Letter to the Editor: Proper Documents

Deborah E. Roland

I>Vice President

rans Products and Services

I agree with Robert S. Abbott’s perspective on the Department of Transportation’s safety compliance review process (Opinion: “The Problem With Safety Ratings,” 7-30, p. 9). His statement, “the relationship between compliance and safety is neither clear nor direct,” succinctly pointed to the problems with compliance reviews.

I further agree with Mr. Abbott’s contention that safety should be checked through performance. Compliance with the regulations is one issue; safe operations is another. As exemplified by Mr. Abbott, and as I’ve seen in my consulting work, a carrier having its paperwork in order does not necessarily equate to safe operations.

I do feel the DOT has moved in the right direction by using performance as a basis for determining who should be audited. Yet the system still has its flaws, best demonstrated by the accident factor. A true measurement of a carrier’s safety performance is its accident rate. However, this factor is not a true reflection because it counts accidents meeting the criteria in Part 390.5 against the carrier regardless of fault.

In the article following Mr. Abbott’s opinion, “Government’s Carrier Safety Database Is Prone to Inconsistencies, Misuse by Public, Critics Claim” (7-30, p. 12), I feel FMCSA’s Bonnie Bass is naïve in thinking the audit process is straightforwardly objective. Paul O’Neill said it perfectly: “ . . . investigators do it differently, even within the same offices.”

I have witnessed this subjectivity of investigators firsthand. I assisted a carrier where two investigators were performing a compliance review. The seasoned investigator leaned toward the lenient side of the regulations while the inexperienced investigator was throwing the book at the carrier.

Through the training I give my clients, I stress that DOT is out to prove “safety” through paperwork. I explain that many of the documentation issues that I cover seem ridiculous. I also explain that proper documentation seems to have nothing to do with stopping accidents and operating more safely, but in order to prove compliance and get a satisfactory rating, the carriers have to have the “i’s” dotted and the “t’s” crossed.

I have the same question Mr. Abbot asked: “Why not align perception with reality and start measuring how safe fleets really are?"

This letter appears in the Aug. 27 print edition of Transport Topics. Subscribe today.

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