Safety on the road is the most important activity for logging companies, and it’s also the most significant exposure encountered in day-to-day operations.
A large amount of time, equipment, and money is spent daily in the woods, but the exposure to the public is minimal. Logging trucks, however, encounter the public on a daily basis and must be diligent and attentive while traveling from the woods to the mills and back.
Federal Motor Carrier Safety Administration (FMCSA), Part 396.11, requires drivers to complete a daily written post-trip inspection, which stipulates:
Drivers must complete a written post-trip inspection report at the end of each day.
- The inspection report must identify the vehicle and list any defects or deficiencies discovered by or reported to the driver that could affect the safe operation of the vehicle or result in a mechanical breakdown
- The motor carrier or its agent must certify that any listed defect or deficiency has been repaired or that immediate repair is unnecessary.
- The motor carrier must maintain the original copy for three months.
- Part 396.11 does not apply to a non-business private motor carrier of passengers (PMCP) or to a motor carrier operating only one vehicle
- Prior to requiring or permitting a driver to operate a vehicle, every motor carrier or its agent shall repair any defect or deficiency listed on the driver vehicle inspection report that would be likely to affect the safe operation of the vehicle.
In simple terms, the driver must inspect the vehicle before leaving work and must repair or have repaired any deficiencies found during the inspection. This one area is and always has been the most difficult one for compliance. During my review of operations, I find one of three scenarios:
- It is noted that the driver inspects the truck, but fails to keep a record
- The driver skips the inspection all together; or
- Deficiencies noted are not repaired, making it easy for DOT officers as they inspect and note each and every item uncorrected, causing delays in delivery of the product to market or in getting the truck back for loading.
In 20 years of visiting logging operations, inspecting trucks, and talking with owners and drivers, I have found the following in almost all operations. Drivers rise early, usually long before the sun, and start their trucks to warm, walking around to check the lights, kick the tires, and head out. Only those items visible in the dark are inspected. Drivers must be directed to re-inspect their trucks during the first load in the daylight so they can see all components. Drivers must also be directed to stop and conduct another walk-around before entering the roadway. By doing so, many items normally cited can be avoided or eliminated altogether.
All DOT inspections are recorded and calculated in the Safety Measurement System (SMS). The FAST Act of 2015 required the DOT to remove percentage scores for the seven basic areas from the public’s view. This was done in October 2015. In March 2016, the DOT introduced the new performance measurement scores, which are based entirely on a specific carrier’s performance. The new system does not allow for inferences to be drawn concerning a carrier’s performance; however, the system provides historical information that offers a good picture of the carrier’s performance.
The system also provides the carrier’s percentage of Out of Service (OOS) Violations compared to the national average. Every logger should review the information on the SMS at www.ai.fmcsa.dot.gov, making note of the OOS percentage compared to the national average. We should all aim for a score below the national average, but when it is above, examine all inspections and violations to identify problem areas and devise plans for correction.
The SMS provides information needed to run sound businesses in a safe and responsible manner. Using the information provided in this article will assist you with improving your operations. For more information, refer to the FMCSA website at www.fmcsa.dot.gov or download the FMCSA’s resource, Guide on How to Comply, at www.fmcsa.dot.gov/safety-security/eta/index.htm. If you need assistance in reviewin
Reprinted with permission of Victor Insurance Services.