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Compliance Review at CTMA Conference July 2015: Triggers, Preparation, and Training

Get insights into what triggers a roadside inspection and a compliance review, and learn how to prepare for a review. Understand the importance of HM reviews and the significance of paperwork in managing operations. Explore the benefits of third-party audits and the necessity of HM training. Avoid common violations and shipping paper errors. Get expert advice from David W. Ford, the HM Program Manager at USDOT/FMCSA.

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Compliance Review at CTMA Conference July 2015: Triggers, Preparation, and Training

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  1. What to Expect at a Compliance Review CTMA Conference July 2015

  2. 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

  3. CSA Impact • Roadside violations drive CSA Scores • CSA Scores result in Basic Alerts • Basic Alerts result in Compliance Investigations

  4. 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

  5. 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.

  6. 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.

  7. 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.

  8. 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

  9. 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

  10. 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 tanks Drivers HM transportation

  11. HM Training • #1 Violation for PHMSA and FMCSA enforcement cases • 5 Categories of Training • Must Certify that you have TRAINEDand TESTEDyour HM Employees! • Document, document, document

  12. 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

  13. 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.

  14. 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?

  15. 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

  16. Shipping Paper Violations • Improper Sequence • No Technical Name • Information interspersed • No/improper ER TX# • No ERI, improperly maintained in vehicle • Fail to retain

  17. 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

  18. Be careful out there! David W. Ford 404-327-7374 david.ford@dot.gov HM Program Manager Southern Service Center USDOT/FMCSA

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