Tips From a Safety Sleuth

Phil Slater and his staff are auditors that truck operators actually want to have knock on their door. “Companies hire us to take them through a dry run-to shine a light on what they’re doing wrong before the real thing happens,” says Slater, president of Slater Safety Systems in Brampton, Ont. (905/455-1006; www.slatersystems.com). “Once we know where they stand, we can create a strategy to help them manage their compliance in the future. Enforcement agencies like to see that a company is taking steps to improve.”

Here Slater offers four tips to help you survive a facility audit.

Learn the Rules: The guiding principles of the audit process are the same across Canada (and in the United States, for that matter). Most are based on National Safety Code Standards 14 and 15, which cover safety ratings and compliance reviews.

But each jurisdiction has specific requirements, and the specifics can be tough to find and daunting to read. “Most provinces do publish guides to facility audits, but many carriers don’t know they’re in print,” Slater says. In his consulting business, Slater often works with companies who question whether it’s not worth the money or trouble to learn the regs-until they’re audited and face a deadline to fix their problems.

Your Own Policies Count: Auditors will judge how well you follow the rules-and also how well you comply with your own company policies. “Let’s talk about maintenance intervals,” Slater says. “Say your company policy says you do A-level vehicle checks every 10,000 kilometres or once a month. But it’s not always feasible to get your trucks in. Say you go 10,100 km on a vehicle. Now the auditor has the opportunity to charge you on that.”

It’s your job to make sure your policies reflect the realities of your operation.

“Look at TACC, a construction company that turns relatively few miles and more accurately gauges its maintenance intervals on the number of hours the vehicle operates,” Slater says. “How does a government agency compare a construction company’s maintenance intervals to those of a highway outfit running Toronto-California? It can’t. So it leaves that section of the law open to the interpretation of the carrier.”

The simple thing to do is to find your longest timeframe between inspections, and if it’s reasonable, structure your policy to reflect it.

Look Out for Your Best Interests: The review process includes the opportunity to appeal the findings, or the amount of a fine.

Pay attention to what the investigator is doing, taking notes in case you need to document a complaint. Remember, the auditor is making judgments about the rules and how well you comply. You can question those interpretations, and be ready to back up your case.

“We oversaw an audit where an inspector was going to try to lay more than $20,000 in fines for hours-of-service charges,” says Slater. “I sat across the table from the guy, got out the regulation, and asked him to explain his thinking. It was not a proper interpretation, and we fought hard to make him realize it.”

The main thing is to keep good records; you may be able to prove that the agency’s information is wrong, or incomplete. The review, after all, is built on records you should be keeping-files on vehicle safety and driver qualifications.

These are the building blocks of a professional fleet-safety management system.

Don’t Try to Cover Up Your Mistakes: An auditor who thinks you have something to hide is going to look that much harder for it. “You want to protect yourself, but there are times when it’s advantageous to acknowledge your mistakes,” Slater says. “You say, ‘You’re here to audit us, we’re here to help, because we’re trying to be better.’ It’s an approach they appreciate.”