Question #1: “I need your advice please. Currently our company has 133 CDL drivers between 11 locations and we plan to add more soon. At what point would a company need a full time DOT Coordinator in your opinion?”
Answer #1 from Tom Flaten – VP Field Operations: Great question! While there are several variables to consider, fleet size is commonly a determining factor as to staffing levels. A lot also depends on whether the position also includes responsibility for any legalization, HR or operational duties. Here are some rules of thumb regarding “who handles fleet compliance matters”;
- 1 – 5 units; usually the Driver manager is capable of keeping up with day-to-day regulatory matters.
- 6 – 10 units; the Driver manager begins to have a handful and the balancing act with daily operational matters gets more difficult.
- 11 – 25 units; the Driver manager probably needs a full-time “support” person to oversee compliance.
- 26 – 50 units; a full-time Safety manager qualified to handle not only compliance, but also driver training, coaching, accident administration, etc.
- 51 – 100 units; the Safety manager will begin to need support of additional staff and technology.
- 101 – 500 units; Fully staffed Safety Department.
- 500+ units; At this stage, multi-location safety administration is likely in place.
It is important to note that, throughout the organization, safety and compliance never be considered as a job belonging to a single person, or department. Nor should safety be viewed as a “priority” or an “expense”. Safety should be viewed as a core value, stated as such in the company’s mission statement, and woven throughout the organizational fabric. Everyone should understand their individual safety responsibility and accountability. The Safety Department then becomes the “Revenue Retention Department” when considering the true cost of a collision. Comprehension of the impact on the organization makes it much easier to understand why investing in safety is a sound business decision.
Question #2: “Does Thorn Valley Safety have a video for reasonable suspicious training?”
Answer #2 from Tom Flaten – VP Field Operations: Thorn Valley does not have a video, but we do have free resources to easily satisfy the regulatory requirements of 382.603 (Supervisor training) as well as 382.601 (CDL Driver training).
To meet the Supervisor regulatory requirement, the CDL supervisor must devote a minimum of 1 hour of learning about the signs & symptoms of Alcohol misuse, and 1 more hour on signs & symptoms of Illegal Substance abuse. 382.603 is silent on how the learning is to be acquired. That said, if video format is used, the learner would have to watch at minimum a 2-hour length video. While we don’t have that resource on our website, we have links to download other (free) resources;
- Implementation Guidelines for Alcohol and Drug Regulations in Highway Transportation
- Employer D&A Handbook
- Employee D&A Handbook
As long as the CDL Supervisor sets aside 2 hours to review these materials, they can “self-certify” (sign a statement that says they’ve done so), indicate time/date, name, etc. and they are compliant. It would be a best practice to have a “witness” (proctor, etc.) sign off as well, and keep copies of the materials reviewed on file.
Please note that fleets that employ CDL drivers are also required to “Promulgate the D&A regulations” which most fleets satisfy by ordering D&A handbooks from JJ Keller or their D&A program administrator, giving to the drivers to sign page 1, tear out and put in the driver file. If they don’t want to pay anything, they can just download the 3rd file link above, print it (or deliver electronically) and give it to the CDL drivers, have them acknowledge (either sign receipt, or if emailed, flag the email for deliver/read receipt). The key is staying compliant;
- Supervisor – minimum 2 hours, and
- document to file.
- CDL Drivers – issue the Employee D&A handbook, and
- document to file.
Oh yes, and one other thing – encourage all to drive safely!