Safety Information and Updates

Forecasts are predicting sub zero temperatures for the New England area this weekend, starting Friday night and running through Saturday. Temperatures are expected to rebound to more seasonable levels (30 degrees or so) by Sunday, but Friday/Saturday we are projected to run around -7 in the Boston area. Based on the timing of the cold, the major concerns on operability should mainly impact Saturday work, and obviously there is the potential for wider impacts in the event of power outages.

As a general reminder, the below is a helpful checklist we run through ahead of inclement weather that we find helps ensure everything goes as smoothly as possible:

General Winter Operability Checklist:

Ensure that your fleet/equipment is running an appropriate winter blended or additized product, dependent on general weather trends and your geographic location.

Ahead of both cold snaps, predicted snow, or other inclement weather, ensure generators are topped off and operational.

It’s a good idea to top off equipment/vehicle tanks, plug in as needed, and ensure lines are drained of water ahead of the freeze.

Make sure your staff has necessary equipment and weather appropriate gear so they are able to perform their jobs safely. (Don’t forget to factor wind chill in your assessment of gear – while wind chill won’t impact fuel operability, it certainly makes a difference in terms of driver/operator safety and comfort!)

In the event of predicted snowfall, ensure that fill ports are clear, marked per API specifications, and accessible. Below is a chart of the API specifications for reference:

As always, if you need assistance, don't hesitate to reach out to your representative or the office. 

Stay Safe and Warm out there!

On January 6, 2020, the Federal Motor Carrier Safety Administration (FMCSA) instituted a “clearinghouse”, or online database where information about commercial driver’s license (CDL) holder’s drug and alcohol violations are maintained. (For a refresher on the Cleaninghouse, go here: FMCSA Clearinghouse )

Despite having a secure online repository providing real-time information about CDL holder’s drug and alcohol violations, potential new employers have still been required to perform inquiries to all DOT regulated former employers where the prospective employee performed a safety sensitive function within the previous three years. Soon this will no longer be the case.

Effective January 6, 2023, the Clearinghouse will turn three years old. This means that for the first time ever, there will finally be three years of information contained in the Clearinghouse, so prospective employers will no longer be required to perform the drug and alcohol portion of the previous employer inquiry. Great news, right? Not so much. Unfortunately, while the Clearinghouse will satisfy the drug and alcohol portion of employment verifications required by 49 CFR §391.23(e), prospective employers will still be required to satisfy the requirements of 49 CFR §391.23(d) pertaining to accident information.

So what does this mean? As an employer of a new CDL driver, you will still be required to perform the previous employer inquiry to any employer the driver worked for as a CDL driver in the past three years. You won’t HAVE to inquire about their drug and alcohol history, but you will have to ask about any DOT recordable crashes they were involved in. Similarly, as a previous employer of a driver who may have left to seek employment elsewhere, you will no longer be required to provide information about the former employee’s drug and alcohol history, but you will still be required to provide answers about their recordable accident history.

While nothing prevents former or prospective employers from continuing to ask for, or continuing to provide drug and alcohol information, the only real change is that this information will no longer be required. Inquiries will still need to be made, and responses will still need to be given. The only change is to exactly what is required to be asked for, and what is required to be provided.  

IFor more information on the clearinghouse and specific requirements, check their site here: https://clearinghouse.fmcsa.dot.gov/

The FMCSA has just closed the commenting for changes they are considering in Hours of Service rules, particularly concerning breaks. The commentary period was meant to solicit opinions from drivers and transportation industry folks to see what those that the rules would affect in real life thought about the proposed changes. 

Below is a quick breakdown of some current HOS rules and how they could change under this proposal:

• Currently drivers are limited to 11 hours of driving within a 14 hour on-duty window, and then are required to take 10 consecutive hours off-duty before driving again. Additionally, they cannot drive after working more than 8 hours without an off-duty rest break of at least 30-minutes.
• Proposed changes would count 30 minutes of "non driving" time as a break, so for instance, if there was an accident, or roadwork, or traffic was horrendous and you pulled off the road, you could be on duty but not actively driving and have that be a break, versus having to go completely off duty. Another example would be 30 minutes spent loading or delivering product being counted as on-duty break time, so taking an additional 30 minute break would no longer be required.
• An additional off-duty break of at least 30 minutes (but less than 3 hours) would pause the 14 hour window (so say you stopped an hour, you would essentially "gain" an hour on the other side because of the pause, so instead of having to clock out at 3pm it would bump to 4pm, etc) but this would only be in effect if you had a 10 hour reset (consecutive) following.
• Short-haul truckers would also be allowed up to 14 hours on duty (from the current 12) and the mileage radius would expand to 150 miles (from 100). 

All of the above are meant to address some rigidity in the HOS rules as they are currently, where often road conditions, accidents, construction, or simply the timing of traffic adds up to essentially non-productive time for drivers and potentially causes people to push through versus taking breaks as needed. 

Having some flexibility in taking the 30 minute break, for example, could mean that instead of sitting in gridlock at 7am behind a major accident, you could pause 60 minutes then jump back on the road at 8am, when it cleared, without losing the hour on the other end - and without sitting at a standstill in traffic. (The fuel savings, and decreased aggravation of that option alone makes it seem appealing).

The idea with flexibility is to improve the efficiency and the experience for drivers, and allow them to make safety conscious decisions about when and how long they need to be taking breaks, without being too boxed in by HOS hard lines to get their work done. The goal being balance, where there is still rest and ample breaks, but the on-hours remain flexible enough to allow people to actually TAKE the breaks without worrying about scrambling to catch the time or distance up to hit deadlines.  

The FMCSA Clearinghouse deadline is January 6th, 2020, which believe it or not, is only a few weeks away. While CDL drivers do not technically need to register immediately, they will need to do so for mandatory employer pre-employment inquiries so it's better to just get it out of the way now.

The clearinghouse will be a comprehensive database with information on CDL holders' drug or alcohol violations, as well as information on whether that driver has completed required rehabilitation in order to return to work legally. The requirements are applied to ALL CDL drivers, from school bus drivers to interstate truckers. Violations will include any positive drug or alcohol test, DUI conviction, refusal to submit to testing, or acknowledgement of a substance abuse issue. 

Employers, medical review officers and third party administrators will be legally required to report drug or alcohol violations to the database. Employers will also be required to query the database to confirm new hires are eligible to work (no violations, or have completed required rehabilitation) and will also need to annually query to make sure current employees remain eligible to be a commercial driver. State licensing agencies (like the MA RMV) will also be required to query the system when reissuing CDL licenses. 

The goal of the database implementation is to ensure that CDL holders who have drug or alcohol violations are removed from the road until they have fulfilled steps to show they are a safe operator again.

This past summer the State of Massachusetts had an extremely tragic example of what can happen when CDL license holders are not properly vetted by licensing agencies and/or employers in regard to their drug or alcohol violations when a multiple violator killed 7 motorcyclists in New Hampshire while under the influence. Comprehensive, multi-agency efforts like the FMCSA Clearinghouse are put in place to make sure the proper checks are in place to get unsafe drivers off the road, and try to reduce the likelihood another incident like the one in New Hampshire happens again.     

The DOT has a great powerpoint presentation that runs through some of the major points regarding the Clearinghouse that you can access here: Final Rule: Commercial Driver's License Drug & Alcohol Clearinghouse

You can also access the full rule text here: Commercial Driver's Drug and Alcohol Clearinghouse

Friendly reminder that December 16th 2019 is the Federal Motor Carrier Safety Association (FMCSA) hard deadline for the Electronic Logging Device Mandate. There have been some "soft" deadlines and delays on this mandate over the last several years but there is no indication we will see another delay, so if your fleet is not fully converted to ELD, definitely get moving on that ASAP.  

We have personally been running E Logs for almost a decade, it made sense for our fleet and our footprint and we like the accuracy and uniformity of the data we get from our system. I will say there is definitely a learning curve involved in making a change over of any kind though, especially one involving software.  But this particular change actually does really make life easier in the big picture when it comes to making sure you are in HOS compliance, and in terms of pulling information for any kind of audit or certification, etc. 

Anyway - if you haven't moved your fleet to ELDs, the time is now. Don't wait til you are fined to get compliant. Good luck! 

This summer we had another successful round of our annual "Safety Jeopardy" game at Driver Safety meetings. We've discussed before how we try to cover as much relevant safety info and training as possible to all our drivers at our monthly meetings. Safety Jeopardy has the same goal, but even the Safety Department will admit it's more fun to review safety stats and info via Jeopardy. 

It's easy to lose sight of the truly monumental amount of information that drivers need to know and remember on multiple topics in order to do their jobs safely, and Jeopardy is a fun way to refresh everyone's memory with a little friendly competition. 

Looks like the team enjoyed it, based on those smiles (even Ed Burke and some Sales Reps got in on the action!)

Let's talk about something that seems easy but can easily trip up your operations if you miss something. Weight Limits.

Weight limits for trucks are governed by the Federal Highway Administration (FHA) to ensure safe weight limits for Interstate travel. In addition to this, individual States set limits for their roadways.

Compliance on these rules is pretty simple, IF you are running within a state or across a smaller group of states with similar limits. However, in regions like New England, its a lot less likely you're within one state (versus say, running trucks in Texas) and so it becomes very important to make sure you know what the rules are where, and which of your units need what permits to be in compliance. 

This is something that comes up for us a lot, as we are running trucks across several state lines, and it comes up a lot for our customers as well, partly because the states in the region are smaller, and they can have vastly different rules on weights and permitting.  So we thought it would be good to share a chart of the limits we see in the region for you to check against. There are also links to broader resources below if you are out of a different part of the country (or if youre just curious about how complicated it all gets nationwide :) )

This is the chart we use in our Safety Department. So basically if you are adding a unit in MA that will be running MA, NH, ME your process for permitting and the limits will be different than a unit running NY to CT. 

(Feel free to snag this chart for your own use, and don't hesitate to reach out if you have questions on it.)   

If you need more states or more info, this is a great reference chart by State by CargoAgents. net: Road Weight & Size Limitations .. most states rules reference the Federal Bridge formula to some extent, a breakdown of that and the accompanying detail from the DOT & Congress  is available here: Federal Bridge Weight (<-- this is a very very detailed breakdown, more than you would ever want to know, but a lot of it is helpful) 

This weekends forecast calls for snow and ice storms, particularly Saturday into Sunday for the entirety of New England. 

Because it is still early, there are HUGE variances in the amounts of snow and ice predicted, which is frustrating, but there is little doubt we will be getting hit head on by this winter's first major snow event. There is also pretty much consensus that the coast is likely to see flooding and severe icing, which is definitely something to be aware of if you are on the coast or have travel plans or work obligations in the metro Boston or Providence areas.  

We will try and keep you updated on expected impacts & developments on our social channels as the models become more predictive. 

If you're expecting a delivery, please make sure you are using fill ports that are properly coded, and make sure the pathway to the fill is cleared of snow and ice so your driver can make the delivery as quickly and safely as possible. (If you're at home, the same goes for making sure your fill pipe is accessible and there is a clear path to access).

The easier it is for your driver to deliver, the quicker he can get home and off the roads himself. 

If you run backup generators, we highly recommend ensuring they are operational and fueled up prior to the incoming storm. Several of the projected forecasts are prediction damaging ice accumulation and high winds, so it is entirely possible large numbers of New Englander's could lose power.

You definitely don't want to miss the Pats game, so make sure you and your generator are ready to go. 

In terms of general winter preparedness, ready.gov has a great overall guide, you can access it here: 

Ready.Gov - Snowstorms & Extreme Cold

Below is a refresher on the API fill port coding. 

Stay warm & safe out there & GO PATRIOTS!

For several years, we have been offering free training for Firefighters on fuel trucks. This has been a great way for them to see and get familiar with current setups and the technology involved in today's fuel trailers & straight trucks in a non-emergency situation.

Usually the training involves a Safety Director and a veteran driver, who can talk about potential hazards, the day to day work of being safe with hazmat materials, and who can answer firefighter questions about different scenarios. The firefighters always end up asking questions that make us think about how we look at some day to day safety routines as well, I always say we learn just as much, if not more, from them. 

Ed wrote an article for the December issue of Oil & Energy Magazine that goes into what we typically do for firefighter training, and why we think its so important. You can read that article here: Sharing Safety with Local Fire Departments