These are busy days for tank truck fleet safety managers and the companies that employ them. Safety compliance challenges are growing by the day, and the situation seems likely to worsen over the next few years.
The entire trucking industry is being buried under an unprecedented regulatory blizzard from Washington DC. Fleet safety managers and their departments bear much of the burden for plowing the way through the deepening drifts of new and expanded regulations. It is an unenviable task.
Topping the pile is Comprehensive Safety Analysis (CSA) 2010, the new Federal Motor Carrier Safety Administration (FMCSA) initiative designed to improve large-truck and bus safety and ultimately reduce commercial motor vehicle-related crashes, injuries, and fatalities. The rule launches in November, but the roadside inspection data used by CSA 2010 already is being posted online. We address CSA 2010 in detail in this issue of Bulk Transporter.
Designed to replace the flawed SafeStat program, CSA 2010 has good aspects that could improve trucking industry safety, but it also contains some scary elements. On the good side, the program has the potential to more accurately identify high-risk fleets and truck drivers. The scary side is that fleets could become the targets of enforcement and intervention actions almost overnight and with little warning.
Many industry officials are calling CSA 2010 a game-changer for trucking, and that it is. It gives enforcement officials a much bigger stick to use in disciplining trucking companies, and these officials literally have the power to determine whether a fleet lives or dies. Drivers who accumulate too many points under the system probably will be rendered unemployable as truck drivers.
Fleet safety departments will have the critical responsibility of tracking all of the CSA 2010 data posted monthly on the FMCSA website. Errors must be caught immediately, and safety officials must work aggressively to have bad data removed.
In addition, they will need to check the CSA 2010 scorecards of driver applicants as part of the pre-employment screening process. They will need to track scorecards for all of their current drivers, and quick action will be required when problems arise.
Regulations covering distracted driving and cell phone use have brought more training and oversight responsibilities for safety departments. New driver hours-of-service rules are under development at the Department of Transportation (DOT) and probably will bring more monitoring and management requirements. The sleep apnea issue has not gone away, and a regulation is still a possibility.
Hazardous materials carriers will face more regulatory action on security and safety. DOT made it clear in a recent guidance document that it would be a good idea to require electronic on-board recorders for hazmat carriers. Other studies call for geofencing and other security monitoring technologies.
Trucking companies are getting more regulatory attention from the Department of Labor and its agencies. This is only going to get worse. Many Obama Administration appointees are organized labor/anti-business zealots.
Enforcement of existing regulations is the focal point, and industry experts are saying that fleet safety managers are among those being targeted for enforcement actions, including criminal charges. Key enforcement areas are hazard communications, respiratory protection, personal protective equipment, and confined-space training.
Slips, trips, and falls are in the Occupational Safety & Health Administration (OSHA) sights. The agency recently issued a notice of proposed rulemaking to make the fall protection rules more rigorous. DOT currently has jurisdiction over transportation equipment fall protection, but that responsibility could be transferred to OSHA under the Obama Administration.
It takes a well organized and well managed safety department to keep up with all of the current and pending regulations that affect today's truck fleet operations. The recordkeeping and data retention requirements alone are enough to keep a team of safety managers and clerical workers busy around the clock.
Many tank truck fleets make do with a very small safety staff, and these people do an incredible job. By and large, these departments are run by outstanding safety professionals who work tirelessly to make the tank truck industry the safest segment of trucking.
In today's regulatory climate, each tank fleet needs to build the most effective safety department it can afford. It will be critical to survival. The only thing worse than an underfunded, ineffective safety department is no safety program at all.
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