such situations from occurring in the future.
• Drivers performing pre-trip inspections should sign the previously prepared post-trip vehicle inspection report always. This should also provide the date of the pre-trip inspections. This should be done even if no safety defect was reported. The copy signed by both drivers should also be signed by the person repairing any safety defects noted, and this copy should be kept with the vehicle file for 90 days.
• Within the month of January, have a designated employee perform an inventory of all toxic substances used by employees in the performance of their work. Document the inventory and obtain material safety data sheets for each item, even if you have an existing MSDS sheet from the previous year. Provide training to all new employees concerning their use of toxic substances, or to existing employees for their use of new toxic substances.
• Beginning February 1st and until April 30th, post OSHA form 300A where it can be seen by all employees. This is the summary of the OSHA log for recordable injuries and illnesses.
• At the beginning of each quarter, have designated employees inspect the facility and document any noncompliant or potentially hazardous conditions. Respond to these conditions and document actions taken within the same calendar month.

While this was not mentioned, good filing procedures are vitally important. Someone must be responsible for filing documentation in the appropriate files. And this should be done on a weekly basis.

This list of suggested procedures is not all inclusive. It does incorporate those items which I have found to be the most frequent problems for motorcoach organizations. What is most important to understand is that management must use defined and regular procedures to fairly and adequately manage employees and to maintain compliance with all applicable regulations. More important than the specific method of getting a job accomplished is the regularity of performing these tasks. Once any task is developed into a routine through well-defined process, it is less likely to be overlooked or forgotten.

Policies and procedures go hand-in-hand. One defines the standards while the other defines how you get the job done. From where I'm sitting, implementing policies and procedures and then using them is the best way to effectively manage your organization.

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