Make up for your regulation shortfalls By Carmen Daecher

I've always been disturbed that the government has set many regulations with which you must comply, and yet many of the most important and fundamental ones are not sufficiently defined to offer real value.

Federal Motor Carrier Safety Regulations require that a driver's MVR (Moving Violation Record) must be reviewed before hiring. The MVR for each hired driver must also be committed to the driver qualification file. Besides that, the government offers no guidance as to its value or use. Somehow you are just supposed to know its value.

To combat this lack of information, you should take this matter into your own hands. First, define for yourself the minimum number of convictions, regardless of points, which you are willing to accept for a new hire. Second, establish a minimum number of preventable accidents that an applicant may have before they are not eligible for hire. By setting this standard, you commit yourself to a level of behavior that is acceptable to the public and yourself.

The regulations also require motor carriers to document their preventive maintenance activities. They dedicate numerous pages to brakes and minimum brake standards. But nowhere do they suggest how you should document brake maintenance.

With brakes being one of the most frequent reasons for vehicles being placed out of service and always one of the first issues raised after accidents, it makes sense to set definitive standards for frequency, methods and documentation of brake maintenance. In fact, any systematic maintenance should be prescribed and documented for all to understand so that consistent, thorough and quality maintenance is applied to all vehicles.

In addition, regulations require that commercial drivers know about many topics that are listed in Part 383. But they never specify how this information is to be obtained or how much knowledge or experience is sufficient for drivers to have.

Sufficient classroom and behind-the-wheel training, coupled with required evidence of proficiency and knowledge by new hires, will minimally insure that your drivers can safely operate your vehicles every day. In order to achieve this, check your training program as soon as possible. You should provide classroom knowledge and behind-the-wheel experiences for all driving situations and conditions - such as adverse weather, skid control recovery and mountain driving - to insure that operators will drive as safely as possible. This is especially important if you know that drivers may encounter certain situations that are particularly unusual.

Hours-of-service regulations, as they are defined now, do not allow for quality driver rest time. While there is much discussion about what new hours of service regulations should be, nothing has changed as of yet.

So what are you going to do in the interim to make sure that your drivers have the opportunity to get regular quality rest? For one thing, you should be using a 24-hour cycle for scheduling. You should also insure that your drivers have the same time each day for adequate rest. If this is not possible, plan for relief drivers as necessary.

Even though many of the regulations do not provide the kind of guidance that may be needed, their intent is very simple: hire the right people; train them properly; provide a proper work schedule and environment; and maintain your vehicles well. This is nothing more than common sense. By setting these standards, you lay the foundation for consistent safe behavior and operations for your organization.

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