OTA Dispatch Issue 4, 2020

32 Oregon Trucking Associations, Inc. Oregon Truck Dispatch Is Your Safety Policy Up-to-Date? By Adam Williamson, OTA’s Director of Training & Development WRITTEN SAFETY POLICIES play an important role in a carrier’s overall safety program. A well written policy will provide not only a formal introduction to safety awareness for new employees but also a degree of protection against civil litigation. Actual implementation of the policy is key but having a policy to begin with is a good starting point. A baseline standard for written safety polices should reflect compliance with the relevant regulatory agencies. Regulations issued by FMCSA (Federal Motor Carrier Safety Administration) will be most directly applicable to carriers, especially as it relates to driver safety. Regulations issued by OSHA (Occupation Safety and Health Administration) will also be applicable. These regulatory agencies establish rules for key areas such driver hours of service, vehicle maintenance, and drug and alcohol testing. A comprehensive SAFETY safety policy will address each one of these areas in detail. Safety policies should be reviewed regularly (at least once a year) to see if updates are warranted. Just in the last couple of years, several notable revisions have been made to key regulations that should be reflected in policy updates. Such changes include: ` Acceptable driver use of personal conveyance has been expanded to include vehicles that are laden. Carriers are responsible to set limits for personal conveyance usage by drivers to prevent abuse. ` FMCSA’s drug and alcohol clearinghouse went into effect in January of this year. The clearinghouse rules require all carriers and most CDL drivers to register with the clearinghouse so that annual and pre- employment queries can be performed. ` Hours of service rules have been revised to allow greater flexibility with 30-minute rest breaks, local air mile radius exemptions, 14-hour driving windows, and adverse conditions. ` The federal mandate to equip CMVs with electronic logging devices was adopted by Oregon for intrastate operations this spring. Hard enforcement began in October. In addition to regulatory updates, the year 2020 has brought us numerous emergency declarations and provisions related to COVID-19. As these declarations have repeatedly needed to be extended, OSHA has taken steps to formally regulate COVID-19 safety protocols for the foreseeable future. These changes should also be reflected in carrier safety policies. In addition to compliance-oriented policy, we should not forget the importance of emphasizing best practices. Safety regulations are often only a minimum standard and should be supplemented with best practices when necessary. As our industry is ever evolving in this area, there will be a need to keep up with advancements in emerging approaches to safety. Safety policies are indeed an important part of a carrier’s safety program. However, just because you have an existing safety policy does not mean that you are staying current. The trucking industry is—pun intended—always on the move, and our safety policies need to keep pace. Contact OTA if you need assistance with creating a safety policy for your organization. Email safety@ortrucking.org.