Do you have a fleet?

When you think of a fleet of vehicles, how many come to mind? Ten? A hundred?

What about the types of vehicles? Do only 18-wheelers and other large trucks make up a fleet? What about smaller trucks used by landscaping companies? How about minivans for delivering baked goods, company cars for sales reps or even golf carts?

“There’s really no number that defines what a fleet is,” said Joe Mokrisky, president of Capitol Motor Carrier Compliance in Stoughton, MA, and chair of the National Safety Council’s Transportation Safety Division. “Let’s say that a bakery company bakes bread, and they have one tractor trailer. They go out to other distributors, and they deliver that tractor-trailer load of bread every day. That’s a fleet.”

He adds: “A fleet is a fleet of anything. They’re all commercial motor vehicles if they’re used in commerce.”

Some employers may not realize they have a fleet – and that they need to follow the principles of fleet safety. They also may not know when federal or state regulations apply.

Regardless, every employer who has vehicles should take steps to improve driver safety and reduce the likelihood of injuries, lawsuits or other costly events – which affect not only the bottom line, but the organization’s reputation.

The importance of a fleet safety policy

One of the first steps is crafting a driver policy that covers safe operation of vehicles, seat belt use, and prohibited actions such as cellphone use while driving or drug/alcohol use.

In its Safe Driving Toolkit, NSC includes a sample distracted driving policy. It offers recommendations such as programming any GPS device before taking off and turning cellphones on “Do Not Disturb.”

The Society for Human Resource Management has a company vehicle use policy on its website. It says a fleet safety policy also should cover the reporting of any crashes, theft or damage – “regardless of the extent of damage or lack of injuries.”

Liberty Mutual’s Risk Control Services details some aspects that a company policy should address in a document titled, “Small fleet safety program ideas.” Download the PDF file.

Screen potential drivers

Another key step is screening drivers before they’re hired. Rose McMurray, chief transportation advisor for Franklin, TN-based FDRsafety LLC and former chief safety officer at the Federal Motor Carrier Safety Administration, said driver selection is the main component in the safety management system for all fleets.

“The driver is the most consequential part of company liability,” she said.

Screening potential employees can include background checks, reviewing driving records and ensuring driver’s licenses are valid. McMurray, also a former chair of NSC’s Transportation Safety Division, said employers should see a physical driver’s license because some states will take away a license if it’s suspended or revoked.

Even if employees are using their own vehicles for work purposes, employers still need to make sure they’re able to drive legally.

“The organization is responsible for ensuring their drivers are qualified to drive whatever vehicle they’re driving, even if it’s not owned by them,” said Ryan Pietzsch, a program technical consultant for driver safety at NSC.

Driver training and other important measures

Training is another important step, including defensive driver training (See “NSC resources” on p. 28). Employers should provide training on the specific vehicle that a worker will operate, Pietzsch said.

He added that employers need to remember to refresh workers at least annually on defensive driving concepts – and retrain if incidents or issues such as speeding occur.

McMurray noted that employers can look into technology such as telematics. The technology can record and transmit information on actions such as speeding, hard braking and rapid acceleration.

McMurray said dashboard cameras are another way to help ensure drivers are complying with safety policies and can potentially help employers in the event of a lawsuit or other dispute. The cameras can face outward to record video in case of a crash or other incident, or can record both inside and outside the vehicle.

However, telematics and cameras may come with privacy concerns from employees, so it’s important to engage with workers before installing the systems. Outline what the technologies will and won’t be used for.

When do federal motor carrier regulations apply?

In the first chapter of its Motor Carrier Safety Planner, FMCSA outlines who must comply with federal motor carrier and hazardous material regulations. Nearly all of those regulations also apply at the state level, Mokrisky said, as many states have adopted Title 49 of the Code of Federal Regulations.

The regulations governing employers and drivers can prove complicated. In general, according to FMCSA, the regs apply to “a self-propelled or towed motor vehicle used on a highway in interstate commerce to transport passengers or property when the vehicle”:

• Has a gross vehicle weight rating or gross combination weight rating, or gross vehicle weight or gross combination weight, greater than 10,000 pounds – whichever is greater.
• Is used to transport hazardous materials, which are typically materials identified under the Hazardous Materials Transportation Act of 1975 or designated as such by the transportation secretary. If so, the vehicle may need a placard.
• Is designed or used to transport nine or more passengers – including the driver – for compensation.
• Is designed or used to transport 16 or more passengers – including the driver – not for compensation.

A GVWR is the maximum amount of weight a vehicle is designed to carry, as certified by the manufacturer. That includes the weight of the vehicle and any cargo or passengers, including the driver.

A GCWR is the maximum weight a vehicle is designed to carry with any passengers or cargo and a trailer – all combined. Both ratings can be found on a vehicle’s door plate.

For GCWR, Mokrisky gave the example of a truck that weighs 4,500 pounds, which would be a nonregulated vehicle. However, if you add a load or trailer that weighs more than 6,000 pounds, that vehicle is now a regulated motor vehicle.

Hazardous material regulations can prove daunting at times as well. Mokrisky gave the example of a small recycling company that transports ballast from old lighting systems in 5-gallon pails or polychlorinated biphenyls. If that same company is carrying a 55-gallon drum of oil, hazardous material regulations would also apply.

Another example: the transport of welding gas tanks. Say a landscaping company is hauling a backhoe that has fuel in it – that applies under hazardous materials regulations. That vehicle also would require a higher insurance policy limit. A typical hazmat hauler needs a $5 million liability policy, whereas a non-hazmat transporter might have a $1 million liability policy, Mokrisky said.

Oversight of driver and fleet safety

Another set of regulations involve the need for commercial driver’s licenses, which come in three classes:

Class A: Any combination of vehicles with a GCWR or gross combination weight of more than 26,000 pounds, whichever is greater, including any towed unit(s) with a GVWR or gross vehicle weight of more than 10,000 pounds, whichever is greater.

Class B: Any single vehicle with a GVWR or gross vehicle weight of more than 26,000 pounds, or any such vehicle towing a vehicle with a GVWR or gross vehicle weight that doesn’t exceed 10,000 pounds.

Class C: Any vehicle, or combination of vehicles, that doesn’t meet the definition of Class A or B but is transporting hazardous material or is transporting 16 or more passengers, including the driver.

To navigate the regulations, McMurray recommends that employers contact their insurance company. Although every employer may not have a lawyer, she said, every organization is required to have insurance.

Most importantly, employers who have fleets of vehicles or drivers need to stay engaged in their operations, McMurray said. They can’t just delegate the role of ensuring safety to another department or an outside entity and think everything will be OK.

“You have to be vigilant about the safety condition of your fleet and your drivers,” she said.