Electronic On-Board Recorders for CSA Audit is A-OK
During a recent conversation with a long standing trucking client I learned of a recent audit he had gone through with the federal DOT in regards to CSA. This particular client was not in an "Alert" status concerning any of the BASICS; however he had been close in the past and the DOT just wanted to make sure he was in compliance. "Just a friendly visit", they assured him.
During the visit, the DOT officer focused on the Fatigued Driving BASIC and, as expected, reviewed the motor carrier's recent logs and supporting documents. An area of concern was the miles driven vs. time noted by some of the drivers in their log books. Some drivers stated they averaged 55-65 miles per hour while the DOT officer felt that over the routes in question they could not have averaged more than 45-55 mph. Note that the average speed limit along this route is 60-65 mph with very few reasons to stop or even slow down. The motor carrier trucks are also governed at 65 mph. This adjustment in average mph put these drivers in a Critical rating on the DOT audit of these logs.
In another area, the drivers listed a particular distance less than what the DOT auditor came up with using a PC miler system and a less direct route. The PC Miler system took a route further to the east on major highways (adding distance) vs. the driver's more direct route using rural roads and highways. This also put the driver into a Critical rating status on the audit, suggesting inaccurate miles being noted on the logs.
My first thought, based on my knowledge of what mph I can average in my SUV around town was, "Could a tractor/trailer really average 50-65 mph when I typically average 35-48 mph around town?" Granted, most of my miles are city vs. rural highways; however, I am also not driving a tractor with an attached loaded trailer. That thought aside, should the motor carrier challenge the results and stand up for themselves and their drivers and what they believe to be accurate record keeping, regardless of the risk of more scrutiny by the DOT officer. Common sense suggests that if they've done nothing wrong, they should have nothing to worry about and further scrutiny shouldn't be a concern. That being said, most trucking companies I've encountered, and most businesses in general, can't do everything 100% by the book, 100% of the time. That's where the concern lies, rendering whether or not to pursue the matter and risk further scrutiny a decision that can only be made by the motor carrier.
The other matter is questioning the methods used by the DOT officer and his "ideas" of how an audit should be performed. Should a motor carrier worry about stepping on the auditor's toes? Of course not. But, the reality is that given human nature when you question someone, you run the risk of being on their radar.
I know many of you reading this have thick skin and feel as I do that fair is fair, but we're talking government here, so work with me.
My next thought was, "What if this motor carrier had EOBRs or even AOBRD devices on their tractors?"
One, the facts would come out in regard to distance traveled and actual time traveled, including operating speed over the route. Secondly, the DOT auditor really wouldn't have a case to using their own assumptions and methods of calculation; as the facts are the facts. Third, and most importantly, the driver could focus on driving and the motor carrier could worry less about the confusion and complacency that sometimes goes along with hours of service, proper logging and tracking.
Is EOBR an added expense? It is on the front end; however, from what I have seen and heard the majority of that cost can be recouped by being able to focus more on the job of trucking and focus less of dealing with the administrative hassles that come with CSA and the ever increasing demands of regulation.
If you've been using EOBRs or AOBRD devises, I am very interested to know how they are impacting your business. If you are dead set against using these devices, I would also beCSA interested in learning more about the reasons for your apprehension. We all know that we're headed toward EOBR's eventually being mandatory, so the question remains, when is the best time for your operation to implement this technology?