What to Expect at a Compliance Review CTMA Conference July 2015.
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Transcript of What to Expect at a Compliance Review CTMA Conference July 2015.
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What to Expect at a Compliance Review
CTMA ConferenceJuly 2015
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What Triggers a Roadside Inspection?
•Visible violations▫Equipment, license plates, permits,
HM markings or placards, traffic violations
•Some states use random number generators
•HM transportation
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CSA Impact
•Roadside violations drive CSA Scores
•CSA Scores result in Basic Alerts
•Basic Alerts result in Compliance Investigations
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What Triggers a Review?
•Motor Carrier Compliance Review ▫Focused, Comprehensive, or Off-Site
▫CSA Scores▫Crashes▫Complaints (internal or external)▫HM incidents▫High-Risk HM (Explosives, RAM, PIH)
•May be Scheduled or Unannounced
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Preparing for a Review
• If not provided one, ask for a list of items the investigator will need to see during the review.
•Don’t manufacture documents!
•Have key personnel available during the review.
•Clear your calendar as much as possible.▫If a staff person is handling the review, check in
frequently.
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During the Review• Try to relax!
• Don’t be offended if the investigator wants to interview staff personnel privately.
• Investigators realize you won’t have every piece of paper at your fingertips right when they walk in.
• Realize that investigators must do “due diligence” and investigate all possible violations, and not just accept you at your word.
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HM Reviews•Be prepared for the investigator to:
▫Inspect the warehouse, loading dock, explosive magazines, etc.;
▫Walk around/climb on cargo tanks or other vehicles;
▫Inspect HM packages;
▫Take pictures.
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It’s Just Paper
•Paper is an indicator of how your operations are managed▫How is vehicle maintenance tracked?▫How are driver qualifications monitored?▫How are cargo tank qualifications verified?
•If it’s not documented, it didn’t happen▫Criminal and civil liability
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Who’s minding the store??
•Consider having a third party audit
•Outsider point of view
•DOT compliance often gets pushed aside for the urgent matters of the day
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The best way to prepare for DOT…
•Have a corporate attitude to Run Legal
•Establish a system to regularly manage compliance in these three areas:
Vehicles, including cargo tanksDriversHM transportation
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HM Training
•#1 Violation for PHMSA and FMCSA enforcement cases
•5 Categories of Training
•Must Certify that you have TRAINED and TESTED your HM Employees!
•Document, document, document
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Function Specific Training•Personnel who:
▫Make and retain shipping papers
▫Fill, load, close, and mark/placard packages and/or vehicles
▫Manufacture or test packages (cargo tanks, IBCs)
▫Manage HM employees
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Function Specific Training
•Special Permits
•Drivers – see 177.816 – CDLs are valid more than 3 years!
•Must be specific to what they do:▫Dock worker: Package Closure
Instructions, Special Permit, Segregation and Securement, Marking/Labeling/Placarding, etc.
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Training Questions
•How often do I have to provide training to my HM employees?
•If I change my security plan, do I have to provide training to my employees under the plan?
•What is the one training category that can never be accepted from a previous employer?
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Other Common Violations•Security Plans –
▫Incomplete – see 172.802▫No site-specific risk assessment
•Failing to report HM incidents – 171.15/16
•Cargo Tank maintenance▫Repairs by unregistered shops▫Improper/no tests/inspections
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Shipping Paper Violations• Improper Sequence
• No Technical Name
• Information interspersed
• No/improper ER TX#
• No ERI, improperly maintained in vehicle
• Fail to retain
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Shipping Paper Retention
•If using a permanent shipping paper in the trucks, are you maintaining a record?
•Shipper/Private Carrier : 2 years
•Must include date, UN#, proper shipping name, and quantity
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Be careful out there!
David W. Ford404-327-7374
HM Program ManagerSouthern Service Center
USDOT/FMCSA