We recently held an HNI University workshop called FMCSA Safety Audit Requirements and How to Prepare, where we heard from FMCSA and Wisconsin State Patrol officials on new policies and procedures in place. It was brought to our attention that not only is FMCSA’s auditing process changing, but so are the techniques used by the auditors.
With CSA being the most common reason for a visit from FMCSA, most carriers will not receive a “full compliance review” but instead will receive a “focused review”. A focused review is usually listed as a “non-ratable review”. In a non ratable review, the inspector cannot issue a satisfactory rating, but they are allowed to reduce your rating to conditional or unsatisfactory. This will occur if they discover a violation (or violations) during the review which in a full compliance review would cause the carrier to receive a conditional or unsatisfactory rating (i.e. hour of service violation which results in a pattern of non-compliance or more than 10% for any one type of violation).
Another interesting thing we learned at the event was how FMCSA is focusing on best practices and procedures internally so that their inspectors are more effective at ensuring compliance.
One thing I thought was especially interesting was with regards to the Maintenance Basic and DVIRs. With the information gathered from CSA, the FMCSA is looking at the percentage of defects in the maintenance area vs. the number of inspections. If done correctly, common sense would dictate that the percentage of defects uncovered in the DVIR process should have similar results to those uncovered during a roadside inspection.
The reality is that the DVIR process shows a significantly lower percentage of defects than those discovered during a roadside inspection. This is telling us that drivers are either not listing defects or that they do not understand the DVIR process. Many drivers think that the DVIR process is a “post trip inspection” where you list what you discover during an actual inspection, whereas the regulations state:
a) Report required. (1) Motor carriers. Every motor carrier shall require its drivers to report, and every driver shall prepare a report in writing at the completion of each day's work on each vehicle operated, …
b) Report content. The report shall identify the vehicle and list any defect or deficiency discovered by or reported to the driver which would affect the safety of operation of the vehicle or result in its mechanical breakdown. If no defect or deficiency is discovered by or reported to the driver,…
This means that the driver is to fill out the report and list anything that he/she was aware of or was notified was wrong with the unit(s) that day!
So, what is a carrier to do? During the event, a number of people described their processes for ensuring DVIR completion and accuracy. As ideas of what you can do, consider these policies for your organization:
Best practices don’t have to be complicated! Aren’t our goals the same? We don’t want people needlessly injured, roadside breakdowns (along with the roadside repair expenses), and customer service failures related to our equipment. We want to know when something is wrong. It’s usually cheaper to fix something then to let it develop into a larger issue. A simple process that ultimately not only helps you to be compliant but saves you money and improves your efficiencies over time. Kind of a no brainer isn’t it?