Brad Klepper
In the third installation of this series, we’re going to talk about bad habits.
Whether we want to admit it or not, most of us have picked up some bad driving habits between the age of 16 and whatever age we are now. (No, I’m not going to say how many years that is for me, and I won’t ask you to tell me either.)
Maybe you have a quick bite or drink while you’re driving, or you send a quick text. Maybe you start programming in the route to your destination after you’ve already taken off — or maybe you reach for something in the back seat to hand to your kid. Maybe you speed up as the light turns yellow, or you drive just 4-9 miles an hour over the speed limit everywhere you go. Or, perhaps you’re a perfect driver who makes no mistakes, and you just throw rude gestures to the needlessly careless drivers around you.
Now … imagine engaging in all these seemingly minor distractions and habits while behind the wheel of an 80,000-pound truck, which requires 50% or more stopping distance than an ordinary passenger vehicle.
Consider this: Most Class A truck drivers have five years or to develop personal driving habits, both good and bad, before they ever start CDL training and testing. We’d like to think the people who decide to be truck drivers quickly gave up those pesky, reckless habits — and maybe they did.
But let me ask you this: How many of your New Year’s resolutions have been successful simply because you knew they were better for you? Again, I won’t tell or make you tell, but I’m guessing most of us are not feeling a rousing sense of achievement at the thought.
So how do we re-train safe driving habits in orientation?
In recruiting, you assess a candidate’s attitude around safety, their accountability for their mistakes and their ability to learn from those mistakes.
IIn orientation, you assess those same items, plus the person’s ability to learn or retrain themselves based on your guidance. If you assigned videos and quizzed them ahead of orientation, now you are seeing if they can apply the information in the real world.
Orientation should consist of hands-on driving and training that cannot be completed online. Some things to cover with drivers during orientation include:
- Share examples of common scenarios that have led up to a violation or accident at your company. Ask the recruits what risks they would face in that situation and how they would mitigate them.
- Provide recruits with examples of publicized lawsuits in the industry over the last several years and how they have played out for the driver.
- Introduce them new drivers your safety team and offer a Q&A session to build trust.
Orientation is your chance to more deeply connect new hires with your value for safety and teach them how to think about and to take safety personally. If new drivers simply sit silently through dull lectures and take quizzes, you’re teaching them to memorize, regurgitate and discard information.
Changing habits necessitates creating new neural pathways through action, interaction and problem-solving.
What about road training?
Road training is equally, if not more crucial than orientation in re-training habits. Road training allows the new employee to cement their new safe habits with the oversight of a respected, mindful advisor.
Your company’s road trainers should be some of the most deeply scrutinized, well-paid and highly engaged employees in your company.
When considering the length of your orientation versus your road training process, I tend to believe investment in road training pays more dividends because it gives a more realistic opportunity to retrain habits.
What’s next?
I’ll bet you wouldn’t have guessed we’d be three parts into a series about a “comprehensive safety plan” before addressing your company’s safety program as it relates to candidates. But each step in the recruiting, hiring and training process is vital to overall safety.
Recruiting, orientation and road training are the gatekeepers of your organization’s value for safety. If your organization’s culture is built on people, these teams are pouring the foundation for your company growth.
You cannot build a strong safety culture on top of a weak safety foundation. Don’t take that statement lightly.
So, what’s next? It’s time to talk about the work your company’s safety team does to build your safety culture.
Brad Klepper
I’m sure my riveting column about strategically interviewing candidates as part of your comprehensive safety plan is what’s drawn you back for the highly anticipated Part 2. (Thanks to both of you for contributing to my delusions of grandeur.)
But on to business.
Now that you eliminated some of the knuckleheads through the recruiting process discussed in Part 1, let’s talk about safety training. I’ve taken the liberty of anticipating some of the most-asked questions on the topic. If you have additional thoughts or questions, let me know.
When should safety training start?
I don’t pretend to be the most tech-savvy person, but like many people my age, I’ve allowed myself to be dragged along by the younger generation. I’ve been assured the constant change and updates to our technology is an inevitable part of being a successful business.
While I will not give specific recommendations on systems, I’m aware many training platforms now offer the option of assigning videos and training materials before candidates even show up to orientation. Drug testing is more commonly completed in advance now too.
However, training in advance might seem like a heavy, and even wasteful, administrative burden.
“Why would I invest in training up front when 20% of my candidates may not even show up to orientation?” you ask.
That’s a fair point — but let’s debate it for a minute.
Human nature dictates that the more time we invest in something, the more committed we become to seeing it through. In addition, when exposed to the same information multiple times, we’re more apt to like it, to believe it and (this is very important) remember it. We see this in advertising, news, music and popular culture in general.
So, do I believe providing safety training before orientation could improve your show rate with more prepared candidates who better understand and are interested in the work you’ll ask them to do? Absolutely.
“I thought this was a safety article, not a psychology article!” I can hear you saying.
Right! Let’s get back on track. Next question….
What topics make sense for advance safety training?
Training materials showcasing your unique safety protocols for your company’s equipment and freight would be a great introduction.
This shows recruits how you stand out and starts drilling the information they’ll need to have to be successful at your specific company. These are things they very likely did not learn in CDL school or at another company.
For more general training, Smith System training or DOT regulation training can benefit drivers at any company. Providing these training opportunities in advance also reinforces to candidates that you have a core value for safety. Ideally, it also helps further narrow your pool to those who share a value for safety or at least for learning.
If the training is presented by your safety team with photos or videos, you have the added benefit that it will acquaint your future drivers with your team early on, making them more accessible and familiar.
How many times have you had a driver make a costly mistake because they were afraid to call the safety director and admit they didn’t know what to do? The more familiar employees are with your safety team members, the less intimidating it will be to make that call in the future.
On the other hand, I wouldn’t be worth my salt as a lawyer if I didn’t caution you to be VERY thoughtful when choosing what you put into writing or record as you prepare these materials.
While it’s great for your safety team to be personable and approachable, your company should never seem cavalier about safety. Any safety training you provide could be scrutinized in the event of a lawsuit. You should be comfortable with showing any piece of your training (possibly cut down and taken out of context) to a jury. Getting the opinion of an attorney who’s knowledgeable in transportation lawsuits and verdicts could save you from making a well-intentioned mistake when attempting to connect with your drivers.
How will we make sure these materials are even completed?
Well, that depends on your systems and your company culture.
Some training platforms can track a student’s progress and determine whether a video session was played in its entirety or was closed out early. You could also build out quizzes to measure trainees’ comprehension.
As far as incentives go, I’m a “use-a-carrot-instead-of-a-stick” guy.
Perhaps those who complete their videos are first up to be placed in a truck, or get first pick of a truck. Maybe they get a bonus at the beginning or end of orientation, or maybe offer a free shirt or hat or other item that will be useful on the truck.
If you’re more of a “stick” person (with the word stick meaning reprimands, not the drawing) and can build the administration to track it, you might require that training be completed before scheduling orientation or purchasing the applicant’s transportation to orientation.
You’ll certainly want to work out this piece before you get started. There is no sense developing safety training no one will complete.
One last note:
While I’m writing these articles in the order a candidate enters and moves through your company, this is not necessarily a step-by-step chronological guide for implementation. If you enhance your safety-mindedness at any step in the career of an employee at your company, I’m sure you’ll reap benefits.
Brad Klepper
We all know how much people love to hate lawyers. Even I can jump right on that bandwagon.
When you pay a lawyer for his/her advice, you’re often actually paying someone to be a killjoy. He/she will listen as you describe what you hope to accomplish — and then not-so-lovingly point out all the risks associated with your dreams.
“But with no risk, there are no rewards, Brad!” I can hear you saying. Well, that’s true, or at least partially true.
Mitigating every risk is impossible, but to avoid losing all those hard-earned rewards, minimizing your risk is a must. This is where your safety plan swoops in to save the day and keep those killjoys off your back.
A comprehensive safety plan starts with these five steps:
- Recruit driver candidates who value safety;
- Engage safety training both up-front and ongoing based on industry standards as well as both individual and fleet performance;
- Evaluate customer locations, freight and routes;
- Provide consistent communication with your drivers on Steps 1-3; and, if that’s not enough —
- Have a process in place for reducing the impact of mistakes when they are made.
I’m sure a parley with my friends in safety could drum up more, but most lawsuits could have been minimized or prevented through careful planning in these categories. And no, of course it’s not just about making money and preventing lawsuits (I know, it’s shocking to hear this from a lawyer), but it’s also about saving lives and feeling pride in how we take care of our people and our industry.
Let’s start with Step 1: Recruit driver candidates who value safety.
In addition to getting the driving history of your applicants, how are you evaluating their attitude about safety? If they have had accidents or tickets, are they taking accountability? Did they learn how to prevent it from happening again?
Here’s a good question to ask prospective drivers: “If you were faced with that same situation on the road again, what would you do differently?”
Perhaps they would pull over for bad weather, remove distractions, study their route more closely in advance, get out to look before backing, etc. Perhaps they’ll tell you there’s nothing they would do differently — which may tell you that, if they’re faced with this same situation at your company, they will likely have the same accident.
Discussing drivers’ previous tickets and accidents may also offer insight as to the attitude they would typically display at a traffic stop. The first guidance I give all drivers is this: Remain calm and professional and treat the officer with respect, regardless of whether you feel the stop was warranted or not, or if you feel the officer is reciprocating.
As you ask questions about a prospective driver’s MVR (motor vehicle record), notice their behavior. Are they becoming defensive with you? Angry? Accusatory?
When reviewing the dates of an applicant’s previous infractions, check to see if they have multiple tickets from the same incident/inspection. In my experience, more than one ticket (and especially more than two tickets) during one interaction means the driver put on his/her war uniform before interacting with the officer.
Also notice whether the driver is willing to take responsibility for his/her part in the interaction. For example, are they saying the citation was bumped up from speeding to reckless driving because the officer was “out to get them?”
Perhaps it’s worth asking a simple, direct question: “How was your interaction with the officer during this incident?” The response could be something like, “Oh he was an idiot. I only got those tickets because the cop was out to get me and wouldn’t listen to reason.” This type of attitude is likely to result in the driver putting several tickets on your fleet’s record — or possibly even the driver being arrested during a roadside interaction. (Meanwhile, you’ll be scrambling to recover your truck and deciding the best way to inform your customer you’re just a little behind schedule.)
Depending on the setup of your company, this conversation with a prospective driver might be with your recruiters, your safety team or your orientation supervisors. Whichever team takes on this conversation, make sure the person asking the questions is clear on the perspective you’re trying gain from an applicant’s responses to.
When it comes to screening and interviewing job candidates, it’s best to assign the duty to a small handful of very well-trained individuals. If, for the sake of expediency, you want to train your entire team to help speed the screening/hiring process, I recommend that you have team members conduct practice interviews with each other at least once a month to keep their skills fresh and focused.
You’re not going to mitigate every risk, but if you’re able to identify a hothead before you put him/her behind the wheel of a truck, you’re going to save your team a lot of headaches at the least — and explosive litigation at the worst.
Kathy Close
A CSA BASIC (Behavior Analysis and Safety Improvement Category) score is a percentile ranking used to compare a motor carrier against its peers to assist in identify high-risk carriers.
The Federal Motor Carrier Safety Administration (FMCSA) generates CSA BASIC scores for the following seven categories:
- Unsafe Driving: Dangerous or careless operation of commercial motor vehicles (CMVs).
- Hours of Service Compliance: Driving CMVs when ill, fatigued, or in violation of the hours-of-service rules.
- Driver Fitness: Operation of CMVs by drivers who are unfit to operate a CMV due to lack of training, experience, or medical qualification.
- Controlled Substances and Alcohol: Operation of a CMV while impaired due to alcohol, illegal drugs, and misuse of prescription medications or over-the-counter medications.
- Vehicle Maintenance: CMV failure due to improper or inadequate maintenance or inadequate cargo securement.
- Hazardous Materials (HM) Compliance: Unsafe marking, handling, or transportation of hazardous materials in an amount requiring a placard.
- Crash-Related: Histories or patterns of CMV crashes, including frequency and severity.
How is a CSA BASIC score derived?
The FMCSA uses a motor carrier’s safety data that is transmitted by state and federal enforcement to the Motor Carrier Management Information System (MCMIS). The past two years’ worth of roadside inspection and crash reports contain critical data elements used in CSA’s elaborate algorithms.
The algorithms provide carriers with a “measure” for each BASIC, taking into consideration:
- The severity of a roadside inspection violation or crash,
- How recent the event took place, and
- The carrier’s level of exposure (i.e., vehicle miles traveled, the average number of power units, number of inspections)
This BASIC measure is then compared against similar motor carriers for the percentile ranking. The rank is on a scale of 1-100, with 100 being the worst-performing. This percentile ranking is the carrier’s BASIC score.
How is the percentile ranking used?
Those motor carriers that exceed a predetermined threshold for an individual BASIC score are subject to an intervention by the FMCSA.
Interventions include:
- Warning letters advising of apparent safety problems and the potential consequences.
- Targeted roadside inspections to verify that the warning letters are being taken seriously.
- Offsite investigations that involve the collection and reviewing of documents at an FMCSA location.
- Focused onsite investigations at the motor carrier’s place of business, focusing on a specific safety problem.
- Comprehensive onsite investigations that occur at the motor carrier’s place of business.
- Cooperative safety plans developed and followed voluntarily by a motor carrier to address safety problems.
- Notices of violation to put a carrier on notice of specific regulatory violations that need to be corrected “or else.”
- Settlement agreements to contractually bind a motor carrier to take actions that improve safety.
- Notices of claims to levy a fine and compel compliance in the case of “severe” or repeat violations.
The intervention taken by the FMCSA is not sequential. If a carrier has multiple BASICs exceeding the thresholds and/or scores close to 100 percent, the agency will probably go straight to an investigation. A carrier can only be placed out of service based on the results of a comprehensive investigation since it contains elements of a compliance review.
How Can I Lower My CSA BASIC Scores?
The data used in the CSA formulas are only used for 24 months. As a result, you can only lower your CSA scores over time, by accumulating recent, violation-free inspections, and by avoiding crashes.
To improve your performance data, you should:
- Examine the violations that are scored in each BASIC,
- Look for trends (e.g., same driver or location), and
- Find a root cause for the safety event.
You should use this information to come up with a safety plan to avoid future violations and crashes. If the safety performance does not improve, you’ll have to re-evaluate its findings (find the real root cause) and apply another remedy until the issue is resolved.
To view your CSA scores and data, you must log into the CSA Safety Measurement System website. You can only access the carrier view of the SMS via an FMCSA Portal account. You also need a Login.gov username and password, since an account is required to securely log into any federal website such as the Portal and SMS.
The public view of the SMS does not require any type of logging into the database and can be accessed directly from the SMS website. This view allows carriers, customers, insurance providers, potential employees access, and any other member of the public access to the carrier’s raw data. However, they will not see a property-carrier’s BASIC scores. Passenger-carrier BASIC scores are visible in the public view with the exception of the Crash Indicator and Hazardous Materials Compliance BASICs.
Drivers’ names will not appear on roadside inspection or crash reports for property or passenger carriers.
Mark Schremmer
The Federal Motor Carrier Safety Administration plans to revisit its ELD rule in 2025.
According to the U.S. Department of Transportation’s Spring 2024 Unified Regulatory Agenda, FMCSA is targeting June 2025 for a notice of proposed rulemaking regarding electronic logging devices. The notice is expected to propose revisions to the agency’s existing ELD rule.
In September 2022, FMCSA requested feedback from truckers about how it can improve the ELD mandate.
FMCSA’s advance notice of proposed rulemaking considers changes to the ELD mandate in five areas:
- Applicability to pre-2000 engines
- Addressing ELD malfunctions
- The process for removing an ELD from FMCSA’s list of certified devices
- Technical specifications
- ELD certification
As part of the notice, FMCSA asked truck drivers for feedback on the original mandate’s decision to exempt trucks with pre-2000 engines.
“Should FMCSA reevaluate or modify the applicability of the current ELD regulation for rebuilt or remanufactured CMV engines or glider kits?” the agency asked.
As part of comments submitted to the agency in November 2022, the Owner-Operator Independent Drivers Association said that there is no justification for removing the exemption.
“The agency lacks data confirming the ELD mandate has improved highway safety and has failed to demonstrate how the expansion of existing requirements to vehicles operating on pre-2000 and rebuilt pre-2000 engines would enhance safety,” the Association wrote in 2022. “OOIDA is unaware of any research that demonstrates vehicles operating under the pre-2000 exemption fail to meet the same level of safety as vehicles with ELDs.”
Individual truck drivers also spoke out against any plans to remove the ELD exemption for older trucks.
“The job of the FMCSA is to advance highway safety,” Dan Roe wrote. “When the FMCSA implemented the ELD rules, it exempted vehicles with pre-2000 engines. To my knowledge, there have not been any problems with these vehicles causing injury-related crashes. Therefore to repeal the exemption for pre-2000 engines will do nothing to advance highway safety.”
Although it remains unclear exactly what FMCSA will propose, the agency appears poised to move forward with a notice of proposed rulemaking next year.
