In the eyes of the FMCSA, motor carriers already have all the information they need to be compliant. What they often lack is the proper policies and controls. One way to determine where you might be vulnerable is by having an expert assessment.
Just like an actual FMCSA audit, an assessment will focus on three main areas of compliance: hours of service, maintenance and driver qualification files, says Ed Emerick, the lead safety consultant for J.J. Keller and Associates, which provides training programs, consulting, managed services and technology for fleet safety and compliance.
During an assessment or “mock” audit, an experienced advisor will pull records, review policies, and interview fleet administrators to identify areas in need of improvement, he says. An advisor will also look for instances where a fleet does not have a clearly defined process to manage exceptions.
“What often happens is there is no functional practice or policy documented,” he said. “People can regurgitate regulations but that does not always help.”
Company policies need to be more than policies; they need to task driven, he said. A fleet may have all its driver files in order but struggle when asked to explain how they manage exceptions. People may start to point fingers.
“A lot of times I will ask ‘who is responsible for this?’ and get four different answers,” he said. “During an audit that’s not good.”
Tasks should be assigned to a job function and responsibility rather than an individual person, he advises.
J.J. Keller offers a premium audit assessment program where advisors will conduct an on-site review to score fleets in over 500 areas. The scores are compiled into a J.J. Keller Performance Rating, a tool designed to measure and benchmark their risk exposure and performance against other fleets, with their other locations, and with their future progress.
For a fleet with 100 drivers, a J.J. Keller Advisor would spend between two and four days on site, similar to the amount of time an FMCSA auditor would spend onsite to conduct a full-scale compliance review, says Steve Murray, J.J. Keller’s senior director of consulting services.
