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29 The interviewee and his safety director attend truck shows, where they may receive training and information on both business and safety practices. Carrier H shares safety information, resources, and ideas with one other company that has a similar operation. Desired or Carrier H does not currently use EOBRs; however, the interviewee would like to install them. He Planned believed that they would help to reduce loading and unloading delays by making shippers real- Enhancements ize that HOS rules could not be broken. He also favored an EOBR mandate to "even the playing field." Small Carrier Even a small carrier has a wide array of business, operational, and safety issues to address. As a Advantages/ carrier grows, it inevitably must hire additional managers. Although growth provides more Disadvantages resources, it creates problems of its own. Other Comments/ A small carrier manager cannot get behind on safety or on anything. He or she must always be Lessons Learned proactive and cannot cut corners. In addition to things carriers can do, desired external changes include more flexibility in the HOS sleeper berth rule, stricter enforcement of trucks entering the United States, and easier access to driver applicant employment records. Finally, the interviewee believes that carriers who undercut the competition on rates are almost inevitably unsafe, because they must skimp on safety to achieve low costs. Although the government probably cannot set minimum rates, it could figure out a way to stop this. BUS COMPANIES The two bus companies represented included a charter company, Carrier J, was included because of its manage- company with 15 buses and a large transport company ment activities overseeing the operations of its 26 smaller owning 26 smaller subsidiary bus companies. The large subsidiaries. Carrier I, Bus Charter Carrier I Carrier I is a charter bus operation based in Pennsylvania. The company has 15 buses and Description employs 9 full-time and 25 part-time drivers. The company has operated for 30 years. Most of its trips are in the Northeast, but some go to Canada and the western United States. The company employs 11 nondriver employees, including sales/customer service representatives, mechanics, a bookkeeper, and a dispatcher. It is in the process of hiring a new driver trainer who will have other safety-related responsibilities. Interviewee and The interviewee was the vice president and general manager of the company. His father founded Job Description the company and is president, but is transitioning toward retirement. The interviewee has 11 years experience with the company. He has no experience as a driver and does not have a CDL. His job encompasses all aspects of general and operational management. Approximately 10% of his time is "directly" tied to safety, but much more time is indirectly related. He oversees all safety activi- ties, but does not conduct driver safety training because he is not a driver. He obtained much of his ongoing management development through industry trade association meetings and seminars, which he finds beneficial. Biggest Safety Highly rated problems on the questionnaire included at-risk driving behaviors (2), driver fatigue Problems and (3), driver selection and hiring (6), assessing driver on-road safety (7), rewarding/disciplining Challenges drivers (8), and lack of training materials for both drivers and managers (13, 14). The intervie- wee believes that driver safety was far more challenging than vehicle safety. If one does vehicle PMs, repairs, and inspections systematically, vehicle-related safety and compliance problems largely disappear. This is not possible with drivers. They are more variable and "out there on their own." Monitoring drivers for safety is more problematic than hiring or training them. Of most concern are driving behaviors such as tailgating, cutting-in, and red light running. These behaviors generally must be observed directly and cannot be easily detected and documented

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30 through onboard monitoring. Driver performance issues such as fatigue and health and wellness are also a concern, especially because most of Carrier I's drivers are middle-aged or older. CSA Challenges Regulatory compliance was not regarded as a major challenge by the interviewee. The company and Comments has had few bad inspections; the most recent was a log paperwork violation 18 months ago. The company has progressed "beyond compliance" in its safety program. In survey Question 15, Fatigued Driving/HOS (b) and Vehicle Maintenance (e) were rated as the most challenging CSA BASICs. Driver Fitness (c) and Cargo Securement (f) were rated as the least challenging. Most Important In Question 31, driver training and communications (b), scheduling/dispatching (e), and vehicle Areas of Safety maintenance (i) were rated as most important. A cross-cutting priority is documentation of safety Management policies and activities. An example is training; the interviewee would like to have much better documentation of company training programs, including both process and content. Successful small company growth is accompanied by more formalization of policies and practices, and by better documentation. Effective Safety Management practices used and rated effective include road/range screening tests (17), safety Management meetings (19), in-house training media (22), EOBRs (23), fuel economy monitoring (24), vehi- Practices cle PMs (26), and participating in peer meetings (30). Carrier I vehicles are equipped with DriveCam, which captured hard braking, hard swerves, and videos of critical events. This has proven very effective, but it does not capture nondynamic events such as tailgating. Carrier I is in the process of equipping its vehicles with GPS devices for navigation and to monitor driver speeds. A responsibility of the new driver trainer will be to regularly monitor these and indica- tors of driver behavior and risk. Problems are infrequent and addressed on an individual basis. Currently drivers are not given extra rewards for safe driving; the company has abandoned a pre- vious system that degenerated into driver bickering over unreliable indicators such as scratches on vehicles. However, the company is planning to adopt a "Pay for Excellence" system that was developed and used successfully by another company. "Pay for Excellence" was just one idea acquired through Carrier I participation in a 20-carrier idea-sharing consortium organized by the UMA. Participating carriers meet several times annually to discuss all aspects of carrier opera- tions and safety. Carriers within each group are carefully selected to be geographically dispersed and not in direct competition with each other. Approximately 10% of group discussions relate directly to safety. Carrier I recently contracted with a new provider of driver physical examinations for medical qualifications. This is to ensure that examinations are rigorous and that drivers meet all phys- ical requirements fully. The interviewee regarded this as a more effective medical interven- tion than those directed toward current employees. Company training and communications promote healthful driver behaviors; however, there were few indications of success, such as driver weight loss. However, interventions to force specific medical treatments [e.g., contin- uous positive airway pressure (CPAP) use by a driver with Obstructive Sleep Apnea] had been successful. Desired or As noted, the company is installing GPS devices with safety applications such as speed moni- Planned toring. It wants to take full advantage of GPS-related safety applications. Carrier I is also devel- Enhancements oping a more systematic process to monitor driver fuel economy and will be adopting the "Pay for Excellence" reward system mentioned earlier. Although Carrier I regards most of its drivers as safe, it wants to use these techniques to better deal with those at the lower end. With regard to driver training, the interviewee expressed a desire to find better web-based or other training pro- grams on safe driving methods, such as setting mirrors and making safe turns. Small Carrier In a small company, the manager knows everyone directly and can react by "gut instinct," not just Advantages/ based on cold statistics. This is an advantage but also a disadvantage in some respects. Having Disadvantages more statistics based on more data would allow a manager to make more objective, data-driven decisions.

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31 Other Comments/ "Make sure you have good equipment inspection, listen to mechanics, and pay attention to Lessons Learned driver hiring." Company safety standards must be "beyond compliance." Company pride and protecting company image are among the strongest motivators of safety excellence. Bus com- panies are particularly vulnerable to single, high-exposure crashes or incidents that could irreparably damage a company's reputation. Carrier J, Large Bus Company (Owner of 26 Subsidiaries) Carrier J Carrier J is a passenger carrier with more than 1,000 vehicles. It is included in this study because Description it owns and oversees 26 smaller companies located throughout the United States. This includes charter services, crew transport, contract services, commuter/transit lines, tours, casino services, and shuttles. Many of their subsidiaries were "Mom and Pop" companies that grew large enough to attract acquisition by Carrier J. Many of the companies are still managed by their original own- ers. The perspective provided in this write-up is that of a large company overseeing subsidiary operations and thus having insight into their common safety practices and challenges. Interviewee and The interviewee has 48 years experience in passenger transport. Most of his career was with Job Description another large bus company, where he retired as Director of Driver Operations. He has a CDL and conducts driver training, but has never worked as a driver. His experience encompasses both driver and vehicle safety; among his past job titles is Regional Maintenance Manager. He also has experience in sales and marketing. Biggest Safety Highly rated problems on the questionnaire included a lack of basic driving skills (1), at-risk driving Problems and behaviors (2), driver fatigue (3), driver selection and hiring (6), assessing driver on-road safety Challenges (7), nondriving injuries (11), and a lack of training materials for managers (14). The interviewee stated that hiring and retaining safe drivers were the biggest challenges for small bus companies. The operations of many of Carrier J's subsidiaries vary seasonally, which means that they hire new drivers every year. Because of this and normal turnover, hiring and training drivers are con- tinual concerns and activities in most Carrier J companies. Driver safety risk factors include both medical fitness and choice behaviors such as speeding and tailgating. CSA Challenges In survey Question 15, the interviewee indicated five CSA BASICs of high importance: Unsafe and Comments Driving (a), Fatigued Driving/HOS (b), Driver Fitness (c), Alcohol/Drugs (d), and Crash History (g). Carrier J's website lists all its subsidiaries and for each provides current data on their CSA BASICs. This includes on-road inspection data and, when applicable, investigation and BASICs status data. Although overall company safety performance is very good, a few subsidiaries showed HOS and vehicle inspection violations. The interviewee believes that bus charter sales representatives sometimes overpromise customers with regard to trips possible within the HOS rules (e.g., 10 hours driving for buses). This sometimes leads to HOS violations for their drivers. Most Important In Question 31, driver selection and hiring (a), driver training and communications (b), and driver Areas of Safety scheduling/dispatching (e) were indicated as the most important areas of safety management. Management The first two of these were emphasized in interview comments. Effective Safety The following were indicated as effective safety practices for the company as a whole: road/ Management range screening tests (17), driver applicant questionnaire (18), safety meetings (19), driver safe Practices driving bonuses (20), web-based training programs (21), in-house training media (22), vehicle PMs (26), reimbursing tolls (28), tracking company safety statistics (29), and participating in peer meetings (30). Carrier J requires most of its subsidiaries to engage in these practices. Com- pany-wide requirements include a largely standardized driver selection system. Selection includes medical qualifications reviewed by a single medical provider for consistency and rigor, and then updated annually instead of every two years as required by the Federal Motor Carrier Safety Regulations (FMCSRs). Driver applicants fill out two questionnaires, one of which is a private self-assessment that they do not turn in. The self-assessment confronts applicants with

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32 the challenges to expect on the job so they have no delusions moving forward. All of Carrier J's buses are equipped with GPS units, which provide navigational aid to drivers and records of vehicle location and speed. Most are also equipped with DriveCam for crash and incident documentation. Desired or Carrier J plans to become more systematic in its monitoring of subsidiary companies. This Planned includes plans to have traveling auditors who visit each company for 7 to 10 days to monitor Enhancements safety, environmental practices, and other aspects of company management. Carrier J is also placing more emphasis on Behavior-Based Safety (BBS), both for crash reduction and to reduce nondriving injuries. Small Carrier The interviewee believes that Carrier J has achieved "the best of both worlds" in its safety man- Advantages/ agement. Each subsidiary deals with a smaller number of drivers and other safety factors, and Disadvantages thus has more direct control over them. Meanwhile, the parent company provides resources and guidance that the individual subsidiaries would not otherwise have. Other Comments/ The interviewee believes that the safety standards it imposes on its subsidiaries consistently Lessons Learned improves their safety. In some cases, improvements have been dramatic. Small company own- ers (who become general managers when companies are acquired by Carrier J) still exert a huge influence on the company's safety climate and outcomes, however. Their leadership is key.