When it comes to pre-trip inspections, it is now far easier for a safety auditor to see when a driver is not properly doing their job. Why? Consider that the FMCSA has now changed the process for completing a compliance review.
The revamped compliance review – which has been in place for some time – expands the interviews the FMCSA completes with specific members of the organization. Still, this doesn’t mean there has been a major overhaul in how the FMCSA completes a compliance review.
For some time now, the FMCSA has been moving away from full reviews and closer to focused reviews. Still, new trends are emerging as the FMCSA slightly shifts its focus.
CSA Scores or Complaints?
If you look at historical trends, the FMCSA has generally put complaints below CSA scores on their list of review priorities. Up until now, a BASIC alert was the primary factor for whether the FMCSA decided to complete a compliance review. Now, that is changing.
The main reason for the shift is in two areas. One is the truck driver coercion rule and another is how easy it has become for a complaint to be filed, which has dramatically increased the volume of complaints flooding into the office.
Many complaints are now treated as though some form of coercion has taken place, even if little to no evidence of coercion is found. This is leading to carriers who have no BASIC score alerts undergoing a focused review.
Hours of Service
Despite a move away from paper logs and toward electronic logging, hours of service violations still abound. This is especially the case where false logs are concerned.
Therefore, it is so important for fleets to ensure that the time being reported is cross referenced with the truck driver’s log. And this must go beyond a simple accounting for the date.
Whether the fleet looks at fuel reports, tolls or reimbursements receipts, there are several ways to cross-reference what is being reported.
Medical Card Changes
With the “grace” period ending, it is more important than ever that a motor carrier verify a physician’s license utilizing a national registry or running a CDLIS report.
Should you run a report from an arbitrary fleet system or utilize the CDLIS report? To avoid a potential focused review, it is very important to utilize a CDLIS report.
Consider that on your own internal report, you may not have all the necessary information at hand. The fact is, you don’t want to risk it, so why not run the report that you know will ensure you have all the boxes checked?
Managing Your DVIR Process
It is now easier than ever for an inspector to make a case against a truck driver who doesn’t have a proper vehicle inspection report on hand. The new rule now requires that a DVIR must be filled out when a defect has occurred, which makes it easier for an inspector to make a case for a focused audit.
This essentially means inspectors can use a roadside inspection with a maintenance issue listed and corroborate that issue with a DVIR that correspond with the date listed. It’s also important to pay close attention to breakdown reports, repair orders and maintenance records. If these show obvious problems that the truck driver should have been aware of – but weren’t listed – you could find yourself on the receiving end of a review.
Finally, it’s important to ensure your operators are not operating with a suspended or invalid CDL. While this may seem like a very basic requirement, it is resulting in even more violations than ever. Ensure an internal process is set up to monitor each of your truck drivers’ CDL statuses.