Safety Management in Small Motor Carriers (2012)

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17 This chapter presents findings from ten case study interviews with carrier owners/managers. The case studies are based on phone interviews, which followed the completion of the sur- vey for each respondent. The final survey question asked respondents if they would be interested in participating in a paid follow-up interview to discuss innovative fleet prac- tices. The question included the assurance, “Responses will be confidential; no interviewees or carriers will be identified unless desired.” Interviewees were selected based on their willingness to participate and on indications in the survey that they were actively engaged in carrier safety. The project team contacted 15 respondents by means of e-mail and/or telephone; ten responded to the request and agreed to partic- ipate. The phone interviews lasted approximately 40 minutes each and followed a structured but flexible sequence of ques- tions. Interviewees were sent a small payment ($50.00) in appreciation for their participation. As seen in the individual interview summaries, the inter- views addressed the following general topics: • Carrier description • Interviewee background and job tasks • Carrier safety problems/challenges • CSA challenges • Important areas of safety management • Effective safety management practices • Desired or planned safety enhancements • Additional comments. The responses shown in the right column of each case study summary include some answers transcribed from the survey questionnaire in addition to comments from the phone interview. When specific survey answers are cited, the ques- tion number or answer choice letter is provided in parentheses next to the answer. Companies are identified here only as “Carrier A,” “Carrier B.” No interviewee names or company contact information is provided. All of the interviewees projected themselves as consci- entious individuals and well-intended managers of their companies’ safety operations. Many good safety insights and examples of effective management practices are pro- vided in the case studies. Nevertheless, project resources did not permit formal evaluation of any carrier or its practices. No carrier or public records on safety or compliance were examined. Doing so would have required a far greater con- tract effort and would likely have sharply reduced participa- tion. Practices described should be taken as suggestions for consideration by readers, not necessarily as scientifically proven methods. Industry readers may judge for themselves the applicability of methods and ideas presented to their operations. As with the project survey, the structure interviews and case study write-ups are intended to capture both objective information (e.g., carrier characteristics and practices used) and subjective information (e.g., opinions on safety risks, effective practices, and outside factors affecting their com- panies). Some of the interview questions addressed contro- versial topics, most notably government regulations and enforcement practices (CSA in particular). Varied views on these topics were stated and are conveyed here to fully and accurately capture interviewee opinion. These opinions may be paraphrased in the write-ups or provided as direct quotations. Case study examples and interview comments will be revisited in chapter four, Evidence Review, in the context of specific safety management topics (e.g., driver hiring and training). In addition, insights from the case studies inform the report conclusions presented in chapter five. TRUCKING COMPANIES Eight trucking company owners/managers were interviewed. Their case studies are presented here in ascending order of carrier size (number of power units). Six of the eight companies were in the principal targeted carrier functional size range. This was defined as large enough to have a man- ager who drives less than 50% of the time, but too small to have multiple managers including a designated manager of safety and/or compliance. The exceptions are Carrier A, that has three trucks and husband–wife co-managers who also drive full-time, and Carrier H, which has in recent years grown large enough (26 trucks) to have both a gen- eral manager and a safety director. These two carriers were included to provide the perspectives of companies just smaller than, and just larger than, the principal carrier size of interest. CHAPTER THREE CASE STUDIES

Carrier A, based in Canada, has just three trucks, although it will soon add a fourth. The company is owned and managed by a husband and wife who both drive full-time while jointly managing the business. They employ a third driver and soon plan to bring their adult son into the company as a driver. Carrier A primarily hauls rolls of paper in dry vans, serving four paper producers. Their trips take them down the East Coast, to the Midwest, to Texas, and sometimes farther west. Most trips are 4 to 5 days, although their third driver is usually out for 8 to 10 days and home for 4 days. Carrier A works under contract to a larger TL carrier that buys its insurance and books its loads. The interviewee had been raised in a trucking family and spent 18 years of her career doing admin- istration and accounting for a trucking firm. Seven years ago she and her husband started their own company, and she became a driver–manager. Both drive full-time while splitting company man- agement and other tasks between them. She does the administrative, tax, and other office work while he maintains the vehicles. On the survey form, the interviewee rated almost all of the 14 safety challenges presented as being extremely important. In comments, she made it clear that vehicle maintenance was the dominant ongoing safety management concern. She was less concerned about driver safety issues because she maintained a high level of confidence in her husband, herself, and their third driver. They have 74 combined years of crash-free and claim-free driving. She did worry about the “stupid things [other motorists] do that create a hazard and put myself and other motorists in danger.” She also worries about random equipment failures. She had had a scare when a steering tire blew out and her truck ended up in the median. “Anything can happen out there,” she said. In survey Question 15, Fatigued Driving/HOS (b) and Cargo Securement (f) were rated as the most challenging CSA BASICs. Driver Fitness (c) and Alcohol/Drugs (d) were the least chal- lenging. CSA and roadside inspections exert strong pressure on Carrier A, and the interviewee believed that the system was often unfair. For example, she had been cited for a vehicle violation on a brand new trailer and regarded the citation as bogus. Although it is possible to appeal, the process is too onerous and time-consuming. Some equipment failures such as burned out lights occur randomly and are not always detectable while driving. Carriers can minimize these viola- tions, but they cannot eliminate them. Sealed loads present an unfair noncompliance risk for drivers, especially those crossing the border. A load sealed by a shipper cannot be opened for inspection by the driver; if the seal is broken, the receiver will refuse the load. However, it may be opened by inspectors, especially at the border. If there is a load securement violation, the carrier and driver are the ones cited. Sealed loads may also create safety risks apart from compliance issues. The driver may not know how a partial load is packed. Knowing this would help the driver avoid load shifts. She believed that cargo securement regulations and enforcement should be directed toward ship- pers when they pack the load, and especially when the load is sealed. Another regulatory/enforcement complaint concerned small non-CMV trucks (e.g., pickups) that are overloaded and/or have gross vehicle deficiencies, which can be substandard and extremely hazardous, but are rarely subject to any kind of police enforcement because they are not CMVs. “What’s wrong with this picture?” she asked. Another complaint concerned inspection station design. She described a scale where there was insufficient distance from the scale pad to the end of the merge ramp to permit a fully loaded truck to accelerate to more than about 45 mph before entering the stream of traffic traveling about 75 mph. Although the interviewee expressed many negative views on enforcement, it wasn’t “personal.” The company is located just one kilometer from a truck scale. She knows “all the scale masters” and sometimes stops in to chat and ask questions. 18 Carrier A Description Interviewee and Job Description Biggest Safety Problems and Challenges CSA Challenges and Comments Carrier A, International TL (Truckload) Long-Haul

19 In Question 31, driver selection and hiring (a), loading/cargo securement (g), and vehicle safety equipment (h) were rated as the most important. Carrier A’s day-to-day safety practices are over- whelmingly related to vehicle maintenance and cargo securement. Regarding vehicle problems, the interviewee said that if there is “anything DOT (regulation-related), it doesn’t go down the road.” Management practices used and rated effective include driver safety bonuses (20), web-based training (21), vehicle PMs (26), detention fees (27), reimbursing tolls (28), tracking company safety statistics (29), and participating in peer meetings (30). Although the company is just three people, it does have formal procedures. For example, the interviewee keeps abreast of new safety regulations and other developments. She does this online and by purchasing safety manuals. She often makes copies of these documents for circulation among the three drivers. She also writes memos and puts them in the third driver’s pay envelope to ensure that he sees them. Because of the company’s extensive travel in the United States, it must stay apprised of both Canadian and U.S. regulations and other transport matters. The company is hiring a fourth driver, the interviewee’s son, who is himself an experienced CMV driver. It previously had a fourth driver; however, this driver left the company “by mutual agreement.” The principal performance issue related to his care of his vehicle; for example, the oil level was frequently low. A driver who does not take care of his truck’s mechanical condi- tion is not looking out for safety either. Small carrier safety management is hands-on. The manager is directly involved and personally maintains and inspects vehicles. If there is a DOT issue, everyone experiences it directly. The problem has to be fixed before the vehicle goes on the road. On the other hand, cash flow prob- lems greatly limit new investments; the focus is on essentials, not optional enhancements. Be prepared for a lot of headaches. Stay on top of safety at all times. Keep up with new safety regulations. If a vehicle develops a safety violation on the road, you must stop and fix it. Oth- erwise, keep the truck running and fix it at home to save time and money. Small carriers do not have much clout and others will take advantage of that. “Be strong and stand up for your rights,” she said. Carrier B, National TL Lease Operator Most Important Areas of Safety Management Effective Safety Management Practices Desired or Planned Enhancements Small Carrier Advantages/ Disadvantages Other Comments/ Lessons Learned Carrier B is a lease operator providing drivers and tractors to two national TL carriers. It has five trucks. It owns its trucks and employs its drivers, but operationally they work for two other companies with the DOT as the operating authority. The arrangement permits the client carriers to increase their fleet and driver counts without making capital investments. The company plans to grow to approximately 12 trucks before it acquires its own operating authority. It has one nondriver employee who does bookkeeping. The interviewee is Carrier B’s owner. He had a 25-year career as a construction manager, but left construction owing to the economy and because he tired of excessive travel and relocations. He then worked for two years as an operations manager for another trucking company. Next he developed a business plan for Carrier B and started the company two years ago. His job as owner/manager encompasses both vehicle and driver management. It does not include those operational management duties (e.g., dispatching) that are handled by its clients. On the survey questionnaire, at-risk driving behaviors (2) received the highest rating as a safety chal- lenge. Other problems rated highly included lack of basic driving skills among drivers (1), driver fatigue/drowsiness (3), driver turnover (9), loading and unloading delays (10), and nondriving injuries (11). Driver management is inherently more challenging and problematic than vehicle management. One can be entirely proactive on vehicles, but drivers can be unpredictable. Prob- lems often reflect an interaction between driver personality and their personal problems. Personal Carrier B Description Interviewee and Job Description Biggest Safety Problems and Challenges

issues include both family and financial problems. A happy driver is usually a safe driver. The interviewee believed that driver distraction owing to personal problems was often a stronger and more frequent distraction than that from cell phone use or other driving-specific distractors. Younger commercial drivers are another potential problem, especially when they have not matured enough to be career-oriented. The lowest-risk driver is one who is middle-aged, happy, and productive. In survey Question 15, Unsafe Driving (a) and Driver Fitness (c) were rated as the most chal- lenging CSA BASICs. Vehicle Maintenance (e) and Cargo Securement (f) were the least chal- lenging. He believes that CSA often punishes drivers when carriers are primarily to blame. Exam- ples include cases where there are vehicle deficiencies that a carrier should have fixed and when dispatchers “force drivers toward HOS violations and drivers pay the price.” On survey Question 31, the interviewee identified driver selection and hiring (a), driver evalua- tion (b), and vehicle maintenance (i) as the most important areas of carrier safety management. In comments, the interviewee emphasized the challenge of finding good, qualified drivers. Motor Vehicle Records (MVRs) and Pre-employment Screening Program (PSP) reports are helpful, but they must be interpreted carefully. For example, crash involvements may be not-at-fault, and roadside vehicle violations may reflect more on carrier deficiencies than on drivers. In contrast, moving violations such as speeding reflect directly on the driver. It is important that an owner/ manager ensure that every equipment item is in tip-top shape. Managers must know their equipment and address every problem, no matter how small. Three specific practices used and rated effective are driver candidate road/range tests (17), a selection questionnaire on driver attitudes and driving behaviors (18), and regular safety meet- ings (19). The company also employs a number of the other practices on the questionnaire, although the owner was less convinced of their safety effectiveness. This included the use of EOBRs (23) and charging detention fees (27). A risk of using EOBRs, the interviewee said, was that managers use the detailed data to micro-manage drivers, thus alienating them. Carrier B’s owner strives continuously to keep his drivers happy. For example, he compensates them for excessive downtime even if the company is not being compensated. “I take care of them before I take care of myself,” he said. Drivers need to be treated respectfully, as adults. They need to be empowered to make their own decisions, but they also need to be “coddled” so they do not become disgruntled. A driver who is not communicating from the road is likely to be unhappy or angry for some reason. The owner encourages them to contact him with any problem. He tells them, “Don’t get [ticked] off at anyone but me.” When drivers are on longer trips the owner sometimes checks in with their families to be sure everything is okay. The object is not to pry, but rather to keep communications open in case there is a problem. With regard to driver rewards for safety, the interviewee noted that money is not always the best motivator. Being able to drive a newer truck or one equipped with satellite radio may be a more effective motivator than an equivalent, or even larger, cash reward. The carrier has no immediate plans for changes. If the owner/manager were able to hire an assis- tant manager, that person would share safety management along with other duties. However, there are difficulties in growth. It adds layers to management and it is hard to find new managers with the same values and standards. Small carriers can invest time and attention in each driver. The owner/manager can be aware of everything going on with each driver and each vehicle and can respond immediately to concerns. The interviewee saw no major safety disadvantages to being small, although he noted that com- pany insurance costs would likely be smaller if the company were bigger. Consider the financial rewards of safety and losses from crashes. Crashes mean financial loss. Better to pass up an additional load than to create a situation where a driver is stressed out and in a hurry. Treat both your drivers and your company image like gold. CSA Challenges and Comments Most Important Areas of Safety Management Effective Safety Management Practices Desired Planned Enhancements Small Carrier Advantages/ Disadvantages Other Comments/ Lessons Learned 20

Carrier C is a regional TL carrier with six power units. It operates in a northern state that allows heavier and more productive trailers than most other states. Its tractors typically pull 8-axle “B- Trains” with a total gross vehicle weight rating of 160,000 lb, twice that of a conventional trac- tor semitrailer. Carrier C hauls steel coils in dedicated service to a steel company, and also car- ries lumber and brick products for various shippers. Most of its driver trips are less than 400 miles each way, and drivers are almost always home for weekends. The company has no full-time non- driver employees. The interviewee is the company owner and sole manager, who has owned the company for 36 years and has 42 total years in CMV operations. Other than driving, he performs virtually all company tasks including administration, personnel, sales, vehicle inspections and repairs, super- vising loading and unloading, operational management, and safety management. He could not assign a percentage to his safety-related tasks because he believed that safety management is ongoing and permeates all his work. Until about ten years ago, he managed the company while still driving part-time. He found that he could not be both a good driver and good manager once the company had three trucks. In general, he spends more time on vehicle safety than on driver safety, because of the size of his rigs (e.g., 20 brakes and 42 tires, versus 8 brakes and 18 tires for a conventional rig) and because the company has a mature and stable group of drivers. The most highly rated problems on the questionnaire included lack of basic driving skills (1), at-risk driving behaviors (2), driver fatigue (3), driver selection and hiring (6), rewarding/ disciplining drivers (8), and driver turnover (9). Because of the company’s large vehicles and loads, emphasis is placed on vehicle maintenance and cargo securement. When each truck has 42 tires and 20 brakes, much time is spent on tire and brake inspection and maintenance. Cargo securement is important both from the respect of preventing a cargo-related crash and prevent- ing driver injuries that might occur during loading and unloading. Empty backhauls are some- what of a problem because Carrier C’s specialized trailers make it difficult to book return loads. Its main dedicated service to a steel coil producer involves only one-way trips. Carrier C trucks make numerous trips to Canada and thus encounters border delays. These delays are tiring for drivers because trucks must move slowly through a queue under often-unpleasant conditions. He believed that border crossings were often poorly designed physically and that their operations could be improved. In survey Question 15, Fatigued Driving/HOS (b) and Vehicle Maintenance (e) were rated as the most challenging CSA BASICs. Alcohol/Drugs (d) and Crash History (g) were the least challeng- ing. CSA is a greatly magnified challenge for Carrier C and others pulling multi-axle trailers. Vehi- cle inspection records are based primarily on the number of violations found. Given equal mainte- nance, trucks with more brakes and more tires will incur correspondingly more violations. Because of this, Carrier C must be “obsessive” about brake and tire inspections and maintenance. The inter- viewee believed that CSA tabulations might take this factor into account. “They should compare apples to apples,” he said. Overall, the interviewee supported CSA but felt that “they haven’t fine- tuned it yet.” For example, an inspector could make a completely erroneous observation that could not later be appealed. CSA does make it easier to hire safe drivers because of the records generated on each driver. Drivers “feel the pressure” from CSA, he said. In Question 31, driver selection and hiring (a), scheduling/dispatching (e), and vehicle maintenance (i) were rated as most important. As already noted, Carrier C’s large trailers require closer inspec- tions and more maintenance than conventional trailers. Driver selection and hiring are of high importance for CMV transport in general, although Carrier C has few driver problems because of the high pay and relatively attractive work schedules it offers. When driver problems do arise, approximately half are related to personal situations, such as financial problems or “girlfriends.” Management practices used and rated effective include road/range screening tests (17), applicant questionnaire on driving behaviors (18), safety meetings (19), in-house training media (22), fuel economy monitoring (24), vehicle PMs (26), detention fees (27), reimbursing tolls (28), tracking 21 Carrier C, Regional Heavy-Load TL Carrier C Description Interviewee and Job Description Biggest Safety Problems and Challenges CSA Challenges and Comments Most Important Areas of Safety Management Effective Safety Management Practices

Carrier D has six trucks and makes short-haul runs, mostly under contract with the U.S. Postal Service. Its six trucks include one tractor–semitrailer and five straight trucks. Most trips are same-day out-and-backs to other Georgia cities such as Augusta or Macon. Apart from the owner–manager, the company has one full-time administrative employee and a part-time mechanic. The interviewee started the company 24 years ago as a driver–manager, and still drives two days a week. The rest of his time is spent on a variety of tasks, with roughly 40% of management time focused on safety. Within the time spent on safety, roughly 50% is spent on vehicle inspection and maintenance, 20% on hiring and training, 20% on evaluating and disciplining current drivers, and 10% on dealing with DOT compliance matters. company safety statistics (29), and participating in peer meetings (30). Carrier C has had no major crashes and no significant nondriving injuries. The interview attributes this to an “obses- sion” with vehicle maintenance, a mature and elite group of drivers, and to proactive opera- tional planning. Because the company carries large payloads, it is able to pay its drivers approx- imately 40% more than they would make pulling conventional trailers; thus, Carrier C can be selective. And, because of its small size and many years in the business, its owner knows his own drivers extremely well and also knows other qualified drivers available as potential hires. Drivers are home every weekend. This and good pay keeps Carrier C’s annual driver turnover rate at less than 10%. Carrier C monitors vehicle speeds using onboard computers, but does not frequently see unsafe readings. Drivers are treated as mature adults and are empowered to man- age their own time when on the road. If they feel tired, they can stop for rest. Trailer loading and unloading and cargo securement are more strenuous tasks than with conventional opera- tions; therefore, Carrier C drivers tend to be in better physical condition than seen elsewhere in the industry. The interviewee believed that Carrier C’s driver hiring standards were very high. The company is able to hire middle-aged drivers with years of experience and clean driving records. Most new dri- vers are already known to the company. Driver appearance and comportment are also important criteria. A driver with “a pony tail and his hat on backwards” would not be hired. The condition of a driver’s personal vehicle is also taken as a safety and performance indicator. In general, the interviewee believed that his current approach to safety management and safety equipment for his trucks was working and needed no major improvements. One might think that Tire Pressure Monitoring Systems would be high on Carrier C’s wish list, but they had been tried and found not to function well during the region’s cold winters. Manual checks work better. One technology of interest was trailer disc brakes because of their better reliability and an absence of brake fade. [Note: New air disc brake designs have many potential advantages over drum brakes, including less need for adjustment, more precise control and modulation by drivers, far less sus- ceptibility to brake fade as a result of heat buildup, easier maintenance, and better vehicle stability during hard stopping. Stability benefits are achieved by a more uniform distribution of braking force across multiple wheels (Knipling 2010).] Small carriers have direct contact with their drivers, vehicles, and customers. They have the oper- ational flexibility to provide superior service to their customers. The driver is “not a number” and the manager knows everything that transpires. However, to be successful, a small company must find its niche. There are no significant safety disadvantages to being small. The company’s insurance carrier has provided ample good safety assistance over the years. For example, it provides maintenance and driving training materials and a safety newsletter for employees. Carrier D, Short-Haul Dedicated Service TL 22 Desired or Planned Enhancements Small Carrier Advantages/ Disadvantages Other Comments/ Lessons Learned Carrier D Description Interviewee and Job Description

Highly rated problems on the questionnaire included a lack of basic driving skills (1), at-risk driving behaviors (2), driver fatigue (3), driver selection and hiring (6), assessing driver on-road safety (7), rewarding/disciplining drivers (8), driver turnover (9), and loading and unloading delays (10). Carrier D’s driver turnover is high; approximately two-thirds of his drivers turn over each year. Of departures, “half leave for reasons, half for cause,” the interviewee said. The most fre- quent causes are failure to follow instructions and comply with rules. A few cases have been worse; for example, larceny and intentional damage to vehicles. On a daily basis, compliance issues loom larger than noncompliance-related safety issues. Among at-risk driving behaviors, driver fatigue and speeding were mentioned as concerns. In survey Question 15, Driver Fitness (c) and Vehicle Maintenance (e) were rated as the most challenging CSA BASICs. Fatigued Driving/HOS (b) and Crash History (g) were the least challenging. DOT inspections are performed differently in different states, the interviewee believed, and states are “hungry for revenue.” Company drivers must also negotiate a crazy quilt of road and parking restrictions across six different municipalities in greater Atlanta, and others elsewhere in the state and beyond. He felt that delays and fines made it very difficult for small carriers to operate profitably. Carrier D’s principal customer, the U.S. Postal Service, also inspects its vehicles every four years, although this was not viewed as problematic. In Question 31, driver selection and hiring (a), driver evaluation (c), and vehicle maintenance (i) were rated as most important. On a daily basis, more time was spent on vehicle maintenance than on other areas, and this was driven largely by the threat of inspection violations and fines. On the survey form, vehicle PMs (26) was the only safety practice used by the company and rated as effective. In comments, the interviewee also described a driver safety and performance bonus system whereby drivers could receive a $10 daily bonus based on criteria such as no crashes or tickets, arriving on-time for work assignments, and not turning down runs. Drivers could earn up to about $200 per month in bonuses. Carrier D finds potential driver hires through the Georgia Department of Labor, which does preliminary screening for experience, job performance record, and “retention skills.” Carrier D prefers short-haul runs that bring drivers back daily or with one overnight stay. “Further away, and it is harder to make money and get back safely. The farther away from shore, the deeper the water and the more sharks.” In addition, crossing state lines means stops at weigh stations and inspections where trucks may be subject to violation citations related to state-specific inspection practices. The interviewee would like to hire a full-time mechanic who would also inspect vehicles for safety and compliance. He would like also to equip its vehicles with global positioning system (GPS) units to aid driver navigation and to provide data on vehicle speed and location. In a small company it is easier to “weed out weak drivers” and otherwise manage drivers because the manager knows them better. There is one central location and the manager sees each driver almost every day. For example, one can watch them do pre- and post-trip inspections. On the other hand, a larger company is likely to have extra vehicles so it can take them out of operational service to receive thorough maintenance. This is difficult for Carrier D because it generally must run every vehicle every day. Companies need to know a lot about DOT regulations because there is such an adversarial atmos- phere. Small businesses are being forced out of the marketplace, independently of safety. Strong financial backing is needed to overcome setbacks. “If you cannot navigate the ‘deep waters’ with DOT from the start, I would not advise going swimming.” In addition to competence in truck transport per se, company managers need a lot of administrative support and training on matters such as DOT regulations, fuel costs, and insurance. Carrier D was close to bankruptcy a few years ago when the company had only two trucks. While driving a tractor–semitrailer, the interviewee was involved in a road departure crash, which was 23 Biggest Safety Problems and Challenges CSA Challenges and Comments Most Important Areas of Safety Management Effective Safety Management Practices Desired or Planned Enhancements Small Carrier Advantages/ Disadvantages Other Comments/ Lessons Learned

Carrier E is a regional TL flatbed carrier in the Midwest. The company has nine power units and mainly hauls lumber and bales of cardboard. The company owns a repair shop and employs three mechanics. In recent years it has expanded its business to include repairs and roadside service. The owner and his son started the business nine years ago. The owner had previously been a building inspector and had never been a commercial driver. His job encompasses all aspects of management, with safety management as a principal activity. His son is the company dispatcher and also runs the repair shop. Among the biggest challenges identified on the survey questionnaire were difficulties recruit- ing and selecting good drivers (6), loading and unloading delays (10), and nondriving injuries (11). Loading/unloading delays are a problem because the company often books loads through brokers and must collect detention fees from them. Carrier compensation depends on the broker collecting the charge from the customer. Detention fees are not an effective deterrent; however, having drivers call the broker immediately upon arrival at a location helps to reduce the problem. Although the company has never lost a load off its trailers, cargo securement is an everyday con- cern in flatbed operations. Speeding is the at-risk driver behavior of greatest concern. Carrier E’s trucks are governed for top speed; however, governors do not affect driver speed choices on lower speed roads. A specific problem facing flatbed operations is that its physical requirements relating to cargo securement make it a “young man’s game.” Yet young drivers without two or more years of experience are often difficult to insure. In survey Question 15, Fatigued Driving/HOS (b) and Cargo Securement (f) were rated as the most challenging CSA BASICs. Alcohol/Drugs (d) and Crash History (g) were the least chal- lenging. The company had undergone a CSA audit and passed. The auditors identified three Car- rier E drivers flagged by CSA as deficient, but all three had already been terminated by the com- pany for safety reasons. The Carrier E owner frequently reminds his drivers to guard against getting “stupid tickets” in roadside inspections. This includes logbook violations, small vehicle violations such as missing lights, and other easily avoidable violations. The interviewee believed that federal safety rules were generally fair, but that there were “too many gray areas” in enforce- ment. Further, he believed that some inspectors acted unreasonably, as if they were “on a power trip.” Having previously been a building inspector, the interviewee was sensitive to the differ- ence between inspectors who made objective judgments and those who did not. With regard to HOS rules, the company instructs its drivers not to split sleeper berth off-duty periods because it was too easy to confuse the rules and incur a violation. Instead, it was better to stick with a stan- dard 14-hour tour-of-duty followed by ten hours off. The company does not have a crash history problem, but its owner worries that just a few crashes, even not-at-fault crashes, could raise its Crash History BASIC score to deficiency status, which has happened to other small companies. On survey Question 31, the interviewee identified driver selection and hiring (a), training and communications (b), and monitoring carrier performance measures (j) as the most important areas of carrier safety management. The key to effective driver screening is identifying specific risk indicators in applicants, such as a record of driver violations in roadside inspections. In his comments, the interviewee also emphasized the importance of loading and cargo securement (g) in flatbed operations. attributed to faulty brakes on a trailer leased from a leasing firm with responsibility for its main- tenance. The crash broke his arm in two places, but he was unable to get treatment for nearly a month owing to lack of medical insurance. He could not drive for a year following the crash. Somehow, he was able to keep the second truck running and the company barely survived. Since then, the carrier has grown to six trucks. However, company survival and growth has been a con- stant struggle, he said. Carrier E, Regional Flatbed TL 24 Carrier E Description Interviewee and Job Description Biggest Safety Problems and Challenges CSA Challenges and Comments Most Important Areas of Safety Management

Carrier F is a national TL flatbed carrier based in the Midwest. It has ten power units and carries a variety of flatbed cargo. The company has been in operation for seven years. The company owner and chief executive officer (CEO) had been a driver and manager for other companies for nearly 20 years before starting his own company. He is involved in all areas of com- pany management, including administration, accounting, personnel, sales, dispatching, and con- tracting for vehicle maintenance. He spends approximately 10% of his time specifically on safety management, in particular driver training and orientation. Three nondriver employees include a sales person, dispatcher, and bookkeeper. Highly rated problems on the questionnaire included at-risk driving behaviors (2), assessing driver on-road safety (7), rewarding/disciplining drivers (8), driver turnover (9), nondriving injuries (11), and lack of sufficient management time (12). Addressing driver problems and incidents on the road is a challenge. It is “hard to find solutions” when dealing with a problem remotely. His approach is to stay positive and try not to place blame. Driver retention is a chal- lenge, but the company is able to keep turnover below 30% by paying drivers more and “treat- ing people with respect, fairly and consistently.” A few nondriving accidents involving drivers have caused the company particular difficulty. The interviewee believed that some employees abuse workers’ compensation rights. “You couldn’t dream up some of the claims we get,” he said. The company had already received a CSA audit and had “passed easily.” In survey Question 15, Fatigued Driving/HOS (b) and Cargo Securement (f) were rated as the most challenging CSA BASICs. Alcohol/Drugs (d) and Crash History (g) were the least challenging. Cargo securement Specific management practices used and rated effective include road/range tests (17), driver bonuses for safe driving (20), use of training media in-house (22), monitoring individual driver fuel economy (24), vehicle PMs (26), reimbursing tolls (28), tracking company safety statistics (29), and participating in peer meetings (30). Carrier E has a “three strikes and you’re out” speed- ing policy. A driver’s first speeding ticket brings a warning, the second a 3-day suspension, and the third possible termination. The Carrier E owner conducts safety meetings with his drivers, but finds that short, to-the-point 5- to 10-minute meetings deliver safety messages more force- fully than longer meetings. Carrier E documents almost all of its safety policies in writing (as encouraged by the DOT), and frequently includes safety handouts or policy statements with driver paychecks. The company uses FMCSA’s Pre-Employment Screening Program (PSP) enthusias- tically. A driver can have a clean MVR with regard to moving violations, but still have a record of crashes and roadside violations as revealed by a PSP search. Only about one-third of Carrier E’s drivers turn over annually; the low rate was attributed to the fact that its drivers are home almost every weekend. If Carrier E had more resources, it would upgrade its fleet by buying newer trucks. Tire pres- sure monitoring systems were mentioned as a specific technology on its shopping list. One small carrier advantage is the flexibility to change in its runs and customers if conditions change or new opportunities emerge. Also, a small carrier can have more informal and personal customer relationships. A disadvantage is a lack of resources to purchase new trucks and safety devices. “Go the extra mile for safety because it will come back to bite you if you don’t. Do lots of train- ing. Play by the rules.” DOT rules are generally fair but some DOT officers are “on a power trip” and their decisions can put a small company out of business. Carrier F, National Flatbed TL 25 Effective Safety Management Practices Desired or Planned Enhancements Small Carrier Advantages/ Disadvantages Other Comments/ Lessons Learned Carrier F Description Interviewee and Job Description Biggest Safety Problems and Challenges CSA Challenges and Comments

“nails every flatbed carrier,” the interviewee said. He believed that inspectors were not adequately trained and that securement rules were not interpreted and enforced consistently. This is a prob- lem for cargo securement in general, but especially for flatbed cargo. HOS rules would be easier to follow if they allowed drivers more flexibility. In Question 31, driver selection and hiring (a), driver performance consequences (d), and vehi- cle maintenance (i) were rated as most important. In comments, the interviewee emphasized new driver screening. This includes driver background checks, road/range tests, and other screening practices. A mandatory 90-day provisionary period for new hires may be extended if they show marginal performance. Management practices used and rated effective include road/range screening tests (17), safety meetings (19), in-house training media (22), fuel economy monitoring (24), vehicle PMs (26), detention fees (27), and reimbursing tolls (28). As noted earlier, driver hiring was regarded as paramount. Evaluating drivers’ on-road safety is challenging, but also important. Managers need to investigate any incident reports (e.g., call-ins) and ask customers about driver behavior at their terminals. The company pays drivers a small bonus for each clean inspection. The interviewee believed that the positive recognition was a stronger motivator than the money itself. Drivers can also be docked for bad inspections. Given more time, money, and other resources, the company would like to have a designated safety manager, have its own repair shop, equip vehicles with advanced safety technologies, and purchase more management software. In a small company, the manager can know every driver and his/her strengths and limitations. In larger companies, “the driver is a number.” Most of Carrier F’s drivers have previously driven for larger companies and did not like them. The biggest disadvantage is lack of resources to invest in safety; that is, no “deep pockets.” Company safety is motivated by many different external forces, including government enforce- ment, insurance costs, and company image; yet, most importantly, safety is the “right thing to do.” Trucking is a difficult and fickle business. It is hard to keep up with everything. Carrier G, National Refrigerated TL Most Important Areas of Safety Management Effective Safety Management Practices Desired or Planned Enhancements Small Carrier Advantages/ Disadvantages Other Comments 26 Carrier G is a national TL carrier in the Midwest. The company runs 12 trucks, which are driven by owner–operators under contract. The company assists new owner–operators in financing their truck purchases while driving for the company. Refrigerated food products are its primary cargo although it also carries dry freight. In addition to its drivers, the company employs a dispatcher and accounting staff. A sister company under the same ownership pur- chases additional trucks and leases them to carriers. The company contracts out its truck maintenance. The owner/interviewee has 35 years experience in trucking. He has been a company driver, owner–operator, and a manager with a large TL carrier. He is a certified driver trainer in his state. His managerial responsibilities cover a range of tasks, with approximately 25% of his time focused on safety. Among the biggest challenges identified on the survey questionnaire were driver health and well- ness (4), driver personal problems (5), recruiting and selecting good drivers (6), correctly reward- ing and disciplining drivers (8), and driver turnover (9). Carrier G faces an added challenge in recruiting because it hires only owner–operators, most of whom purchase their trucks with the assistance of the company. Thus, Carrier G drivers must be entrepreneurial and financially responsible in addition to being safe. Only about 10% of driver inquiries become new hires, thus making driver screening a labor-intensive process. Carrier G Description Interviewee and Job Description Biggest Safety Problems and Challenges

Carrier H is a national long-haul TL carrier with 26 trucks. It hauls parts for a major auto manu- facturer in dry van trailers, and also serves other customers. Although the company runs nation- ally, more than 90% of its operations are in the Midwest. Nondriver employees include office staff, two dispatchers, mechanics, and a safety director/driver trainer. Approximately 60% of Carrier H drivers are owner–operators. The interviewee is the president and owner of the firm, which he founded eight years ago. Before that, he drove for 18 years, both as an owner–operator and company driver. Although he has many other management responsibilities, he is heavily involved in company safety. He partici- pates in applicant screening and “has the final say” on hiring. He also conducts many safety meet- ings and oversees a driver safety bonus program. His safety director trains drivers, reviews logs, and maintains compliance files, among other tasks. The interviewee had been both general man- ager and safety director until the company’s size reached 18 trucks. At that point, a separate safety director was needed. In survey Question 15, Fatigued Driving/HOS (b) and Vehicle Maintenance (e) were rated as the most challenging CSA BASICs. Unsafe Driving (a) and Crash History (g) were the least chal- lenging. The interviewee believed that “CSA intentions are good” and that the overall program is effective. However, in some respects it is overly ambitious. On survey Question 31, the interviewee identified driver training and communications (b), driver rewards and discipline (d), and vehicle PM (i) as among the most important areas of safety man- agement. In addition, the criticality of driver selection and hiring was mentioned in comments. Specific management practices used and judged effective included vehicle PMs (26), charging detention fees (27), reimbursing tolls (28), tracking company safety statistics (29), and manager participation in peer meeting (30). The interviewee believed that it is natural for drivers to want to transition to becoming owner–operators after 3 to 5 years of company driving. Carrier G’s hiring and management system was set up to foster this. Thus, Carrier G’s drivers are somewhat like business partners, rather than simply being employees. Carrier G produces a monthly com- pany newsletter directed primarily toward its drivers, with much of its content relating to safety awareness. As part of its continuing efforts to advance, Carrier G is installing tracking equipment on all its trucks. The new system permits continuous tracking of vehicle location, trip history, moving speed, idle time, fuel use, maintenance status, and other operations- and safety-related parame- ters. The interviewee noted that the company’s insurance carrier offers various safety programs to its customers, such as driver safety training programs and management software. They have yet to take full advantage of these offerings but plan to do so. Carrier G’s owner believed that his small, “family-oriented” company fosters a personal relation with drivers, and thus can have high performance and safety expectations of them. There is a two- way personal commitment. In larger companies the driver may be “a number” and there is likely to be more waste and lowered standards. He believed that his company exercised strong lever- age over its owner–operator drivers because of their contractual and personal relationship. A dif- ficulty for small carriers, and for the industry in general, is in making a profit and helping drivers to make a good living. Carriers and drivers want to be safe, but those not making a good living will tend to “run against” the clock and safety rules. Carrier G strives to closely follow mandatory and other established safety practices. It is a con- stant challenge to make trucking both productive and safe. Truck driving is a hard job and most drivers want more flexibility in how they manage their time and work. Carrier H, National Long-Haul TL 27 CSA Challenges and Comments Most Important Areas of Safety Management Effective Safety Management Practices Desired or Planned Enhancements Small Carrier Advantages/ Disadvantages Other Comments Carrier H Description Interviewee and Job Description

Highly rated problems on the questionnaire included lack of basic driving skills (1), at-risk driving behaviors (2), driver fatigue (3), and loading/unloading delays (10). The interviewee believed that driver misbehavior (e.g., tailgating and aggressive driving) was a bigger safety problem than performance failures (e.g., fatigue), although both are important. He believed that the driver fatigue problem had been made worse by current HOS sleeper berth rules limiting the shorter split-sleep period to two hours. From his own driving experience and that of his employees, he believed that 6-4 and 5-5 splits were more natural and restorative than an 8-2 split. Shippers often threaten safety by demanding tighter delivery schedules. “They can always find a carrier who will run 15 hours (rather than 14, the legal maximum),” he said. Shippers have improved in recent years but the problem is still there. Sometimes his drivers experience 6 to 8 hour loading and unloading delays. Carrier H charges (and usually collects) detention fees in such cases and com- pensates its drivers; however, such delays are still disruptive to operations and to drivers’ per- sonal lives. In survey Question 15, Fatigued Driving/HOS (b) and Crash History (g) were rated as the most challenging CSA BASICs. Alcohol/Drugs (d) and Cargo Securement (f) were the least chal- lenging. Carrier H regularly checks its CSA Safety Measurement System (SMS) scores, and the interviewee was familiar with CSA practices. He complained that traffic violation “warnings are the same as a ticket in CSA. The only difference is the fine.” The company had to fire a driver who had had three speeding warnings, but no tickets. The Crash History BASIC is a problem because it includes all crashes, regardless of preventability. Carrier H had had seven crashes, but four were nonpreventable. Two others were minor preventable crashes in which company dri- vers were not charged. One, however, was a fatal, single-vehicle crash as a result of a driver med- ical failure. The company had been subjected to a DOT audit because of the fatal crash. In Question 31, driver selection and hiring (a), driver evaluation (c), and scheduling/dispatching (e) were rated as most important. In comments, the interviewee emphasized the importance of hiring the right people and also to responding immediately to reports of driver misbehavior. Management practices used and rated effective included road/range screening tests (17), bonuses/ rewards for safety (20), web-based training programs (21), training in-house media (22), vehicle PMs (26), reimbursing tolls (28), and tracking overall company safety statistics (29). In addition to taking road/range driving tests, driver applicants must perform a pre-trip vehicle inspection as part of screening. Applicant “red flags” include anger issues, bad driving history, and frequent job changes. The company pays an outside source for driver background checks, but the process may take two weeks or more. A better system is needed, the interviewee believed. Carrier H’s vehicles are not equipped with On-board Safety Monitoring (OBSM) computers; it had used them in the past but did not continue, in part as a result of cost. Instead, it has its trucks’ engine Electronic Control Modules (ECMs) read quarterly at a truck dealership. For a fee of $50, the dealer reads the ECM and prints out a 5 to 6 page report with safety indicators such as over- speeds, hard braking events, and fuel mileage. Drivers can earn a safety bonus twice a year if they have no tickets, warnings, or vehicle damage. For every clean inspection, the driver earns a chance to win $100 in a drawing. Drivers also receive an annual $100 bonus for every year they have been with the company. Although these bonuses are not substantial in relation to overall driver earnings, they are effective motivators and contribute to company esprit de corps. Any customer or public complaints about a driver are taken “very seriously.” Although infrequent, such complaints might involve aggressive driving behaviors such as intimidation of other vehi- cles by tailgating. Carrier H has excellent safety partnerships with both its main customer and with its insurance provider. The auto company provides training videos on yard, dock, and loading safety. The insurance carrier provides videos and printed material on safe driving techniques and avoiding nondriving injuries such as slips and falls. 28 Biggest Safety Problems and Challenges CSA Challenges and Comments Most Important Areas of Safety Management Effective Safety Management Practices

Carrier I is a charter bus operation based in Pennsylvania. The company has 15 buses and 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. The interviewee was the vice president and general manager of the company. His father founded 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. Highly rated problems on the questionnaire included at-risk driving behaviors (2), driver fatigue (3), driver selection and hiring (6), assessing driver on-road safety (7), rewarding/disciplining 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 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. Carrier H does not currently use EOBRs; however, the interviewee would like to install them. He believed that they would help to reduce loading and unloading delays by making shippers real- ize that HOS rules could not be broken. He also favored an EOBR mandate to “even the playing field.” Even a small carrier has a wide array of business, operational, and safety issues to address. As a carrier grows, it inevitably must hire additional managers. Although growth provides more resources, it creates problems of its own. A small carrier manager cannot get behind on safety or on anything. He or she must always be 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. Desired or Planned Enhancements Small Carrier Advantages/ Disadvantages Other Comments/ Lessons Learned Carrier I Description Interviewee and Job Description Biggest Safety Problems and Challenges BUS COMPANIES The two bus companies represented included a charter company with 15 buses and a large transport company owning 26 smaller subsidiary bus companies. The large company, Carrier J, was included because of its manage- ment activities overseeing the operations of its 26 smaller subsidiaries. Carrier I, Bus Charter

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. Regulatory compliance was not regarded as a major challenge by the interviewee. The company 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. In Question 31, driver training and communications (b), scheduling/dispatching (e), and vehicle maintenance (i) were rated as most important. A cross-cutting priority is documentation of safety 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. Management practices used and rated effective include road/range screening tests (17), safety meetings (19), in-house training media (22), EOBRs (23), fuel economy monitoring (24), vehi- 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. As noted, the company is installing GPS devices with safety applications such as speed moni- toring. It wants to take full advantage of GPS-related safety applications. Carrier I is also devel- 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. In a small company, the manager knows everyone directly and can react by “gut instinct,” not just based on cold statistics. This is an advantage but also a disadvantage in some respects. Having more statistics based on more data would allow a manager to make more objective, data-driven decisions. 30 CSA Challenges and Comments Most Important Areas of Safety Management Effective Safety Management Practices Desired or Planned Enhancements Small Carrier Advantages/ Disadvantages

Carrier J is a passenger carrier with more than 1,000 vehicles. It is included in this study because 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. The interviewee has 48 years experience in passenger transport. Most of his career was with 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. Highly rated problems on the questionnaire included a lack of basic driving skills (1), at-risk driving behaviors (2), driver fatigue (3), driver selection and hiring (6), assessing driver on-road safety (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. In survey Question 15, the interviewee indicated five CSA BASICs of high importance: Unsafe 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. In Question 31, driver selection and hiring (a), driver training and communications (b), and driver scheduling/dispatching (e) were indicated as the most important areas of safety management. The first two of these were emphasized in interview comments. The following were indicated as effective safety practices for the company as a whole: road/ range screening tests (17), driver applicant questionnaire (18), safety meetings (19), driver safe 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 “Make sure you have good equipment inspection, listen to mechanics, and pay attention to 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) 31 Other Comments/ Lessons Learned Carrier J Description Interviewee and Job Description Biggest Safety Problems and Challenges CSA Challenges and Comments Most Important Areas of Safety Management Effective Safety Management Practices

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. Carrier J plans to become more systematic in its monitoring of subsidiary companies. This includes plans to have traveling auditors who visit each company for 7 to 10 days to monitor 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. The interviewee believes that Carrier J has achieved “the best of both worlds” in its safety man- agement. Each subsidiary deals with a smaller number of drivers and other safety factors, and thus has more direct control over them. Meanwhile, the parent company provides resources and guidance that the individual subsidiaries would not otherwise have. The interviewee believes that the safety standards it imposes on its subsidiaries consistently 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. Desired or Planned Enhancements Small Carrier Advantages/ Disadvantages Other Comments/ Lessons Learned 32