The Role of a Driver File in a Carrier’s Safety System

Introduction

Welcome to article six of ten in this series on trucking company safety systems!  Up to now, we have discussed the importance of taking a systematic approach to achieving compliance and improving safety, examined the role different people play in safety systems, and dived into specific arms of the overarching carrier safety system.

This article will describe the role that driver files play in the safety management system of a carrier.  While the maintenance of accurate and up-to-date driver files might be viewed as nothing more than an exercise in basic compliance, there is more to driver files than meets the eye.

Driver files are a tangible representation of a system.  Multiple roles and processes mesh to produce the ordered collection of data contained within a driver file, and by auditing driver files, safety system efficacy can be assessed.  This is part of the reason why compliance audits - both internal and external - examine the contents of a carrier’s driver files: missing documentation is indicative of failures throughout the safety management system.

Many carriers spend considerable time on maintaining driver files, and the driver file is sometimes thought of simply as a place where documents go to wait for some uncertain future audit.  It is true that these files are repositories for important documentation that forms an important part of a compliance audit, and I will provide a short section on the minimum items required in a driver file in Alberta.  However, my main focus here is to shift such a mentality to one where driver files are seen as a valuable resource from which important data can be extracted to guide and improve operations.

Alberta Driver File Basics

For carriers operating under the authority of a Safety Fitness Certificate, the following ten items must be present in a file for each authorised driver of a National Safety Code (NSC) vehicle:

1. Employment application;

2. Driver’s abstract from hiring;

3. Annual driver’s abstract copies;

4. Record of previous employment history;

5. Record of safety law convictions;

6. Record of safety law administrative penalties;

7. Record of all reportable collisions;

8. Record of all safety training related to operating commercial vehicles;

9. Transportation of Dangerous Goods training certificate, and;

10. Copy of current driver’s medical.

This list is taken directly from Section 41 of Alberta’s Commercial Vehicle Certificate and Insurance Regulation [1].  I have not listed each point verbatim and I encourage those who are unfamiliar with the regulations to look up the specific wording and timelines associated with the items on this list.

A compliant driver file does not need to have ten sections, and despite Section 41 requiring specific information to be present in the file for each driver, the rules are fairly non-prescriptive in terms of how the final file needs to appear.  The employment application will likely capture the information related to previous employment.  A company may not haul any dangerous goods and therefore have no requirement for dangerous goods training certificates. Additionally, a commercial driver’s license in Alberta can only be issued with a valid medical having already been complete and verified by a registry agent, so a copy of the driver’s license (which should be kept in the driver’s file anyways) will suffice for proof of valid medical.

Expanding on the Driver File

Compliant and regularly updated driver files form the auditable cornerstone of a National Safety Code (NSC) safety program for a carrier in Alberta.  Carriers that do not meet the minimum requirements for driver files are not only breaking transportation laws but are also operating without critical safety information.  Imagine hiring a commercial truck driver without verifying that they have the correct class of license or without seeing what sorts of traffic convictions they may have; personally, no one is driving a truck I am responsible for without me ensuring they are competent and qualified.

Albertan carriers that operate in the USA under a USDOT (United States Department of Transportation) number will need to have driver files that comply with the USA’s Federal Motor Carrier Safety Regulations (FMCSRs) in addition to the NSC requirements in Alberta.  While the spirit behind the FMSCRs rules for driver files are the same, the exact requirements differ and there are extra requirements for records related to drug and alcohol testing and previous employer safety performance history checks [2].

There are other recordkeeping requirements for employers under applicable labour legislation; depending on the nature of a carrier’s operations, filing and document management can get very complicated.  But while compliance is a requirement, recordkeeping provides the carrier with opportunity: data, and the ability to analyse it.

Cooler Heads

Many companies use complicated software programs to identify performance trends based upon company metrics (data).  However, sophisticated data analysis is not necessary to benefit from information already contained in driver files.

Driver files, which should include a record of driving convictions and collisions, provide the ability to quickly review the negative safety-related performance of a driver with minimal effort; it gives a quick snapshot of past performance.  When a driver receives a ticket, violations on a roadside inspection, or has an incident in the yard that is brought to the attention of management, the immediate reaction from management can be anger and impulsivity.  By having an up-to-date record of past performance, management can quickly see how the individual in question has been performing in the context of their employment history at the company.

This is important because an anger-infused confrontation can quickly end an employment relationship regardless of who started it; furthermore, expressed anger is rarely, if ever, appropriate in today’s workplace.  The very act of checking a driver’s file for a record of their past performance before talking to the driver creates space between reactions and time for tempers to cool.

While most drivers will not accumulate one million kilometres of service without an incident and/or tickets, most professional drivers operate without routinely having problems with the law.  When an incident does occur, it needs to be viewed in the context of the driver’s complete work experience.  Sure, some offences are serious enough to justify immediate termination; most, though, are not.

Tracking Positives

From a compliance perspective, driver files focus on recording information related to transgressions of the law.  However, points of positivity should be tracked in these files as well.

Commercial driving is demanding and is often a thankless profession.  If a carrier only draws attention to drivers when they make mistakes, these stressors are only exacerbated.  Carriers should find ways to recognise good, reliable, safe service and document it alongside other driver performance records.

The reason why this is important is because tracking positive metrics allows a carrier to create a balanced view of their drivers.  Customers will occasionally contact the carrier and praise a driver; other times, drivers will reach important milestones without having a preventable collision.  These are all examples of events that should be recorded in the driver’s file (and, of course, the driver should be lauded).

Occupational Health and Safety Integration

Since this is a series on carrier safety management systems, I would be mistaken to not quickly touch upon the driver file as a mechanism for occupational health and safety (OHS) and NSC integration.  OHS systems generate employee-specific data in the form of incident reports and other documents, and this information needs to be recorded and retained in accordance with the applicable legislation.

Transportation legislation is concerned mostly with reducing the risk that carriers pose to other public highway users.  OHS legislation, on the other hand, is aimed more at protecting the workers within the carrier.  Employes will often have more success tackling high Workers’ Compensation Board (WCB) premiums by addressing OHS system deficiencies than they will transportation compliance deficiencies.

OHS system data like investigation results, incident reports, and WCB data can be used to identify areas of operations where injuries are more likely to occur.  It can be valuable to include copies of some of these documents in driver files so carriers can review OHS-related information about drivers in addition to that related to NSC.

The Right Driver for the Job

Depending on how a carrier operates, certain routes and tasks may be more hazardous than others or better suited to drivers with different skills and experience.  The information within a driver file can tell management which drivers are more capable and which require more experience.

For example, consider a flatbed company that occasionally hauls oversize loads.  Most of the loads this carrier does are comparatively simple from a driving and permitting perspective.  When oversize loads come up, the driver must take extra precautions in the form of reading permit conditions, planning routes, and affixing flags, lights, and signs as needed.

At this example carrier, not all drivers may have oversize load experience.  To reduce the risk to the carrier from problems associated with inexperienced drivers hauling oversize loads, the carrier could require drivers to do their first oversize haul under the supervision of a driver trainer.  The size and frequency of previous oversize loads hauled by each driver could also be tracked.  Such a system of tracking allows the carrier to quickly and systematically confirm which drivers are best suited for certain loads and which require additional training and experience.

I could go on about this at length, but the important takeaway is this: tracking driver experience, safety infractions, and positive performance give the carrier the ability to learn more about their workforce and better match the drivers they have with the most suitable assignments.

Summary

Driver files are compliance requirements.  However, they also contain information that presents opportunities for carriers to go beyond compliance and improve their operations.  As senior and safety management review driver files and other records, they can set aside some time to see what insights can be gained from the information they are already collecting.  Without good recordkeeping and time spent reviewing it, management drives blind.

References

1 - “Driver records”, Section 41, Commercial Vehicle Certificate and Insurance Regulation, AR 314/2002, Province of Alberta, accessed September 19th, 2021, https://www.qp.alberta.ca/documents/Regs/2002_314.pdf

2 - “6.1.2 Driver Qualification File”, Federal Motor Carrier Safety Administration, accessed September 20th, 2021,https://csa.fmcsa.dot.gov/safetyplanner/MyFiles/SubSections.aspx?ch=23&sec=66&sub=152