Can you guess the most common violation when enforcement agencies log trucking violations? It’s an acronym we’re all familiar with: HOS, or Hours-of-Service. Just consider for a moment that the Federal Motor Carrier Safety Administration provides a portal where roadside inspection results are displayed. Up to this point, it shows nine of the top 20 driver violations are related to hours of service. And if that isn’t bad enough another 11 of the next 20 recorded violations. Hours of service remains a top violation and fleet manager must ensure their truck drivers keep it front of mind.
Trucking companies are well aware of how the seven Behavior Analysis and Safety Improvement Categories (BASICs) categories are ranked. They must deal with these measurements every day. And when it comes to a fleet’s Compliance, Safety, Accountability (CSA) safety percentile ranking, FMCSA puts the most weight on three BASICs.
- Unsafe Driving
- Hours of Service Compliance
- Crash Indicator
Of those three, it’s no secret that the FMCSA pays the closest attention to HOS compliance. Wondering why there are always so many roadside inspectors are watching for HOS violations? Well, quite frankly, it’s because the federal government finds HOS to be the most important factor. As a result, enforcement places a priority on HOS compliance during roadside inspections and audits.
Hours of Service Violations Are Too High
The simple fact of the matter is that HOS violations across the trucking industry are too high. Trucking companies of all sizes must make greater efforts to ensure their truck drivers we both aware of and understand HOS regulations, why they are important, and how to avoid violation. There are a couple of questions smart fleet managers usually ask when they evaluate HOS violations and how to prevent them.
- Which truck drivers are responsible for the most violations among the fleet?
- Among that cohort, how can we address the behaviors causing HOS violations?
To be clear, this is about more than just avoiding violations. The stakes are so high because people’s lives are at stake. Sure, trucking companies deliver goods, but in transporting them, we have the safety of other road users in our hands. If we are driving more hours than we should be we run the risk of falling asleep at the wheel. When that happens, the worst is possible.
Obviously, violations also negatively impact the motor carrier that receives them. Trucking companies are also aware of the Inspection Selection System (ISS). Repeated HOS violations can elevate a motor carrier’s ISS score. But how does that alone negatively impact them? First, it could cause the trucking company to get denied if they participate in a weigh station bypass program.
If a fleet is not participating in a bypass program, an elevated ISS score increases the likelihood of its trucks being pulled into weigh stations. This, in turn, causes delays and service disruptions, causing customer service issues and headaches for truckers. And when enforcement events are occurring, you can bet your trucks will get pulled over if you have elevated ISS scores. International Roadcheck, where every commercial motor vehicle is available for inspection, could become your worst nightmare.
We Are All Responsible for Good ISS Scores
Consider for a moment that we all have a little hand in how good or bad our fleet’s HOS-related scores are. Let’s look at some of the common reasons for a violation. We’ll start with the third-most frequent of all truck driver violations: “False report of driver’s record of duty status.”
Truck drivers receive the ignominious award for this violation when their HOS numbers don’t match. And even worse, truck drivers who are violated for HOS issues are placed Out of Service (OOS) nearly 67% of the time! That’s a massive number. And we know that when a trucker is out of work, they aren’t making money. These kinds of problems negatively impact people’s lives.
Another common one relates to electronic logging devices (ELDs). We remember many years ago when ELDs were first mandated, and the trucking industry was beside itself with worry. Today, ELDs are quite common, easy to come by, and simple to navigate and operate. Yet, they remain an incessant violation, plaguing truckers both old and new, experienced, or not.
In fact, the sixth most cited ISS violation is the failure to have an electronic logging device (ELD) to begin with. Honestly, it is an unacceptable and easily remedied violation. And if you thought the OOS result on the HOS side is bad, consider on the ELD side, the OOS rate is over 95%. If you don’t have an ELD, you don’t drive, and the enforcement mechanism ensures that.
Fleet Management Must Set the Tone for HOS Compliance
As we mentioned before, HOS compliance is part of everyone’s job. Everyone in the fleet has a say in HOS compliance success. Still, before anything else, HOS compliance is a management responsibility. Fleet management has access to individuals and departments within the organization that can provide a safe and legal compliance framework. Only management can provide the framework for safe and legal fleet operations and expect truck drivers to stay within that framework.
Let’s take a closer look at specific responsibilities fleet management must keep in mind. First, only management can hire drivers familiar with hours-of-service rules. They also have a responsibility to provide the equipment – ELDs and record of duty status (RODS) sheets — necessary to record and display HOS compliance. They must also maintain an effective training and development program. This program should train truck drivers how to properly use the fleet’s ELD model, plus the ELDs on any rented or leased tractors, which may have a different ELD. Finally, managers must make sure they are on hand to conduct oversight of the operation.
Additionally, only company management can ensure lines of communication remain open and explanations are clear and actionable. Leadership must ensure their respective departments provide information on customer updates, the time needed for equipment repair and replacement, route information, weather and road conditions, traffic, and any adjustments to dispatch schedules to help truck drivers operate safely, efficiently, and within compliance.
As with any company, management bears a lot of responsibility for the success or failure of internal initiatives. These are concrete actions management must take to remain HOS compliant. There is no room for complacency when it comes to compliance. Still, it is important to remember that the root cause of documented HOS violations may not begin with management’s approach.
Truck Drivers and HOS Responsibility
Of course, truck drivers must make sure they always operate within HOS limits. It is the truck driver who must correctly record and annotate their time. A common truck driver failure – though many times unintentional – is forgetting to log on and log off an ELD at the beginning and end of each workday. This may seem minor, but it can have serious knock-on effects.
The result can be time improperly carried over from a previous truck driver or attributed to a later truck driver. As a result, both drivers’ time is incorrect. This type of violation can also impact what happens in the shop or the yard.
Still, truck drivers follow dispatch orders. Those orders represent commitments that management and its sales department have made to customers. Management must commit only to operations that truck drivers can run safely and legally. They must take time to test new runs for realistic speeds and available parking along the new route. Management, dispatchers, and sales staff must resist customer requests to add another delivery to an already full truck driver schedule.
In the end, it is up to everyone within the organization to ensure highways are safer and more efficient through effective policy decisions and follow-through. Fleet managers must take the time to understand their operation and truck drivers’ needs before coming up with a solution. They’ve got to understand their business operation, goals, objectives, and challenges.
In addition to ensuring proper training and development, fleets have access to a powerful suite of systems using modern technology. From weigh station bypass to toll payment services and more. Through a combination of technology and policy, trucking companies improve safety, reduce compliance risk, and control operating costs.