Required Vs. Recommended DOT Training


I got a client’s email question a few days ago asking what training is required annually, and I thought, “Wow, this guy must be a real go-getter!” as most motor carriers don’t do any training at all . . . this guy is looking for mandatory training topics to cover yearly!

So I gave it some thought, answered his question, and then realized it would be a good topic for a blog post.

 

The first question was, “What training is required on an annual basis?” 

The answer may surprise you: NONE.

In fact, the only training the DOT requires to be re-done on a regular (but not annual) basis is HazMat Training for HazMat drivers/other employees.

(A quick note: OSHA may require some training annually, but I’m not an OSHA expert. I think you are supposed to train on fire extinguishers annually.)

 

So, let’s put together a rundown on required training:

 

  1. I always tell people the MOST important thing (unless you are hauling HM or driving doubles/triples) is:

Supervisor Drug and Alcohol Training

The DOT nearly always asks for proof all members of management have had this training.

Best management practice is to do a refresher course each 2-3 years.

 

  1. HazMat training, for drivers and administrators.

This is required if you haul placardable quantities of HM, but note it’s also required for a lot of HazMat that is in LESS than placardable quantities.

And, some ‘universal’ HazMat safety training is supposed to be done for ALL CMV operators, regardless of their shipments.

So, is it required by the regs? Yes. Is it enforced by FMCSA though? Not so much (except for actual HazMat drivers – then it is really enforced).

Then, is it a good idea?

Yes, for everyone, once each 2-3 years. If you are a hazmat hauler, this has to be done each 3 years.

 

  1. Introduction to Drug & Alcohol Testing training for all CDL drivers.

This is required by the DOT, but hardly anyone does it. Most companies give the driver a copy of the company D & A policy (which usually is incomplete) and make them sign a receipt.

 

The regulation states you are to provide information to the driver about the 11 topics found at 382.601. If the company D & A policy is complete, and if this is presented to drivers as a training session and then it is documented properly, this can be acceptable.

 

  1. I like the fire extinguisher training as required by OSHA and NFPA regulations. 

The regulations are as follows 1910.157(g)(1) and 1910.157(g)(2) that require all employees to be trained and have annual refresher training. This training is not that long and has helped out on other areas also.

 

  1. And then there is Entry-Level Driver Training (ELDT) – it’s a good starting place. Four topics required in ELDT are: Driver Qualification\Disqualification, Hours of Service, Wellness, and Whistleblower training. Here is a comment I made on ELDT on a national website about 2.5 years ago:

 

“I think you should present, at a minimum, the 4 ELDT topics PLUS load securement to all new drivers, regardless whether ELDT is required by the DOT.

1 – If you as a manager understand driver qualification and disqualification, you should be the one training the drivers. This can be incorporated in the DQ process, along with any unique administrative requirements.

Be sure to cover the physical qualification to include if you are unable to work one day and you have to see a doctor, you MIGHT not be qualified to work – and you should check with the medical examiner (this is a ‘best management practice).

2 – Hours of Service – most drivers lie on their logs all the time.

I hope if you are participating in this forum you have made a business decision to put a stop to it.

Drivers deserve to hear this from you. And, you need to show them how you want the logs presented. Again, I don’t want to hurt anyone’s feelings but I have to say “If you understand HOS documentation” because a lot of people don’t.
There is a new website with some training material on driver fatigue; if you have never seen it, you should invest a little time in looking at it. Go to http://www.nafmp.com/en/

I am NOT a fan of “canned training” – I think it conveys the message that you are just paying lip service or that you don’t understand it yourself.
A – you need to understand it if you are the safety manager, and
B – your policies procedures and paperwork need to be customized for your circumstances.

3 – Wellness – who cares if it is REQUIRED – It is a good idea to have a brief, frank discussion with your drivers on this topic. The health insurance industry says “Persons / employees / co-workers who are concerned about their personal physical well-being are less often missing time due to illness and injuries and return to work sooner” or words to that effect.
If you care about your drivers or the long-term success of your business, you need to deliver a brief, meaningful presentation on the topic of driver wellness. The occasional distribution of some literature on the topic has also been shown to have a beneficial impact.

4 – Whistleblower Training. As I understand it, OSHA requires this for any company that has more than 8 or 10 or 16 employees – I don’t remember the exact number because I am not interested in doing just the minimum.
I advocate doing what is right and what is smart, to the extent that I know what this is.
A driver deserves to know you mean it when you say you don’t want dispatchers pushing them inappropriately and that you WILL fix it if it is a safety issue (HOS and Maint. are the 2 whistleblower topics)

5. And the bonus segment – load securement.
Though not technically required as a topic of training, the regulation does say a driver is not qualified to operate a CMV unless he knows how to block, brace and secure cargo. And, since one of the required topics is on Driver Qualification\Disqualification, if you have never done any formal training on the topic, you cannot prove the driver is qualified to drive a CMV. So why wouldn’t you spend a few minutes to go over it with them during the entry-level training?

Again, I hate to step on toes here, but it would be a bad case of ignoring the elephant in the room if I didn’t address this:
 – SOME trucking companies hire a person and give them the title of safety manager with no regard for whether the person has a clue about motor carrier safety. If you are not competent to deliver a presentation on these 5 topics to your drivers, you should seek self-improvement such that you are comfortable with not only the DOT minimum, but the industry standard and best-management practices. There are a lot of people out there who have been given the title “Safety manager” without the proper background.
If you have been given the title without the perfect body of experience or educational background, you are not in the minority. When I was first instructed to “read this stuff and make sure we are doing this paperwork right” I was hopelessly unqualified – it’s like being tossed into the deep end of the swimming pool – you either figure it out or you have a bad experience.

If you don’t feel comfortable putting together a meaningful presentation – one that is customized for your company – on each of these five topics – MAYBE using some sort of ‘canned training’ product is better than nothing.
But, it should be a temporary solution, and you should strive for a better command of the material and you should be planning to develop your own unique treatment of each of these topics.”

This leads me to my final topic, which may be a bit self-serving, but I promise you it did not start that way:

 

When I first got into this business back in 1988, one of the helpful suggestions I got from a member of the state motor carrier association was to attend a 2-day seminar. There were several vendors of such educational events in the 1980s, and I was able to find one. It was helpful in getting my feet under me, so to speak, in this new area.

 

After I left the FMCSA in 2007, I started helping small trucking companies establish safety management systems; the first 10 or so people I visited with simply didn’t know anything about DOT safety regulations. So I told every one of them they needed to find and attend a 2-day seminar. They all called and emailed me back saying they were unable to find such a training event. So, I created one. I figured out later there were a couple major national providers of these training events that had simply dropped out of the marketplace, creating a vacuum. Today, I think we offer the best 3-day seminar there is on the topic.

 

The FMCSA has tried and failed repeatedly since 1982 to make driver training mandatory. (Other than the approximately 2-hour ELDT requirement for new CDL drivers, there is still NO mandatory training for CMV operators). But, in MAP-21 (the current transportation law), there is a requirement for the FMCSA to create a specific proficiency requirement for motor carriers. Not later than April 2014, the agency was supposed to create a regulation making this mandatory. I’m not sure what the current status is, but my point is the whole “go-to-a-seminar if you are new to the business” might be in the DOT Regulation someday.

Right now, it’s just a recommendation for those newly assigned to the job.

 

 

In summary:

If you are coming into this job from another area of management, and you are accustomed to a checklist of required training, note there is very little required by the FMCSA, but there are at least three types of training you should be thinking about:

 

-Topics above (A, B, and C) required by the FMCSA

-Entry-Level Driver Training / initial driver safety training (E)

-Training for management

 

This is just my 2 cents worth on the topic – but hey, I’m just a simple country boy with a public-school education from southern Missouri.
-Mike England

About DOT Compliance Help Inc
Phone: 847-836-6063 web: www.dotcompliancehelp.com e-mail info@dotcompliancehelp.com DOT Compliance Help, Inc. is a full-service consulting firm specializing in the interpretation and execution of the regulations and guidelines set forth by the US Department of Transportation Federal Motor Carrier Safety Administration. •Mission Statement• To assist our clients in establishing proper safety management controls in order to minimize accidents, injuries, and fatalities. The ultimate goals are safer roadways for the public and increased profits for our clients. Our core consulting competencies include FMCSA Assessments (mock audits), DOT compliance training (on-site and via webinar) and custom safety plans and policies. We also hold DOT compliance workshops and conferences all across the country. Utilizing a proprietary curriculum developed by our President, Mike England, our classes cover everything you need to know about the FMCSRs, how to survive your next DOT Compliance Review, and how Comprehensive safety Analysis (CSA 2010) will affect you. www.dotcompliancehelp.com

3 Responses to Required Vs. Recommended DOT Training

  1. Kobus Hanekom says:

    Absolutely brilliantly put Mike. I have been nailed with similar questions.

  2. Elizabeth St. Clare says:

    Very well written Mike. I believe that when carriers embrace safety as a personal value for each member of the organization, only then will they recognize the importance of ongoing training not only for their most important asset, the driver but their leadership and support teams as well.

  3. Steve says:

    2 CENTS? I’D GIVE IT A NICKEL, AT LEAST. ACTUALLY, MUCH MORE. I AGREE WITH YOUR ASSESSMENT OF DOING MORE THAN THE MINIMUM. THERE ARE SO MANY MINIMUMS THAT YOU ARE GOING TO MISS ONE HERE OR THERE. IF YOU ARE CLEARLY ATTEMPTING TO EXCEED MINIMUMS, MY EXPERIENCE (I’M AN OLD FART – SO, LOTS OF EXPERIENCE) HAS BEEN THAT YOU ARE GOING TO EARN A BREAK WHERE YOU FAILED IF YOU EARNED SOME CREDIT FOR DOING MORE THAN WAS REQUIRED.

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