Page 88 - Occupational Health & Safety, September 2017

TRANSPORTATION SAFETY
4 Establish guidelines to create safe solutions if drivers run out of hours.
4 Prohibit harassment (see §390.36) and coercion (see §390.6) of drivers.
4 Prohibit log falsification by improper logging in or logging out of the ELD, editing or proposing edits to gain on-duty time, or by other means such as tampering.
4 Adjust audit practices to review unassigned drive time daily, review for ELD falsification techniques, and to verify that “exempt” drivers are qualified for hours-of-service or ELD exemptions.
4 Define criteria for appropriate use of the “Personal Use” or “Yard Move” options on the ELD if these options are allowed by your company.
4 Empower, motivate, and reward employees to engage in safe behaviors based on ELD behavioral safety data.
You may discover gaps in your updated policies and procedures due to situational interpretations or regulatory changes that may occur. Periodically review and revise these “living” documents to keep them relevant, accurate, and ensure that policies remain com- pliant and aligned with the safety vision.
3. Institutionalize ongoing communication. Safety leaders must contribute to the culture change by being a change agent, not just providing their technical expertise. Change agents ensure that safety dialogue occurs through several channels, including leadership updates, driver town halls, and periodic safety meet-
ings, as well as use of social media, newsletters, and seasonal re- fresher training.
For people to take a significant change seriously, the consistent communication of expectations and standards is essential. Repeti- tion of expected behavior coupled with an open-door policy that allows employees to express their concerns is a keystone process to sustaining and improving the safety culture.
4. Coach with behavior-based data. Reporting systems must provide actionable data that can be used to coach employees. ELDs will provide a deluge of data, creating a potential liability if not distilled to identify feedback that can be used to coach and hold people accountable. ELDs can provide data such as:
■ Hours-of-service limits’ violations ■ Unassigned drive time
■ Hard braking events
■ Excessive speeding
■ Coasting out-of-gear time
Drivers, dispatchers, and leadership must not have ongoing friction in their communication. It is essential to place a priority on recognition for the achievement of desirable safety results in addi- tion to coaching and/or discipline after safety events. Your drivers should have an expectation that feedback should as likely be a “Way to go!” or “Thank you” as it is “What happened?” and “How can we avoid it next time?”
5. Use recognition and rewards to sustain change. Discipline,
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