DOT Compliance Safety with Sun Tzu (Part 3) Prepare the Battlefield


Sun Tzu’s third lesson; “Prepare the Battlefield” . . . I’m not proud to admit this, but I started a 3-part discussion of the principles of Sun Tzu and how these time-honored management concepts might be well-used by a newly-hired or newly-appointed transportation safety manager today, a long damned time ago.

Sun Tzu part I – October 2016 –  “Know yourself”

Sun Tzu part II – October 2016 – “Know your enemy”

Sun Tzu part III – January 2018 – “Prepare the battlefield” . . . What can I say? I’ve been busy.

Here’s my suggestion; read parts I and II, THEN come back and read this one.

While you are at it, read the other blogs that follow Sun Tzu part II.

I just re-read them all, and I really mean it when I say they are good reading. And, if you are the new safety guy for a transportation department of a construction company, or a manufacturing company, or ANY entity that needs a truck or two as a part of it’s overall business footprint, this whole list is good reading. It’s stuff you need to know, put in a way that I’m not trying to impress you with what I know; like quoting the reg. word for word. I’m trying to put it in a way regular folks can understand and relate to.

I’m not going to apologize for the fact some of these titles are clearly self-serving:
I started in this business in 1988 and no one offered me a hand up. I’m trying to reach back into my own past and offer expert assistance to people who are experiencing the fear and panic I felt when I was made responsible for this unloved and un-resourced function in a company that was otherwise pretty robust.

January 2017 – Fine amounts changed by DOT

January 2017 – Who is DOT Compliance Help Inc.?

January 2017 – Mock Audit, or CAV

Jan 2017 – Seminar training

Feb 2017 – On site training

Let’s get back to Sun Tzu now: IF Sun Tzu was hired as the safety manager for a construction company today, clearly, he would assess his own position first, then assess the enemy; (carelessness, bad training, complacency, drugs, fatigue, etc.). Then, he would set out to develop the systems needed to cause the battlefield to be his (and his employer’s) friend.

Prepare the battlefield: I learned this important principle as a young engineer officer in the Army.  It’s all about improving the terrain to make the battlefield your friend.

If my boss, the infantry commander, wants to advance toward the enemy that is right in front of us, to the West, he wants to orient his main force in that direction, call in an air strike to soften up the enemy, and charge! Well, that might be a bit over-simplified, but that’s where the engineer comes in. When the infantry officer is just dying to say “Charge”, he is concerned about the possibility the enemy might advance from a different direction and cut in from, let’s say, the south, over some flat-looking pasture-fields in that direction.

“Engineer,” he says, “What can you do to protect my flank?” . . . the engineer gives him two or three options, including minefields, trenches and other obstacles, as well as the engineer’s “Magic Bullet” of aerial mines. If the infantry commander wants to advance in a straight line, and there is a river in front of him, he says to the engineer “How can you get me across that river?” or “Get me across that river” or “How long will it take you to get me across the river?”  You get the picture.

So now Sun Tzu has just been hired – he has sized up the situation (Enemy and friendly, vendors, suppliers and competitors) and he wants to ‘prepare the battlefield’. . . that’s the easiest part of the Sun Tzu vision to relate to your job as a safety manager:

  • Make sure you have a good hiring process. Of the 7 paragraphs that follow, this is the most important. Most people don’t do a good job of this. Ask yourself: IF a customer calls and wants you to haul 11 loads and you only have enough drivers to haul 10, and a truck parked out back, what do you do? You have three choices:
    1. Tell the customer you can only take 10 loads
    2. Tell the customer you have the situation covered and broker the last load
    3. Hire the first knuckle-dragger that crosses your threshold as long as he has a CDL.

Too many people go with option #3. and once you hire this bum, you have to live with him. He doesn’t follow the rules, he argues, he makes excuses, he gets lost, and he’s more likely to wreck a truck that most drivers. And if he is in a wreck, you might find out the underlying reason he’s such a butthead is, he was on drugs the whole time. Now that you’ve been involved in a bad wreck, the DOT is breathing down your neck and you WISH you were more careful about all that record-keeping nonsense the agency seems to think is so important.

Better to go with #1. . .  tell the customer “NO” today, leave the truck parked, but try to find a GOOD driver that is going to understand that following the rules and doing an honest day’s work is going to help him get ahead in the long run.

If you want to go with #2. . . make sure you have broker authority; it’s easy to do. But illegal brokering is almost never prosecuted so you might consider breaking the rules here, too.

  • Make sure you have a good D & A testing process (for CDL drivers)

Drivers that are on drugs are NEVER good drivers.

If you do everything the DOT wants AND THEN SOME, you’ll have less trouble in the long run. And, once you do it, make sure the paperwork is done exactly right. It’s easy to mess this up, but 95% of the time when I see a customer whose D & A paperwork is not right, it’s the underlying functionality of the D & A testing process that is lacking.

If your trucks aren’t getting put out of service all the time on roadside inspections, you probably have a good system. Now, look at the documentation; it’s really easy compared to DQ, D & A, and HOS.

  • Make sure you have a good HOS management system. Most people, I believe, are switching to ELDs now. Let me rephrase that; MOST people are investing in fleet management systems – HOS management is a small part of the whole FMS picture.

These first 4 are what I call the “Nuts and bolts” of DOT compliance. The DOT gives you some input into how to do this. If you have never done it, look at the list of critical and acute violations. In the seminar, I go over these but first I have to explain how important they are.

The next three paragraphs are a little more difficult to “put in a bag and hang on a nail.”

  • Managing the UNSAFE driving This means an effective management process to enforce, and reinforce, the message that drivers must comply with state and local laws. Too many moving violations means you are going to splatter someone on the road soon if you don’t straighten up your act. Written policies and  driver training are sometimes placed in this “cubby-hole”.
  • The HAZMAT BASIC – if you haul HMs, this is more important than all the other 6 combined; the DOT is much more likely to punish you for a minor violation in this category than for any of the others. If you DO NOT haul hazmat, there are a few things you need to do; I spend a little time talking about these things in the seminar. You can find a brief comment about it in FMCSR 383.111 (a ) (1) (iv) knowledge of part 397 TRANSPORTATION OF HAZARDOUS MATERIALS
  • Crash prevention – this is really what the first 6 paragraphs are about; but most people treat this as a separate area of endeavor. The DOT sees this as a separate system. If you are a safety manager, you should be spending a LOT of time doing this:
    a) Look at your situation;
  1. b) predict the next crash you will have, and
  2. c) find a way to prevent the crash you predict in your company’s future.

You can be a lot more formulaic about it, but no one has ever come up with a substitute for that 3-step process. It’s just like defensive driving, on an organizational level.

Now that you know yourself, know your enemy, and have prepared the battlefield, you can expect to succeed in every endeavor (Paraphrasing Sun Tzu again).

And hey, let’s be careful out there.

Signed,

Mike England

President, DOT Compliance Help, Inc.

847-836-6063

info@dotcompliancehelp.com

www.dotcompliancehelp.com

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

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