In favor of on-site DOT training

If you are new in the business, I think a 4-day seminar is a great starting place.

But, there is some training that all members of management should have.

BLUF: (bottom line up front) – The whole management team needs some DOT training, because without it, you might make a bad mistake that gets you in trouble with the DOT, and also because the DOT requires training for every employee, including mgt and drivers.

The biggest reason I say this is, I’ve seen so many situations where an organization runs like a well-oiled machine, but invariably someone makes a really bad decision that is a DOT violation they did not know about.

Example I: ‘Burns MFG’ runs like a giant Swiss watch, or like some big churches, with various management positions reporting to one another, creating a visual image of a wiring diagram you can see simply by whose office is biggest and who answers the phone when it rings etc.

But if there are, let’s say, 19 people working in the office and one person is designated Safety Manager, it’s a good bet the safety manager is the ONLY one who has a clue when to do a post-accident drug test and when not to do one. This may be one of the most common examples of that: when there is a wreck, the safety manager goes to the crash scene and whoever is in the office decides about what comes next.

Do we need to do a drug test? Yes, we will do a drug test, just to be on the safe side.

It seems like a safe bet, but it’s actually a critical violation if it shows up on a compliance review. This happened to one of my favorite long-time customers just a week or so ago.

Example II: Let’s just call them Echo Imports – they have several trucks and several good mechanics who fix things as quickly as the drivers break them. They had some good management practices that had been in place for years, but the original brains behind the operation has since moved on. Then, there’s a new CEO who is into cost cutting: Why are you putting those stickers on the outside of the truck? Is it required by the DOT? No? Well, let’s stop doing that – we’ll save $2.13 on each annual inspection.

Two years later, I’m doing a compliance assistance visit; I noticed the frequency of roadside inspections has increased and the frequency of violations as well. There are several things we can recommend to reverse the trend, but one of the recommendations I always make is to use those red stickers. They are not a DOT Requirement, but using them decreases the frequency of roadside inspections and violations. At Echo Imports, no one knew that, so they had stopped using them.

Example III: Let’s call this Dixon Land & Cattle; they have a feedlot and 21 trucks are used to transport feeder calves, hay, grain, machinery and equipment, and whatever else needs to be done. At one point, all the employees were either friends and neighbors or relatives. Over the years, they’ve grown and in the last 5-10 years, most of the entry-level employees they have hired were not known to them prior to hiring, and several of these are driving CMVs; including CDL trucks.

One of these drivers was a little sketchy about his previous work history; said he worked for company XYZ for the last 4 years, but when we sent a letter to that previous employer and got one back, it said he had only worked there for 2 years. Not understanding how important this discrepancy was, whoever was doing the hiring overlooked it.

6 months ago, that driver was in a collision and when the DOT realized they had a DQ file with an egregious contradiction between the driver’s work history and what a previous employer said, the company came close to being shut down over this and 2 other critical or acute violations.

This one is an acute violation, for presenting a false document to the DOT, when you knew or should have known it was falsified.

Example IV: Yelnushka is a small business engaged in importing rugs and fixtures from some country I cannot pronounce, but here in the US they accept deliveries at their distribution center, then make deliveries to home-décor stores and others, using their straight trucks and one F-450 with a trailer. All their employees are from the home country, but most have attended college in the US before becoming involved in the business, so they speak English well enough.

The business has been growing gradually for about 20 years, but in the past 5 years, it seems all their customers are becoming a little more demanding; they want to know with pinpoint accuracy when a delivery is going to arrive and they are asking to have some deliveries made directly to the end user. Along with the fact the business is growing at a healthy clip, this is beginning to present a more-challenging problem for the dispatcher each day.

So 2 years ago, they invested in a GPS system that tells them exactly where their trucks (and therefore the customer’s merchandise) are at all times. But the operations manager who made this decision doesn’t really talk to the person who keeps all the drivers logs and everything else the DOT might examine one day.

After being involved in a serious crash, involving 7 automobiles and their truck, the DOT comes in to look at their logs and supporting documents, among other things. There was no evidence of deliberate falsification on daily drivers logs, but the records the GPS system keeps is a discoverable supporting document and it never matches the paper logs exactly.

The DOT investigator found hundreds of examples of log falsification, AND the  GPS system was set to preserve delivery records for 90 days, so there was a false-log violation AND another for not keeping supporting documents.

So there are four clear examples of companies that could benefit from some customized, onsite training for management:
Example I – Burns – Critical D & A violation

Example II – Echo – Maintenance

Example III – Dixon – Driver files

Example IV – Yelnushka – HOS

In each of these cases, there are several people involved and just sending ONE PERSON to a seminar in Las Vegas, Chicago, Houston, or Dallas or one of the other cities we visit might not have prevented it.

But, if we have the chance to visit your company and present a one-day, two-day or even a half-day customized presentation on the rules that are most likely to impact your business, to a larger group, you might have the ability, as an organization, to avoid some of these really common pitfalls.

The D & A violation can come from only one person knowing when to do a post-accident drug and alcohol test or when to do a company-directed drug and alcohol test instead.

The Maintenance violation can come from an inexperienced management team shaving pennies here and there, and a failure to know about a common best-management practice that could have saved them a pickup truck full of pennies.

The Driver File problem can come from HR getting someone involved, with the safety manager thinking, “OK, I’ll just let them do this part, I’ve got too many things going on, anyway.”

The HOS violation can come about because a high-level decision-maker who decided how to do something operationally was unaware how it might impact the company’s DOT-mandated safety management processes.

In each of these cases, numerous members of a management team are involved in making important decisions every day. But none of them knew ANYTHING about how their decisions caused their business to be in jeopardy because of one or more Federal Motor Carrier Safety Regulations.

These rules apply to every business entity that dispatches commercial motor vehicles in interstate commerce, and they are NOT written by pencil-necked bureaucrats sitting behind desks, arbitrarily making transportation rules.

These rules are arrived at, one at a time, after a lot of people have lost their lives due to what was originally an innocent mistake. But, since the DOT has to make a rule, they made one called “General Applicability” that goes something like this:

  • These rules apply to every employer, employee and CMV.
  • An employer is NOT prohibited from requiring more stringent requirements.
  • Every employer shall be knowledgeable of. . . Every driver and employee shall be instructed. . . and shall comply. . .

So the bottom line is, you should have some DOT training for ALL Decision-makers, not just that one person who is primarily responsible for making sure these things are done, AND you should have some DOT training for everyone BECAUSE the DOT DIRECTS IT.

It’s a good investment; a lot of people do it; and we specialize in it.

If you are interested, contact our office; they have a list of 1-and-two-hour presentations that make up 4 days or more; we will make suggestions, but you can select a customized slate of training topics for your management team and we can deliver at your location or, if necessary, we can arrange a venue.

About DOT Compliance Help Inc
Phone: 847-836-6063 web: e-mail 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.

One Response to In favor of on-site DOT training

  1. I like your opinion about having everyone be trained. Having every driver and employee getting some sort of training would prevent a lot of accidents and problems, I would think. My brother really wants to become a trucker, so I’ll tell him about the training he’ll need to go through.

Leave a Reply

Fill in your details below or click an icon to log in: Logo

You are commenting using your account. Log Out /  Change )

Google photo

You are commenting using your Google account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s

%d bloggers like this: