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2015 2nd Quarter - NASTC Management and Safety Program
NASTC's Management and Safety Program
I must be very careful in my wording while commenting on this topic to avoid hypocrisy.
Imitation is supposedly the highest form of flattery and NASTC is very flattered by the surfacing of FMCSA’s “beyond compliance” program as this thinking is the cornerstone premise of our Management and Safety Program (MSP) which I’m once again publishing in this newsletter.
Such concepts as monthly or quarterly MVR updates, real time log audits for all drivers, all trips, monthly audio safety and awareness programs, driver monitoring decals with a public 800 number response capability on all trailers, pre-screening tests for obstructive sleep apnea, twenty-four hour turn around on drug screens, on-site collection for drug screens, and, ongoing CSA analysis are all a part of MSP, and all go far beyond the minimum requirements of the regulations.
These concepts have been offered (all or in part) for over six years now and we can certainly make the case that this risk management protocol is bearing impressive fruit with the companies and drivers who allow us to install MSP into their business model. Their CSA numbers are twice as low as like-sized NASTC members who aren’t on the program. All of these initiatives and programs are setup and supported by NASTC employees and are designed to be simple, driver-friendly, not time consuming, and affordable. We would not want to offer our MSP model however in the “best practices” contest to be judged by FMCSA, but rather have these concepts tested as valuable tools in THE MARKETPLACE, where they belong. We have been offering simple, inexpensive ideas for decades to the agency and to anyone else who’ll listen, and we’ve been summarily dismissed for the most part. Why?
Because our ideas are not expensive and they tend to “level, the competitive playing field” with the mega fleets in the safety arena without a million dollar budget.
We know that there is a direct and impressive correlation within the NASTC community of companies between safety and profitability. Our programs become good business decisions (not mandates) because as the safety culture improves, the operating ratio gets healthier, driver turn-over decreases, insurance costs decrease, and better freight rates are achieved.
Questions that go unanswered:
1) Why are driver turnover and dispatcher/ driver ratios not safety issues addressed by the agency?
2) Why are rumble strips, an inexpensive and proven safety tool, not on every inch of interstate highways?
3) Why did the 3 year long experiment with EOBR’s with Werner Enterprises not disprove the safety value of those devices? Their numbers got worse. Also, by FMCSA’s own cost/benefit analysis mandated ELD’s are projected to save 19 lives. Based on 2013 fatality numbers this represents a .005 decrease which is statistically meaningless and unsupportable by any scientific measurement, despite the fact that implementation of mandated ELD’s will cost the industry 1.5 billion in year one.
4) Why has the value of a human life gone from $1,000,000 to over $9,000,000 in supposed cost/benefit analyses by the agency?
5) Why has the out-of-service criterion for a commercial vehicle grown from 7 pages in length to 77 pages in length with no corresponding increase in the percentage of out of service violations?
Congress and the agency tend to talk out of both sides of their mouth when it comes to the behavior of FMCSA and other federal agencies. The Administrative Procedure Act is federal law, passed by Congress. It directs among other things that the agency be data driven and that a valid cost/benefit argument be convincing prior to implementation. The agency over the past decade has paid lip service to this requirement or ignored it altogether numerous times. The agency also is charged with doing impact studies on small business models, competition, and efficiencies prior to going through the RuleMaking Procedure. They continually ignore this consideration and the OMB, who’s supposed to hold them accountable, has failed to adequately perform this oversight function. Also, in this newsletter, you will see a copy of a letter addressed to the agency, and the OMB regarding the recently completed negotiated rule-making for entry level drivers training requirements and its questionable cost/benefit justification.
Though I’ve wandered about a bit on this article, I would like to sum up NASTC’s preliminary feelings on the agency’s “beyond compliance program.” We do not feel that it is within the scope of the agency’s charter to begin to pick winners and losers regarding safety, establish “best practices” that will reflect nothing but mega-fleet input, and/or further discriminate against our members, the small, family-owned, rural-based trucking companies that represent approximately 90% of the companies who move freight for hire in the full-truck load niche and, represent many of the safest companies in that niche.
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