Safety Management in Small Motor Carriers (2012)

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65 CHAPTER FIVE CONCLUSIONS AND FURTHER RESEARCH This report has synthesized information on safety manage- ment in small motor carriers (commercial truck and bus companies) in North America. The goals of the study were to (1) identify useful practices for safety management in small companies, and (2) outline a logical and practical progression to more active and comprehensive safety management for small companies as they grow. This chapter summarizes major conclusions relating to project goals and outlines some potential areas for future research and development (R&D) on small carrier management. Small companies were defined in this study as those with more than one driver, but with too few drivers and trucks to afford to designate a manager with the primary function of “Safety Manager.” Further, these are companies where the company owner/manager drives less than 50% of the time and thus is primarily a manager. He or she performs most management and supervision tasks, including those relating to safety and compliance. The three principal information sources for this study have been (1) the project survey of small carrier owners/managers, (2) in-depth interviews with a subset of survey respondents, and (3) the research literature review. This chapter first presents a brief summary and recap of major findings from the project survey. Next, it summarizes findings from all project information sources on small carrier safety performance, safety-related small carrier strengths and advantages, and small carrier safety weaknesses and dis- advantages. Then the chapter recounts effective small carrier safety practices identified in the study. Small carriers can progress in safety by adopting more of these practices. Finally, the chapter identifies R&D needs relevant to small carrier safety. STUDY SURVEY FINDINGS The carrier owner/manager survey asked respondents ques- tions about safety problems they faced, what safety manage- ment practices they used, and the effectiveness of these practices. Chapter two presented the survey methodology and results in detail. As with most surveys, this one con- sisted of questions that were either subjective (i.e., asking for an opinion) or were asking for an objective self-report. A more important caveat relates to the sample composition. The respondent sample can be regarded as a convenience and “judgment” sample of interested, knowledgeable indi- viduals, not as a representative sample of some larger popu- lation, such as “all small carrier owners/managers.” In spite of these caveats, survey findings are revealing because of the comparative information they provide. This includes the perceived relative importance of various safety problems and perceived relative effectiveness of solutions. A total of 262 respondents (187 truck, 75 bus) completed the online survey; however, the sample reported here was reduced to 112 (79 truck, 33 bus) by Question 34, which asked about the carrier’s “functional” size in terms of man- agement. To be included in the current report, respondents had to select multiple choice answer “c,” “Company owner/ manager. Drives less than 50% of the time. Performs most management and supervision tasks, including safety and compliance.” The first set of questions (1–14) asked about the impor- tance of various small carrier safety management problems. These employed a 5-choice Likert rating scale for impor- tance. The five importance levels were assigned values of 0, 1, 2, 3, and 4 in the data analysis. All of the items received overall average ratings of greater than 2.0 on the 0–4 scale. Therefore, all of the problems were considered to be “impor- tant or greater.” The highest-rated safety problems included the following (question number in parentheses): 1. Recruiting and selecting good drivers (6). 2. At-risk driving behaviors; for example, speeding and tailgating (2). 3. Assessing driver on-road safety; that is, knowing how safe your drivers are (7). 4. Driver fatigue/drowsiness (3). 5. Correctly rewarding good driver behaviors and dis- ciplining bad behaviors (8). Problems rated relatively unimportant compared with oth- ers on the list included lack of training materials for drivers, lack of training materials for managers, and driver personal/ family/financial problems. Questions 15 and 16 presented the seven CSA Behavior Analysis and Safety Improvement Categories (BASICs). Respondents were asked to select the two areas representing the biggest and smallest safety challenges, respectively. For both trucks and buses, the top three items were Fatigued

66 Driving (HOS compliance), Unsafe Driving, and Vehicle Maintenance. Questions 17–30 presented 14 assorted carrier practices and first asked respondents to state whether or not they regu- larly used the practice (yes or no). Respondents used an aver- age of 8 of the 14 practices listed. The most frequently used were preventive maintenance (PM) schedules, providing “EZ Pass” transponders or reimbursing toll charges to drivers, tracking overall company safety statistics, and conducting road and range driving tests with driver applicants. By far the least frequent practice was purchasing advanced vehicle safety systems. Other infrequent practices were using onboard Elec- tronic Onboard Recorders (EOBRs) and having driver appli- cants complete a questionnaire on attitudes, personality, or driving behaviors. When a respondent answered “yes” regarding a safety practice, he or she was then presented with a question asking them to rate the effectiveness of the practice on a 5-choice Likert scale. Thus, only users assigned effectiveness ratings. All 14 of the practices received generally high ratings among users; the lowest rating was 2.4 on the 0–4 scale. Safety man- agement practices used by a majority of carrier respondents and receiving high favorable ratings included maintaining PM schedules, conducting road and range tests for driver applicants, and participating in peer meetings. Ironically, the three least-used practices all received high average effective- ness ratings from those who used them. These were purchas- ing advanced vehicle safety systems, use of EOBRs, and use of driver applicant questionnaire on attitudes, personality, or driving behaviors. Across the 14 practices, there was a nega- tive correlation of −0.31 between the percent of respondents using a practice and the average effectiveness value assigned to that practice by users. Perhaps the benefits of common prac- tices are taken for granted, whereas the benefits of less com- mon practices are more readily recognized and appreciated by users. Questions 31 and 32 listed ten general areas of safety man- agement. In Question 31, respondents were asked to select up to three items they considered most important; that is, having the greatest effect on carrier safety outcomes (i.e., crashes, incidents, and violations). In Question 32, they were asked to select up to three items having the least effect on carrier safety outcomes. The ten areas are listed here in their order of selection for the truck and bus subsamples combined. The choice letter is in parentheses. 1. Driver selection and hiring (a). 2. Vehicle preventive maintenance (i). 3. Driver training, orientation, and communications (e.g., safety meetings) (b). 4. Driver scheduling and dispatching practices (e). 5. Driver evaluation (i.e., violation and incident tracking, ride-alongs, covert observations of driving, onboard computer monitoring) (c). 6. Trip planning, routing, and navigation (f). 7. Monitoring carrier CSA scores and other safety per- formance measures (j). 8. Driver performance consequences; that is, rewards and discipline (d). 9. Loading, cargo securement, unloading, and dock/yard practices (g). 10. Vehicle safety equipment (e.g., technologies such as collision avoidance systems) (h). Item “g” (loading, cargo securement . . .) is much more relevant to truck operations than to bus operations. Neverthe- less, it received a relatively low rating in each: ninth for truck respondents and tenth for bus respondents (zero votes). Several final questions asked for information about respon- dents’ carriers and about themselves. Nearly two-thirds of the carriers were for-hire truckload, and these were roughly split between national and regional. Nearly one-third was charter bus operators. The mean number of carrier vehicles was 10.1, whereas the median value was 7. Most respondents had decades of experience; they had been owners/managers for an average of 17.8 years, and in the commercial motor vehicle (CMV) transport industry for an average of 24.8 years. SMALL CARRIER SAFETY PERFORMANCE, ADVANTAGES, AND DISADVANTAGES Stating generalizations about the safety performance of small carriers in relation to larger ones is problematic. An individ- ual carrier’s crash and violation rates are reflective of its own individual practices and operating environment, independent of carrier size. Federal roadside inspection data are not based on random samples; rather, inspections target higher-risk carriers of all sizes through the use of the Inspection Selec- tion System. CSA (Compliance, Safety, Accountability) crash and moving violation metrics are indexed to the number of car- rier power units, not carrier mileage. Other factors being equal, a long-haul carrier or driver will look worse on these metrics than those traveling fewer miles. In addition, the CSA Crash History metric does not distinguish between preventable and nonpreventable crashes. Given these strong caveats, it still appears likely that smaller carriers have higher frequencies of inspection viola- tions than larger carriers. Recent federal data show both driver and vehicle out-of-service (OOS) rates for carriers in the 2–19 vehicle carrier size category to be more than 50% higher than those for carriers in the 100+ vehicle category (see chapter four, Figure 5). A less recent (2001) study by Stock reviewed 13 different measures of compliance in road- side inspections for seven different carrier size categories. Consistent inverse relationships between carrier size and vio- lation frequency were seen in this study. The same study found that smaller carriers tended to be less knowledgeable and hold negative views about U.S. regulations and enforce- ment practices. As noted, these compliance studies have

67 weaknesses, and it is also not clear the extent to which small carrier compliance problems translate directly into greater crash risks. This study reviewed available statistics on these issues, but did not include resources to perform new analyses of national statistics. Any statistical study of carrier safety performance by size must control for the concept that safety performance variability is inherently inversely related to car- rier size. Smaller carriers have fewer safety data points (i.e., inspections, violations, crashes, exposure) and thus their inci- dence is more affected by chance variation. This also means that they will have proportionally more extreme outcomes. This is a statistical effect, independent of actual safety risk. Through the project survey, interviews, and literature reviews it is possible to qualitatively identify apparent safety advantages and strengths small carriers have, as well as appar- ent disadvantages and weaknesses. The safety advantages and strengths of small carriers over larger ones include the following: 1. Direct manager contact with drivers and vehicles. Most small carrier owner/managers personally select their drivers and typically are in direct daily contact. They usually have insight into how well drivers are performing and the problems they might be facing. Similarly, most small company managers know every- thing about their vehicles. They often perform vehicle maintenance and vehicle inspection tasks themselves, or oversee this work directly. There are no layers in their management structures. 2. Narrower span of control. Carriers in this study had an average of ten vehicles and a similar number of drivers. This is a narrower span of control than would be found in a larger fleet, permitting greater individual attention to drivers and vehicles. 3. Greater personal involvement in company and work. Both managers’ and employees’ sense of per- sonal involvement and their work satisfaction are gen- erally greater in small companies and work units than in larger companies and work units. 4. Lower turnover. With few exceptions, driver turnover rates are inversely related to company size (see chapter four, “Retention”). Retention and safety are positively related for multiple reasons; one tends to foster the other. 5. Experienced managers and drivers. The average survey respondent in this study had 25 years of experi- ence in the industry and 18 years as an owner/manager. Lower driver turnover in small companies means that many drivers are experienced. Many small carriers are family businesses; their owners and drivers may have grown up around trucks and buses. 6. Niche orientation. Many successful small companies fill a specific market niche, which gives their managers and workers greater knowledge and experience in their specialization area. They can better anticipate hazards within these unique environments. 7. Lower productivity pressures in some companies. Some small company owners, especially those satis- fied with their existing market niche, may be less inter- ested in high productivity and company expansion than in maintaining a steady-state operation. For these companies, work pressure may be less than in larger companies (see chapter four, “Driver Hiring”). 8. Vehicle maintenance orientation. Motor carriers of all sizes appear to recognize the importance of vehicle maintenance and consider it the foundation of safety. This was seen in the current survey and has been seen also in past CTBSSP Synthesis reports. Company pride in vehicle maintenance may not be a small company advantage over larger companies (indeed, the findings cited suggest otherwise), but it is a strength to build on. 9. Recognition of the importance of driver selection. The earlier statement on vehicle maintenance applies to driver selection and hiring as well. Carriers of all sizes recognize the paramount importance of hiring the right drivers. The safety disadvantages and weaknesses of small carri- ers relative to larger ones include the following: 1. Management spread thin. Small carrier managers must fulfill many different roles while responding to constant demands. A risk is that they become spread too thin and are continually occupied addressing immediate concerns rather than thinking and acting proactively. 2. Weak business skills. Across all types of businesses, small company owners are often experts in their oper- ational work tasks but unprepared for the rigors of business and financial management. 3. Nonanalytic management. Many small company owners have flexible personalities; they are infor- mal, confident, assertive, and adventurous (see chapter four, “Operational Management and Supervision”). These traits may lead to success; however, a downside is that flexible personalities often lack thorough analy- sis in their decision making; rather, they tend to act on intuition. 4. Weak documentation. Small companies tend to be less systematic and thorough in documenting their policies, administrative procedures, financial dealings, operational records, etc. For motor carriers, this may leave them more open to vulnerability to enforcement actions and tort liability. 5. Unsystematic hiring for “personal fit.” Small com- panies recognize the importance of driver selection, but they are more likely to hire new employees unsystem- atically and with fewer formalized steps than are larger companies (see chapter four, “Driver Hiring”). Hiring emphasis is often on “interpersonal fit” rather than on an objective breakdown of job tasks, requirements, and applicant qualifications. Small companies are also more likely to conduct “closed searches” for new employees rather than recruiting widely. Barrett et al.

68 found that having open, formalized, well-documented hiring procedures helped small companies to hire better workers. 6. Less time spent on driver training. Small carriers tend to devote less time to both initial and ongoing driver training than do larger carriers. This is also true of safety meetings with drivers. A reason for this may be that small company managers know their drivers better and have more confidence in their abilities. 7. Less management development. In general, small companies are less likely to engage in management training and development than are larger firms. This includes both in-house training and training from out- side sources. The survey item, “Lack of training materi- als (or easy access to them) for yourself as a manager” received one of the lowest average safety importance ratings of those presented. It appears that the relative lack of management development in small carriers is related both to lack of resources and lack of perceived need. 8. Less computer literacy. This study did not directly address computer literacy; however, one indicator was the relatively low proportion of small carrier respon- dents (35 of 111) who used online training programs. This suggests a lower familiarity with online resources than would likely be found in larger companies. 9. Less use of Onboard Safety Monitoring (OBSM). As discussed in chapter four, “Driver Valuation,” OBSM is probably the most powerful form of driver observation and evaluation. Small carriers use OBSM less than larger companies. 10. Nonuse of crash avoidance technologies. Two differ- ent questions on the project survey indicated that very few small carrier respondents purchase advanced crash avoidance devices and that they do not appreciate their potential safety and business value. 11. Less use of internal “leading indicators” of safety. CSA’s Safety Measurement System has gotten the attention of the entire CMV industry. Small carriers in this study do pay close attention to CSA metrics for both their drivers and their companies as a whole. However, use of internal “leading indicators” appears to be less common, extensive, and sophisticated in smaller companies than in larger ones. 12. Less operational planning to reduce risk. As was discussed in chapter four, motor carriers can reduce their crash risks considerably through better opera- tional planning. Risk avoidance strategies include reducing empty (“deadhead”) trips, minimizing load- ing and unloading and related delays, maximizing travel on Interstates, avoiding urban traffic, avoiding work zones, optimizing travel times, use of higher pro- ductivity vehicles, and team driving. Project survey responses and interviews suggest that small carrier managers do not fully perceive the value of these strate- gies. They do appreciate the increased risks caused by loading and unloading delays, but have less leverage to reduce the problem with their customers than do larger companies. 13. Limited financial resources. Many of the earlier- cited disadvantages and weaknesses are related to small carriers’ tight profit margins and uncertain cash flows. They are generally much less able to make pro- active safety investments (e.g., new vehicles, onboard technologies, and training) than are larger companies. 14. More likely to be new entrants. One reason for greater safety challenges in small companies is that they are more likely to be young companies without years of experience and lessons learned. New entrants have higher violation and crash rates than more experi- enced carriers. FMCSA has initiated a major program to improve new entrant performance. IMPROVING SMALL CARRIER SAFETY MANAGEMENT The project survey (chapter two), case studies (chapter three), and evidence review (chapter four) suggest many effective safety management practices for small carriers and their owners/managers. A company’s progression toward more comprehensive safety management is likely to include adop- tion of multiple new practices such as those described here. Many small companies already do many of these things, as evidenced by the current survey findings. Furthermore, the value of these practices is not limited to small companies. Given that, it is small carriers that need to assess their current practices and consider possible changes in these areas: 1. Business plan and attention to business needs. Com- panies should have a business plan, ensure that pricing is adequate to sustain the business, and pay close atten- tion to the business aspects of company management. This includes legal issues, licensing, facilities, purchas- ing and leasing contracts, costing of services, assessing and dealing with competition, advertising, loans and other financing, record keeping, taxes, cash flow, con- tracts, creating a website, and other areas not directly related to CMV transport. 2. Record keeping. Companies benefit from maintain- ing up-to-date and detailed operational, safety, admin- istrative, and financial records. 3. Development of business management competen- cies. The typical small business owner starts as an expert worker, but must transform himself or herself to become a business person and manager. Business management competencies are needed to complement CMV transport competencies. 4. Self-insight into management style. It is important that owners/managers recognize their management styles and personalities and, based on this insight, antic- ipate positive and negative implications for company success. 5. Build on small company strengths. The previous section articulated a number of the potential safety

69 advantages small companies can have over larger companies. These include direct management contact with drivers and vehicles, closer personal relation- ships within the company, and lower driver turnover. Small companies need to work to retain these small company values while incorporating the more pro- active and systematic practices of larger companies. 6. Systematic management. As discussed in chapter four, “Business Operational and Safety Management in Small Companies” (for companies in general) and in “Business Management” (for transport companies), a carrier needs to conceptualize and develop its own top- down safety management system. The system might set out a company’s safety policies, define how it iden- tifies safety hazards and controls risks, and provide for goal setting, planning, and measuring performance. A company’s top-level safety system concept needs to devolve downward to all company employees. Four different systematic approaches to safety man- agement were described in the section on Business Management, and others were discussed earlier in chapter four. Two particularly useful concepts, in the authors’ opinion, are Glendon and Stanton’s safety monitoring approach (see Figure 13) and Mooren’s 12-element model of company fleet safety described in chapter four. 7. Occupational Safety and Health Administration (OSHA’s) four key elements. By implementing OSHA’s Four Key Elements of Company Occupa- tional Safety and Health Programs (chapter four, “Safety Management”), companies would ensure the following a. Management commitment and employee involve- ment in safety. b. Worksite analysis to identify hazards. c. Hazard prevention and control; for example, estab- lished and enforced procedures. d. Safety training for drivers and other employees. 8. Safety culture. Companies need to develop their own safety cultures; that is, shared values and beliefs establishing safety as a priority. 9. Consider onboard safety technologies. Although few small companies purchase such devices, the safety and business benefits of onboard technologies such as Electronic Stability Control, Forward Collision Warn- ing, and Lane Departure Warning are well-established. At a minimum, small carriers would learn how to obtain engine Electronic Control Module (ECM) readouts to help assess driver behavior patterns. 10. Recognition of compliance challenges. Although there may be many imperfections in government reg- ulations and enforcement practices, small companies need to recognize the compliance challenges they face and seek to excel in roadside inspections and other compliance areas relative to their peers. 11. PM schedules and software. The practice of main- taining PM schedules and records for each vehicle is well-established. This may be aided by the use of com- mercial maintenance management software. 12. Operational and trip planning. Pre-trip, managers and drivers should schedule trips to avoid high-traffic times and excessive driving during circadian low peri- ods (e.g., 3:00 a.m. to 6:00 a.m.). Once on the road, pre-crash threat avoidance includes route selection to avoid undivided highways, traffic congestion, and work zones. 13. Detention fees for loading and unloading delays. Even though small carriers have less leverage in deal- ing with their customers, they could negotiate deten- tion fees as part of their contracts, and enforce them assertively. 14. Use EZ Pass or reimburse toll charges. Drivers who choose to drive on a lower-capacity roadway to avoid paying tolls are usually greatly increasing their crash risks. For both time savings and safety, toll roads are preferable. Carriers need to make it easy for drivers to use toll roads. 15. “Cradle-to-grave” Human Resource Management (HRM). Driver and other employee HRM is critical for any motor carrier. Cradle-to-grave HRM encom- passes best practices in employee recruiting, selec- tion, hiring, orientation, training, supervision, evalua- tion, retention, and termination. These practices may be even more important for small companies because they can potentially retain their drivers longer. 16. More formalized driver selection. Survey respon- dents identified driver selection and hiring as the most important safety management area, and much other research supports that opinion. Chapter four, “Driver Hiring,” presented a number of effective driver hiring practices, based in part on CTBSSP Synthesis 21. Small carriers can improve driver selection by using more test and measurement tools (e.g., adding a driver question- naire) and making a conscious effort to hire based on objective criteria rather than primarily “interpersonal fit.” One study found that small companies that for- malized their HRM processes (e.g., by documenting job tasks, knowledge, skills, and attitude, and mini- mum employee qualifications) were more successful in finding better employees than those that did not. 17. Expanded driver training content. Small carriers might consider expanding their training of new and experienced drivers to include additional topics, such as those identified in CTBSSP Synthesis 5 and the section on Driver Orientation, Training, and Communications in chapter four of this report. 18. Embrace e-learning. Computer-based and web-based training offers numerous advantages over conventional classroom instruction. Ease of access is the most notable advantage; however, e-learning also appears to result in better and faster learning for many topics. In many ways it is ideally suited for small carriers with limited resources. Small carriers need to seek out and take full advantage of e-learning offerings.

70 Motorcoach Association. Participants meet several times annually to discuss all aspects of carrier opera- tions and safety. Carriers within each group are selected so as to be geographically dispersed and not in direct competition with each other. Almost any carrier would benefit from this kind of peer information and idea exchange. 27. Growth and metamorphosis. Table 17 in chapter four presented five stages of business development. The growth of a business involves dramatic personal and organizational transformations. A manager’s role of providing direct supervision is gradually replaced by a role of delegating, coordinating, oversight, and strategic planning. Broadly, it is important that small carriers try to sustain and reinforce their advantages while also adopting the more sys- tematic safety management approaches often seen in larger companies. This report has frequently cited findings from the I-95 Corridor Coalition Coordinated Safety Management Study, which compared carrier safety practices and outcomes by carrier size. Across almost all measures, Stock found that larger fleets generally had more active and systematic approaches to safety. They also achieve better roadside inspec- tion outcomes. Stock concluded that government inspections and enforcement “should focus on smaller fleets.” Just as sig- nificantly, he concluded that the “safety management practices of larger fleets adjusted for [the] operational constraints of smaller fleets could provide effective ‘best practices’ models” for small carriers. These 27 effective practices were identified based on the current survey, interviews, and literature review. The textbox presents abridged recommendations for U.K. transport com- panies from a similar study by the U.K. Department for Transport. Many of the suggested practices are the same as those suggested earlier. “Recommendations for Companies” by the U.K. Department for Transport (2000) • Training/Recruitment – Ensure thorough driver assessment during recruitment. – Carry out a risk assessment on new employees (e.g., a hazard perception test). – Set a ‘qualifying period’ for less-experienced drivers. – Integrate corporate safety messages and driving pro- fessionalism into training. – Establish and maintain a continuous driver training system. – Use in-cab computers to provide feedback and incor- porate this feedback into training. – Teach self-management to drivers. – Include the following in driver training: emergency situations, maintenance, freeway driving, traffic laws, defensive driving, hazard awareness, and equipment knowledge. 19. Driver evaluation and feedback. Feedback (knowl- edge of results) facilitates performance, but feedback must be based on accurate and timely performance measurements. Small carriers could seek to develop multiple measures of driver safety performance to com- plement those provided by the CSA BASICs. 20. Consider OBSM. Although OBSM technology is beyond the immediate reach of many small carriers, those with the capability might consider using it. As discussed in chapter four, OBSM is potentially the most powerful form of driver evaluation because it direct measures behavior. 21. Safety rewards program. Rewards and punishments are an extension of feedback. The most effective carrier programs appear to be those based on Behavior-Based Safety (BBS). BBS emphasizes timely observations of behavior, goal-setting, rewards and recognition for success, and correction of any hazardous situations identified. Group involvement is important to the process. Rewards can be tangible but not be of such high value that they become a source of contention. Rather, they are primarily social reinforcers and might be designed to strengthen group norm-setting and cohesion. 22. Driver retention. Driver retention is a strength in many small carriers. Positive and supportive personal relationships between managers and drivers appear to be a key to good retention in small companies. Driver pay is also a factor, especially for older drivers with marketable driving records and job skills. 23. Crash documentation and investigation. Crashes are rare events, especially for small carriers with just a few vehicles. Proactive carriers have established, prescribed response practices following a crash or incident. Drivers need to be instructed on procedures and provided with crash reporting forms. Insurance companies often provide assistance in this area. 24. Regular safety measurement and monitoring. By regularly monitoring and measuring safety, companies can better understand their sources of risk, respond to them, and continually improve. Comparisons with other companies provide both performance bench- marks and ideas for innovation. The CSA BASICs provide such measurements, but these could be supple- mented with internal measures, especially measures of driver behavior. 25. Development of safety management competencies. Small companies are less likely to engage in manage- ment training and development than are larger firms. Through training and professional contacts with peers, small carrier managers can develop their supervisory skills and increase their knowledge of specific safety- related topics. 26. Participation in carrier peer consortia. Case study Carrier I (see chapter three) is a charter bus operator with 15 vehicles. Its manager participates in an idea- sharing carrier consortium organized by the United

71 RESEARCH AND DEVELOPMENT NEEDS Our knowledge of small carrier safety would benefit from additional research. In many cases, this research would seek to validate tentative findings from cited research, but with more rigorous methods. Development efforts could focus on new training programs, software applications, and other aids to small carriers. Suggested R&D includes the following: 1. More representative study samples. This report, pre- vious CTBSSP reports, and other oft-cited studies of carrier safety management have been based primar- ily on successful, safer-than-average carriers. Such carriers are more likely to be active in national CMV transport organizations and conferences, and thus more likely to be reached by researchers. Carrier sam- ples generated through probability-based sampling methods would require greater resources, but would reveal more about the practices of the industry as a whole. Further, such studies could be structured as case-control or parametric comparisons between car- rier practices and their safety performance criterion measures. This would reveal more cause-and-effect relationships. 2. Intervention case studies. This study’s case studies provided snapshots of ten motor carriers and probed the views of their owners/managers. However, none involved the experimental application of new safety management interventions. The previous section iden- tified 27 reported effective safety practices for small carriers. Many of these could be structured as direct interventions and evaluated in small carrier case stud- ies. These could be smaller-scale versions of an inten- sive carrier case study by Murray et al. in 2009 involv- ing Wolseley, a large U.K.-based heating and plumbing distributor. This comprehensive case study classified dozens of company safety interventions that together reduced the Wolseley crash rate by more than 40% over four years. Ideally, intervention case studies would be structured to follow one or more of the systematic, top- down approaches to safety management reviewed in this report. 3. Driver selection tool validation in small carrier set- tings. CTBSSP Synthesis 21 reviewed driver selection methods of commercial truck and bus companies. Driver selection relies on tests, measurements, and other assessments of applicants. Testable, safety-rele- vant driver traits include personality, attitudes, psy- chomotor performance, medical status and conditions, behavioral history, and mental abilities. CTBSSP Syn- thesis 21 cites studies of these factors and tests to assess them, but noted that little data had been collected on commercial drivers. Few studies provided the valida- tion evidence needed to legally and ethically justify the use of a test for hiring commercial drivers. Only larger fleets with more sophisticated HRM departments are likely to conduct test validations. Test validation stud- ies with small carriers would need to aggregate data from multiple carriers to be statistically significant. Such studies, followed by educational outreach to the industry on how to use them, would help improve driver selection in small carriers. 4. Filtering for crash preventability in CSA Crash History BASIC. One small carrier saw its CSA Crash History indicator jump from 0% to 44% as a conse- quence of two nonpreventable crashes. In one crash its truck was rear-ended, whereas in the other its stopped truck was struck by a red light runner. A company safety audit by FMCSA would be necessary for the crashes to be removed from its CSA record. FMCSA • Procedures – Set driving safety standards with associated proce- dures and review them periodically. – Run formal risk assessments based on accident tracking. – Clearly lay out insurance policies, accident procedures, etc. – Set specific driver guidelines around trip times, trip lengths, etc. – Set a strict cell phone use policy in accordance with the law. – Conduct regular safety checks and audits. • Planning – Match drivers to journeys based on a driver’s experi- ence, safety history, training, etc. – Involve the drivers in planning optimal routes and sequencing. – Build breaks, peak traffic times, and local routes into schedules. – Plan routes in advance; avoid busy routes when possible. – Ensure sufficient time in yard for safety checks. – Balance driver hours for even workloads. – Stay away from ‘strict timed routing’ to avoid added pressure on drivers. • Incident Management/Feedback – Educate employees about the value of sharing incident/ accident information. – Provide guidance and encourage incident reporting without blame. – Be willing to learn from accidents, incidents, and near misses. – Emphasize what could be done differently in the future, not what went wrong. • Safety Communications – Talk to an employee directly about a problem, do not communicate through others. – Communicate information on external hazards such as weather, roadwork, etc. – Focus on driving risk factors; for example, speeding, tailgating, need for breaks, and seatbelts. – Put out a newsletter 3 to 4 times per year to update everyone on company safety. – Be approachable to talk about safety and act on good suggestions.

72 and CSA recognize the need for an analytic filter that would keep clearly nonpreventable crashes from con- founding company CSA scores. An effort is underway by FMCSA to develop such a capability. This would be especially beneficial to small carriers because they are more vulnerable to large score shifts based on a small number of crashes. 5. Control for regression to the mean in Compli- ance Reviews. Two studies of pre-CSA Compliance Reviews have reported dramatic carrier size differ- ences in post-review safety outcome changes. Consis- tently, the magnitude of post-review safety improve- ments varied inversely with carrier size, suggesting that small carriers are more responsive to these audits. However, the same effect could be the result of regres- sion to the mean, and the two studies did not appear to adequately control for that. Similar studies under the new CSA regimen and with adequate controls could determine the degree to which this suggested safety improvement effect is “real.” More broadly, the effort could address the degree to which CSA and other safety measurements are reliable for small carriers. In a 2011 report, U.S. General Accountability Office (GAO) pointed out that a significant majority of small carriers have insufficient BASIC compliance data to be ranked under the CSA Safety Measurement System. 6. Aid to small carriers in reducing detention delays. The GAO recently reported that, in a survey, 68% of surveyed drivers had experienced excessive loading and unloading delays in the past month, and that 80% of these drivers reported that the delays affected their ability to meet HOS requirements. The report found that small carrier drivers are more vulnerable to such delays because their companies have less market strength to demand customer compliance with load- ing and unloading provisions of shipping contracts. A 2011 analysis by Miao et al. estimated the true cost of delay to be $80 to $121 per hour for truck drivers and their carriers. A typical detention charge is $50 per hour, with drivers receiving half of that. Small carriers need assistance in dealing with this source of finan- cial loss and safety risk. One way would be to publish a detailed guide on how carriers can successfully pre- vent detention delays and receive proper compensa- tion when they are delayed. 7. Technology demonstrations in small carriers. Vehi- cle safety equipment was seen by survey respondents as the least important of ten safety management areas, and only four of 111 survey respondents regularly pur- chased such devices. However, advanced safety tech- nologies can dramatically reduce crashes. Technology transfer studies could investigate the reasons behind small carriers’ resistance to safety technologies and ways to overcome it. Factors examined might include initial costs, returns on investment, effectiveness, sys- tem reliability and maintainability, driver acceptance, management use of system data, and potential liability concerns. Field operational tests conducted with groups of small carriers (as opposed to single large carriers) could demonstrate technology practicality and effec- tiveness. These tests could showcase both the direct crash prevention and OBSM features of safety tech- nologies. An entry-level OBSM approach for small carriers is to take their vehicles to a dealership where they can obtain downloads of driving data from engine ECMs. A demonstration study might familiarize small carriers with this low-cost approach, provide training on how to read and use the data, and provide bench- marking statistics to improve driver safety assessments based on ECM data. 8. Open-access benchmarking tool. Small carriers would benefit from a low-cost (or free), open-access safety management benchmarking database. The data- base would consist of lists of specific safety manage- ment practices and internal leading indicators of safety (see chapter four, “Carrier Performance Track- ing and Benchmarking”). Carriers could enter their own data into the database and receive feedback on how their practices compare with those of peer com- panies. Confidentiality would be essential. The I-95 Corridor Coalition Coordinated Safety Management Study developed an interactive, web-based “Safety Toolbox” to provide such benchmarking; however, it is no longer active. 9. Web-based management training for small carriers. Small company managers are less likely to seek profes- sional training and development than those in larger firms. This reticence is the result of a lack of time, money, and recognition of potential benefits. If well- designed and promoted, low-cost, web-based training for managers could improve small carrier business viability and safety outcomes. Successful web-based training for managers might result in greater use of web-based driver training in small companies as well. 10. Wellness programs for small carrier drivers. This study did not explore driver health and wellness issues in depth, and driver health was not considered by small carrier survey respondents to be a top safety prob- lem. Nevertheless, prevailing evidence suggests that unhealthy lifestyles and associated medical conditions are significantly more common for CMV drivers than for the rest of the U.S. adult population. Many larger, progressive companies have initiated driver wellness programs; however, they are less common among smaller companies. Small carriers would benefit from assistance in this area.