Appendix A
Stakeholder Comments by Topic

APPENDIX A1. STAKEHOLDER COMMENTS REGARDING THE SAFETY COMMUNITY AND ENVIRONMENT

Appendix A1 is devoted to comments provided by Listening Session participants around topics of how the community and environment affect safety. The statements presented are inclusive of the substantive points made by participants on this specific set of topics. The goal of the compilers has been to preserve comments in their original form but, at the same time, eliminate redundancy.

The largest portion of this chapter is devoted to key players; those individuals in the community that have a role in motor carrier safety. The Federal Motor Carrier Safety Administration (FMCSA) is not listed among the key players, but instead has its own dedicated section within this chapter, since its role as a regulatory agency drives the safety agenda for the carrier community. This chapter also discusses partnerships among the key players, and between the key players and FMCSA, and finally presents thoughts on the role of tangible infrastructure, such as roads and vehicles, with respect to safety.

A1.1 Key Players

Drivers

• Carrier drivers need to be a part of monitored groups. There is not enough attention given to the drivers; there is too much on attention given to the process.
  • FMCSA should also be monitoring driver leasing companies.
• Examine and identify the difference between drivers versus carriers.
• Drivers need a stronger say on when shipment can be delivered.
• However, maybe that is expanding the parameters of focus too much and overreaching.
• We need more focus on individual drivers, hold them accountable for personal performance and change their driving performance (if it is poor).
  • It is hard to hold drivers accountable. In order to achieve accountability, ALL drivers need to be included: all Commercial Motor Vehicle (CMV) (defined as any vehicle over 10,000 lbs), and non-commercial vehicles.
  • There is a concern that accountability may distract from safety regulations, but it is possible that accountability will not distract from the safety regulations if you track a driver over time.
  • We should extend accountability to drivers for safety and background investigations, and have them report compliance to DOT (which is different from carrier reporting responsibility).
• We must respond to the changing driver pool, because new drivers are less experienced.

Employment Environment

• There has been an increase of foreign nationals brought in from overseas to be drivers in the United States. There needs to be special attention to this new industry dynamic so we can properly address driver safety and fitness for the road system.
• There is a serious driver shortage, and there is only so much pressure that can be put on drivers before they leave the job.
  • Shifting the policing function from --- to carriers is tough in this economic environment.
  • Nevertheless, if drivers are held accountable they will perform at a higher level.
  • If drivers with bad records are allowed to switch companies, safety will be compromised. All drivers must be held accountable in some uniform way.
• To address turnover rates and the shortage of drivers, start vocational education in high schools to develop potential drivers; identify transportation as a viable career path; stop them from doing things between the ages of 18-21 that would prevent them being hired as drivers.

Hiring and Certifying

• Each company hiring manager needs to make the right decisions.
  • Regulations can only go so far.
  • Use the Motor Carrier Management Information System (MCMIS) database for drivers; good place to start when hiring.
• Currently drivers are able to move from carrier to carrier, and there is no way for a carrier to track past driving performance.
  • Currently, poor performing drivers can go from one company to the next since violations stay with a company and do not follow the driver.
  • The current law in California has a standard requiring 3 years of employment records and 2 years of drug and alcohol test results to be available (to employers).
• Qualifying drivers takes too much time and there is a shortage of drivers.
  • Companies need better, faster, and more accessible ways to pull background checks. This would enable companies to hire quicker and better drivers while maintaining a higher level of compliance.
  • The companies that are winning are those who can get drivers on road quickly.
    • Companies that are trying to comply by certifying drivers and completing background checks are losing drivers to other companies.
    • Some of the biggest violators of hiring practice regulations are large companies.
• Are there incentives or benefits to having experienced drivers?
  • Not if drivers are not unionized.
  • Many carriers would rather have new drivers.
    • Less experienced drivers cost the company less in salaries.
    • Inexperienced drivers can be trained according to the company’s needs.
  • Some insurance companies will not let companies have drivers with less than xyz years of experience.

Educational Standards

• Require minimum standard of education for all drivers.
  • Driver Vehicle Inspection Report (DVIR) – make drivers accountable for their education as well as the carrier.
• Establish an annual educational requirement.
• Provide more voluntary opportunities for drivers to be involved and develop a relationship with the FMCSA.
• Carriers must understand and appreciate that many drivers’ education level is below that of many other occupations.

What to Monitor (Non-data driven)

• Identify ways to monitor and measure driver behavior through standards that are performance-based not just statistical.
  • Conduct interviews without face-to-face meetings using electronic means or paper information.
  • Use new methods of observation.
  • Use data collected via on-board recording technology, such as hours-of-service.
    • However, these records need to be associated with managers and companies as well, not just the drivers.
    • FMCSA needs to be able to measure difference between on-duty and off-duty time.
    • A general challenge will be implementing the technology due to resistance from carriers and drivers, and cost.
  • Establish a system that distinguishes between driver errors and equipment issues. Equipment violations need to be documented and recorded.
  • Background checks should include past employment records, Motor Vehicle Record (MVR).
  • Critical factors such as fatigue need to be monitored closely.
  • Road tests and license reviews need to be conducted regularly.
• Connect citations and other traffic violations associated with a driver’s personal driving record and personally owned vehicle (POV) to his or her commercial driver’s license (CDL).
  • This will not be fair if it affects their personal insurance rates.

Performance

• Negative inspection results and log violations should follow a driver by being attached to their CDL to help carriers from hiring drivers with bad records.
• Implement a grading system for drivers and companies. Grades could be issued during various phases of employment/training:
  • Pre-employment,
  • Hiring,
  • Issuing or renewing CDL.
• Drivers should have a scoring system similar to carriers based on:
  • Motor vehicle history,
  • Valid license by state,
  • Number of log violations, and
  • Number/type/fault of accidents.
• FMCSA and other regulating entities should notify the motor vehicle carrier of driver violations.
  • This raises the issues of “Big Brother”, and violation of driver’s right to privacy.
  • The insurance companies already watch this so what’s the problem?
  • Smaller companies rely on the driver to pass violations back to the company owner, but there is no incentive for the driver to do this and it often does not get done. Companies need a way to receive driver performance information in a timely manner.

Disciplinary Action

• Industry needs more effective medical oversight to minimize issues such as forged medical cards. Drivers should be disciplined for medical fraud and omission of violations.
• Speeding violation enforcement should bear more severe consequences; for example, revoking of license or high fines.
  • Violations should also acknowledge moving type loads like hazmat and tankers.
• When carriers become out-of-service, it does not impact the driver. The driver can still get another job.
• Drivers should only be accountable for what they can control. However, currently, there is currently little consequence for their individual behavior.
• Drivers know that enforcement mainly happens with carriers and that they (the drivers) can get away with more.

Carriers

• FMCSA needs to be monitoring all carriers, which include:
  • Carriers in large metropolises
  • Unregulated carriers
  • Regulated inter and intra state companies over 10,000 lbs
  • International haulers
    • However, an issue is that FMCSA cannot regulate without jurisdiction.
  • Rogue carriers
    • Often travel up and down the interstate without penalty.
    • Often they also drive back road routes to avoid inspections.
  • Small carriers
    • There is concern about small carriers falling through the cracks. Larger carriers are more dominant so they have more inspections and attract more attention. Smaller carriers are not as easy to see. They may have less number of miles and less equipment but they still need to adhere to regulations.
  • Consortia
    • Are they following the regulations for providing documentation, random testing, accurate reports, and other regulations set for the industry?
    • Small motor carriers rely on consortia to keep them in compliance. It is difficult to help people comply if the consortium does not know the rules.
    • So, how can FMCSA help small carriers?
  • Small carriers could show they meet certification requirements.
  • Pay extra effort to incorporate the smaller carriers.
• FMCSA needs to ‘get inside’ the carriers.
  • Interview carrier officials.
  • Interview customer service personnel and operations schedulers.
  • Chief security officer (CSO) should work with FMCSA. A potential barrier is that, some safety departments are under–funded (and may not have a CSO).
• FMCSA needs to find ways to ensure that safety personnel understand the core performance of their organization. In addition, there should be minimum standard education levels, and certification and re-certification statuses established for safety personnel.
• What is working?
  • FMCSA's set of standards sets focus and direction for carriers.
  • Having FMCSA physically present at a motor carrier’s place of business is especially helpful during on-site inspection visits.

Management

• Require a ‘real’ yearly certification like those required by the Securities and Exchange Commission (SEC) or Occupational Safety and Health Administration (OSHA).
  • The OSHA 300 log affirmation is a good example because it also considers operational characteristics.
  • Corporate officers should sign something similar to SEC requirement for a signature of statement on compliance.
• The company should be accountable.
  • Because the individuals are not held accountable through FMCSA, the responsibility should fall on the company.
  • In order to get around this, some individuals move companies.
• It is up to the company to manage driver performance and then if the company stays “clean”, the government does not need to be involved.
• Make the program so that it helps the owner fix the problem.
  • Certify safety coordinators at carrier companies.
  • Help educate the industry
• It behooves us as managers to use the system properly and to be more proactive.
  • Is FMCSA asking us to take more responsibility?
• Carriers need to identify management staff [to FMCSA].
  • Some states already require management staff identification.
  • Owners’ names could be kept as part of the database, and treated as any other data of the business.

What to Monitor (Non-data driven)

• Monitor the management of a company.
  • Check whether proactive programs are in place and whether they are effective.
  • Check the company’s safety culture based on its training programs, [employee attitudes], safety record, and safety policies.
  • Check driver stability, turnover and strong management. These are the basic indicators of a stable workforce. Deterioration in any area leads to problems.
  • Look at key elements in the carrier’s safety program. Check:
    • The history of the motor carrier.
    • Drivers’ histories.
    • How many companies the owner has closed and re-opened.
• Inspect the financial state of carriers. When companies are in financial trouble, the first programs usually cut are safety and maintenance.
  • Financial inconsistencies can be a warning flag.
  • The danger zone is a carrier with 25-50 vehicles. The cost of a safety director is a competitive disadvantage for that size of company.
• Assess the culture of individual companies and states by measuring the company based on quality of driving personnel.
• Consider the [physical] appearance of driver and truck.
  • This already plays into roadside inspections but needs to be done outside of the inspections.
  • Check for ‘imminent hazards’.
  • The issue with monitoring driver and truck appearance is that there are no federal personnel to do this. How will we accomplish this need? Perhaps have the State personnel monitor back-road routes.
• Monitor the integrity of a company.
  • Verify if owner(s) have a history of prosecutions, unsatisfactory ratings, or have changed the company’s name.
  • Have a subjective measure of strong management, using objective characteristics.
  • Check if various paperwork items are being filed in a timely manner because this may be an indicator of quality.
• Are MCS150 form submissions timely?
  • If companies do not complete an MCS150 form, operation authority should be pulled or the company should lose their insurance. FMCSA would be responsible for pulling the operations authority.

Motor Carrier Authority

• An effective way the FMCSA can monitor carriers and control behavior is by issuing a warning of losing authority and enforcing the loss of authority.
  • Loss of authority would be effective for those that require authority. However, not all companies are required to have authority.
  • FMCSA needs to monitor the authority concept as opposed to monitoring the function of transportation. A Motor Carrier number means you can haul anywhere, versus a DOT number of an interstate motor carrier. When it comes to safety, who cares [to distinguish]? The authority should have been done away with because if you want to be a carrier then you must comply with safety.
  • Authority is irrelevant if the purpose of the FMCSA is safe operations and reduced injury, death and crashes. We need to determine the function of safety and if we are supposed to be meeting that goal.

Owners

• Existing owners of a company should be prevented from setting up a new company.
  • Carriers should not operate under multiple entities.
  • Many facets are involved; some companies do not have insurance.
• Have the equivalent of a CDL for owners.
  • The Federal Maritime Commission and other transportation committees have information on officers and directors and require a certain amount of experience before being qualified for their position.
• [There should be] background checks and fitness checks before an owner(s) obtains authority, in addition to pre-employment drug testing.
  • However, this creates a higher level of resources to regulate.

Economics of the Business

• Carriers are often forced to choose between serving the client or losing the client.
  • Take action against carriers who accept unreasonable contracts.
  • Take action against businesses that pressure carriers to accept unreasonable contracts.
• Consider the economics of trucking industry. In a few years there may be a decrease of carriers due to the high price of diesel fuel.
• Pay and compensation.
  • Much of safety boils down to economics. If there is a way to ensure pay is fair and equitable, then you have a better chance of equitable safety compliance by the industry.

Carriers: Bus Companies

• More bus carriers need to be inspected.
• Church and charter buses should be treated the same.
  • Non-profits should be equally regulated.
  • Compliance costs money and that cost is passed along to customers. Non-profits have harder time absorbing the costs of compliance.
    • Is a passenger’s life worth less because they are traveling with a non-profit organization?
• Hours-of-Service issue:
  • Tour groups often will not pay for drivers to comply with hours-of-service. Some bus companies ignore regulations altogether.
  • The bus industry operates differently from the trucking industry for hours- of-service.
• How often are city buses reviewed?

Carriers: Owner-Operators

• Different regulatory agencies define carriers in different ways.,
• [Owner-Operators] should take more direct responsibility because they play the role of both carrier and driver.
• Unsuspecting owner-operators can be abused by carriers and need protection and education.
  • Some carriers are predominately in the business of buying and selling trucks and not in the business of hauling freight.
• Agreements of Lease or Purchase Drivers need to be monitored, especially the economics of the agreement.

Carriers: New Entrants

• Compliance does NOT equal safety; do more upfront to prevent future problems [by engaging with new entrants].
• Check to see if the carrier is an old carrier under a new name. Existing carriers that are not complying [often] establish new entities to get around non-compliance; for example they often change their name or legal status.
  • There are also various other loopholes such as document falsification.
  • FMCSA needs to impose a penalty if a new company is started by changing their name.
  • Currently, there is no penalty for carriers who close down and open back up under different name.
    • Create a ‘watchlist of individuals’ and companies.
    • Check for consistent hours-of-service violations.
    • Watch and check the point-of-sale or re-sale of equipment by Vehicle Identification Number (VIN)
      • Purpose of use (for example, are they non-profits or small companies operating illegally?)
      • [Partner with] vehicle manufacturers and resellers

Identifying New Entrants

• New entrants should alert FMCSA of cell phone numbers so that they can be tracked [and contacted].
• New entrants often come from drivers who worked for other companies and then became an employer.
• Contractors could be used to contact all the new entrants in a instead of enforcement officers.
  • Partner with insurance companies and truck driving schools to influence the quality of new entrants.

Raise the Bar

• Evaluate and approve new entrants to see if they are up to standards before entering. Licensing application process would need to be changed.
• It is too easy to enter the industry. New York City cabs have a series of hoops to go through to get a license, why is it so much easier for trucks?
• Need to challenge [new entrants’] knowledge of rules when they apply for a DOT number (similar to what is done for a driver’s license) to assure fitness before the DOT number is established.
  • An example of testing fitness is the Department of Defense (DOD) program. They send carriers seven-page questionnaires before they are accepted. As a result, 20 percent [of carriers] are rejected for their DOD number or insurance program.
• Establish higher level of financial responsibility for entry-level carriers.
• Require fee for new entrants and justify the cost by earmarking dollars to improve safety, compliance, or education programs. If [those funds are] focused and targeted to safety, the industry would be paying for its own safety compliance though the fees.
• There should be an investigation before issuing a license to prevent repeat carrier offenders from re-opening business under a new name.
• New entrants should have a required level of education in order to get a DOT number; this should be more than just an MC (motor carrier) number. Currently, more education is required.
  • Use this as a barrier to entry. Mandate training. New entrants should attend a seminar prior to receiving a DOT number.
  • It should be harder to get into the business than stay in the business.
  • Florida has a program where new carriers are required to attend a seminar to learn about Compliance Review (CR ) process. Georgia does not have any rule at all for new entrants.
• The positive effects this could have:
  • Slow incoming entrants. We acknowledge the amount of new entrants and limitations in covering more than 2 percent of the industry due to money constraints, Congress, and number of bodies.
  • Improve the quality of carriers on the road
  • Identify who is violating the rules.

Process for New Entrants should be ‘Educate, Then Certify, Then Monitor’

• Prevention and education greatly lower the number of new entrants. FMCSA cannot efficiently get to all the new entrants, but it is better to orient them before they start.
  • Currently, new entrants receive a letter without any follow-up of regulations or expectations.
  • Use education to reduce fines; for example, if [company staff] takes a certain number of educational classes a fine could be reduced.
• Improve new entrant program with stronger control, safety audits, testing, and ratings. Front-load new entrant program with CR’s and assessment ratings.
  • Assess safety fitness programs and look at acute and critical violations. If the processes are poor, put the carrier out-of -service until they are in compliance.
  • FMCSA should have a certification process in place for [new] operators [to expedite the start-up process and encourage compliance].
    • Some new carriers are put out of service for 30 days because they have not received their warning letter.
  • [The FMCSA should] perform [a new entrant’s] CR with a rating in the first 18 months of operation.
• [New entrants could] post a bond to cover the cost of a pre-entry safety certification and rating that could be conducted by a certified third party examiner.
• Educating new entrants wastes the time of enforcement officers.

Auditing New Entrants

• New entrant audits should have better follow-up after the initial audit.
  • Initial audit should be more informal and educational.
  • Audit done inside initial 18 months was informative.
  • Need better responsiveness from DOT during follow-up.
  • DOT is responsive when organization states that they need a training program immediately. However, once DOT leaves a facility, compliance often ends immediately.
  • Organizations often feel like they have no one to go to. When they call DOT, there is no one to talk to, and all they can do is leave a message.
• New carriers are [often] willing to undergo a CR, [and yet are] unable to get one.
  • It is inefficient to perform CRs [for new entrants] one by one; administering them in groups would be better.
  • CRs for new entrants should have more Q & A.
• New U.S. entrant audits differ from Mexican entrant audits:
  • Mexican carriers are required to go through a safety audit first to allow them provisional authority, then, are issued a CR after 18 months for permanent authority.
  • U.S. carriers: No audit prior to obtaining operating authority. Initial audit is scheduled within a ‘reasonable timeframe’ after DOT number request, and then there is no follow-up,
• Follow up and enforcement is lacking.

Dispatchers

• During a compliance review (CR) it would be useful to talk to dispatchers, inspect the operation and safety program.
  • Conduct employee interviews, similar to the interviews conducted by OSHA and report observations.
    • If a dispatcher understands hours-of-service, this at least shows an attempt at safety compliance.
  • Look at the morale of employees and drivers.
    • Dispatcher can affect morale.
• Currently, there is no documentation on dispatcher activities.
  • Data storage issues
  • Off hours
  • Dispatchers are key resources [of information] and often underutilized.
• You can relate on-time rates and miles per gallon back to the dispatcher.

Shippers, Brokers and Receivers

• There are many forms of shippers:
  • Travel agents.
  • Tour agencies.
  • Other customers.
• [Someone needs to] regulate shippers.
  • FMCSA needs legislation from Congress in order to enforce with criminal and civil penalties.
  • Could regulate by hours-of-operation and proper identification of shipped goods.
• Shipment documents that are incorrect and or inaccurate should be the responsibility of shipper. Currently carriers are cited for any errors made by the shipper.
• Shipper put loads together but they do not have to load them themselves.
• During compliance reviews (CR), shippers and brokers are forgotten and the entire burden falls on the carrier.
  • Should the FMSCA have jurisdiction over shippers and brokers?
  • How would the FMCSA enforce rules with respect to these and other entities?
    • Build off contractual expectations
    • Actions should be taken against shippers who continually attempt to contract with unreasonable timeframe expectations, etc..
    • In addition, action should be taken against carriers who accept these unreasonable contracts.
• It is naïve to believe that FMCSA can have an affect on shippers.
  • The reality is that consumers need to make the correct decision.

Shipper Impact on Carrier Industry Raises Question of Need for Regulation

• Review shippers to see if they are putting pressure on the carrier industry.
  • Driver’s log has shipping information. A specific shipper’s name may be linked to forcing hours-of-service.
    • FMCSA needs to police this connection somehow and have the authority to enforce retribution for violations.
  • Large shippers are the ones involved [main offenders of pressuring hours-of-service]. They need special regulation and a specified penalty. Small shippers usually do not have the leverage to apply pressure to carriers.
  • [The FMCSA should take] example from hazardous waste, where the concept [of safety] is “from cradle to grave” meaning that everyone in the chain is responsible for the disposal. Assign responsibility to the shippers in addition to the carrier. The penalty is liability. Make shippers accountable for hiring carriers.
  • It is the responsibility of shipper to choose a good carrier, not just the guy with the cheapest rate.
• Shippers require that products be delivered on time, demanding drivers to violate minimum hours. They also dictate how vehicles should be loaded and they lack accountability.
• An FMCSA agent should call on shippers known to require carriers to conduct unrealistic delivery schedules thereby forcing violation of hours requirements. Shippers should be held liable for “aiding and abetting” those violations.
• Shippers’ demands are putting pressure on carriers to promote illegal action on part of the carrier and the driver.
  • FMCSA can monitor shippers and motor equipment operators and enforce responsibility.
    • Are shippers hiring carriers that are going out of service more frequently? If so, what responsibility do they have?
    • Do carriers [in violation] end up being placed out of service or get an unsatisfactory rating [from FMCSA]?
  • Carriers take responsibility when they assume freight, but shippers bear none.
    • If there are carriers with out-of-service problems, look at who the shippers are. If a specific shipper hires four core carriers and all of them have problems then perhaps the shipping company should be consider or sited for placing unsafe demands on people hauling products.
    • Shippers always get a free ride! They should be treated fairly and equitably.

Shipper Incentives and Enforcement

• Create shipper disincentive to put load on street.
  • There is a network of knowledge within industry of who will take loads.
  • The question is how to report and enforce, and what will be the response? We need to know the agency has someone to talk to if they are raising awareness of an issue.
• Create shipper incentives to create more driver friendly loading times, better equipment utilization, predictable freight patterns.
  • For example, a discount for non-peak hour shipping. Trucking companies could expand operations to handle non-peak shipping such as extending into weekends and using more drivers without additional cost of equipment.
• Shipper ratings could established and be based on:
  • Accuracy.
  • On-time arrival.
  • Creating a safe environment.
  • OSHA ratings on injury reports.
• Shippers should get fined for “forcing” drivers to break regulations.
  • Define at what point does it become negligence by the shipper to give hazardous material to a carrier?
• Maybe license shippers and hold them accountable in some way.
  • Provide shippers with more information and make them accountable for knowing and applying that information.
  • We cannot make the industry enforce the shipper and customer controls.
  • Is it better to regulate the shipper or the motor carrier to assure effective enforcement?
  • What is the insurance industry’s perspective on this topic?
• Currently, there is no accountability with shippers on what they ask carriers to do. Maybe shippers can become involved in this process.

Shipper Awareness

• Shippers should tour distribution centers.
• Shippers should assist carriers in meeting compliance.
  • Need to educate shippers on regulations, and the realities of transportation.

Equipment Suppliers

• The intermodal equipment suppliers.
  • Where does the accountability by the owner start and the equipment supplier stop?
• Owners of trailers [leasing companies].

Unions

• [Some perceive] that they keep unsafe drivers on the road.
• [Others perceive] that they keep drivers from being penalized for not agreeing to pressure of operating unsafely to meet shipper requirements.
  • Do request help from law enforcement when driver is pressured by carrier.

Law Enforcement
[Also refer to Appendix A1.3 Partnerships/Partnerships with States]

• The level of enforcement is currently different in different places.
  • Law enforcement needs to investigate truck complaints.
• There is discrepancy with enforcement officers. When I call the local enforcement agency to take care of a motor carrier violation, they have no idea what I am talking about. If you make a phone call that there is a robbery at a 7-11, they react. But if a limo company crosses a state line illegally, they do not respond. Aren’t they supposed to respond to that, too?
• Educate law enforcement on more than just basics of commercial driving.
  • Local law enforcement needs to know the local laws.
  • There is different experience at the state level.
  • Law enforcement training is functionally based. According to a Wisconsin study, only 4% [of incidents] are checked by fully trained people. It is more likely that crashes are the responsibility of unregulated motor carriers.
• Currently, neither State DOT nor USDOT pursues uninsured carriers. However, carriers have been known to borrow ICCS and DOT numbers from others to invent phony IDs, and insurance cards.
• Law enforcement is source of data.
  • There needs to be more accountability for law enforcement to report accurately.
  • Accident reporting guidelines are needed. Many problems occur with SafeStat because of misinformation and checking the wrong boxes on accident reports.
  • Law enforcement should collect less information but standardize it.
• FMCSA has no authority over law enforcement group.

Third Parties: Commercial Driving Schools

• [The FMCSA should] work in conjunction with driving schools.
• Need to monitor or provide minimum reviews, standards, guidelines, certifications.
  • [However, this raises the question] ‘What about over-regulating?‘
  • A rule was just passed on training but it didn’t go far enough because it does not address defensive driving.
    • Training should be consistent, but how is that done?
• Truck driving schools could help by ensuring a proper curriculum and providing professional accreditation.
• [Commercial Driving Schools could] conduct offsite testing.
• FMCSA should endorse existing good certified programs. Many schools are not currently certified.
  • Encourage similar programs that are best practices be adopted by new schools.
• FMCSA should track and oversee the following:
  • Curriculum.
  • Pass or fail rate of schools.
  • Performance of graduates including crashes, violations.

Third Parties: Examiners/Administrative Services

• [Certification of third parties is important.]
  • Certify other transportation consultants.
    • Certify to improve consistency of what is being communicated.
    • Certifying consultants may also require a change in rules because interpretation of rules creates subjectivity.
  • Create a certification process for providing third party administrative services for trucking associations.
    • For example, Medical Review Officers (MRO) who do drug tests need to have training on what is required for DOT regulations. [Also refer to Appendix A1.1 Key Players/Third Parties: Medical Professionals.]
• [The FMCSA should consider the] use of a licensed third party to:
  • Conduct all or part of compliance reviews (CR) or audits.
    • Insurance, private certified organizations or internal certified carrier personnel.
    • Paid by motor carrier and under the direction and control of the FMCSA.
    • Third parties could to the CR administrative work such as entering data into the system from the carrier.
    • Carriers would have no problem with third party inspectors if they are qualified.
  • Third parties could contact new entrants for other FMCSA activities without an associated enforcement action.
  • Institute a third party to conduct internal audits of security performance to encourage more companies to comply, and to increase the amount of data collected.
• [The FMCSA needs to consider the following concerns] if third parties are used:
  • There would be training, oversight, and certification issues.
  • The federal level should monitor fraud when using third party examiners.
  • Conflict of interest issues.
• Set up an outside certification program. FMCSA can be the sponsor and define requirements. Then the industry can maintain through market forces, interest in certification all by third party.
• The more you have the more you get – insurance carriers and others can help create policies, requirements, structure, programs.

Third Parties: Medical Professionals

• Certify those who do DOT physicals, including Medical Review Officers (MRO) who administer drug tests.
  • The Federal Aviation Administration (FAA) certifies doctors for pilot physicals; currently, there is nothing like this for drivers. [The FMCSA] should use FAA method for guidelines.
  • Make a list of certified physicians available.
  • Currently drivers can go anywhere for physicals or drug testing, and doctor-shopping does occur.
  • Medical doctors should certify drivers, not medical assistants.
• [Medical exams] must be consistent, complete, uniform:
  • What is being checked? Physical health such as; blood pressure, hearing loss and medications.
  • Need programs that look out for shortcomings of clinical physicians because they do not know what needs to be looked at during these physicals.
  • Drivers and companies need to have confidence in the accuracy of drug testing procedures.
• Medical providers need to “be on the same page”.
  • Physicians need to know what to look for in order to certify a “safe” driver
    • Many doctors do not kept up-to-date with changes and new guidelines.
  • Supporting teams such as insurance and policy need to be consistent.
  • Need to establish standard definitions across the country.
• [The FMCSA needs to] revamp drug and alcohol regulations so that it “captures” all drivers. However, this tensions between Human Resources versus Safety due to issues of invasion of privacy.
• Need a way to track immediate certification of drivers.
  • Better controls are needed of physical form which currently comes from drivers; this should come from medical professionals.
  • Carriers need to know, understand and have access to [some] database.
  • Driver’s health assessments should be made available, not all drivers will tell a company.
• Doctors do not want to put drivers out of work.

Third Parties: Vehicle Observing Companies

• The vehicle observing companies…companies get those reports and do not follow up on them. That should be considered, too. They might be doing it, having the sticker on their truck, but it is for show. It’s not something they monitor.

Insurance Companies

• [Insurance companies should] ensure that carriers have an MCS90. Right now, a carrier gets penalized, not the insurance company.
• There should be centralized data about insurance for carriers.
• States should notify FMCSA if an insurance agency goes out of business.
• Currently, neither State DOT nor USDOT pursues uninsured carriers. However, carriers have been known to borrow ICCS and DOT numbers from others to invent phony IDs, and insurance cards.
• Some insurance companies do not understand the business of carriers, which increases risk. These insurance companies need to be educated.
• Insurance companies want partnership because their bottom line is the safety of their clients.
• Partnership with insurance companies could:
  • Determine best practices
  • Make loss prevention resource program available
  • Disclose claims data
  • Standardize regulations across states
  • Programs focused on CMV, address needs and statistical data
• [The FMCSA should] partner with insurance companies, since they have so much information. Also because trucks, by law, must be insured, insurance companies often have up-to-date information. However, carrier companies are not always willing to share the data. Loss runs are the carrier’s property not the insurance industry, and the FMCSA could review and collect that information.
• Insurance companies do the same type of audit [as FMCSA]; FMCSA should follow the CR, educate and give information back to the insurance company.

The Motoring Public

• The motoring public (non-commercial drivers) should be tested, monitored, and educated.
  • Address other drivers on the road who do silly things such as cut in front of trucks and cause unnecessarily dangerous situations.
• Pay attention to non-commercial driving education. Educate non-CMV public using the roadway on:
  • Sharing the road with trucks. Expand existing “Share the Road” program.
  • Where truck blind spots are located
  • Truck-related laws

A1.2 The FMCSA

• The FMCSA’s uniqueness is its enforcement power.
• There should be a performance metric for FMCSA itself.
  • Need to measure how well the compliance reviews (CRs) are being administered by the FMCSA and key officials.
  • Oversight is perceived as ineffective because compliance officer training lacks consistency.
• Also, the FMCSA must test out technologies. As part of change, FMCSA should use an evaluation tool for seeing whether we are heading in right direction.
• [The FMCSA needs to] drive fairness and uniformity by eliminating arbitrary discrepancies between states and apply its own rules consistently.

Coping with Growth, Size, Economics

• Need to streamline processes and cut down on paperwork.
• Need to catch up with what is there now and keep up.
• FMCSA is not keeping up with the current number of “approved” carriers. However, is FMCSA only concerned with covering the numbers to hit their pre-determined goal?
  • FMCSA needs to clean up the records of ‘dead’ carriers.
• Functionally, there is no way to manage the increase in new carriers and freight.
  • FMCSA needs to get a handle on industry growth. Where are all the carriers coming from?
    • How will this growth continue to impact 2 percent of carriers receiving CRs?
    • As the number of entities to monitor increases, who will enforce violations?
• Trying to reach more people just to do an audit is ridiculous, FMCSA needs to have a legitimate reason as to why that will add value.
• There does not seem to be an effort to look at existing programs to see if they’re viable. [The FMCSA should] eliminate programs of no value before layering on more programs.
• If there is no change in the way FMCSA does business, everyone from the top down continues to drown. FMCSA will probably continue to regulate those who do not need to be regulated and squander the likelihood of any partnerships.
• Can another agency, like the Department of Homeland Security (DHS), security program take on some of the responsibility?
• Are carrier population growth statistics [provided by FMCSA in the presentation] based on organic growth?
  • Are the new carriers actually new entrants (companies with new trucks and new drivers) or just a shuffling of the deck with a new DOT number? For example, large companies could split themselves into 50 different DOT numbers, one for every state.

Budget and Resources

• Funding and budgetary constraints are big issues, especially as increasing program demands require more resources.
  • The FMCSA needs to find funding for states to maintain compliance.
  • [The FMCSA needs to] reconfigure Motor Carrier Safety Assistance Program (MCSAP) money; do not waste on roadside inspection.
  • Supplementary funding methods should be explored.
  • If government resources are not available then we will need to push responsibility onto operators.
• Additional resources will be needed to help carriers comply when new regulations are made.
• Economic realities show decreasing resources for enforcement, law, and rail partners.
• [The FMCSA needs to make] trade-offs: Are we going to spend more on enforcement versus barriers to new entrants in the market?
• [The FMCSA needs to] prioritize. [It needs to] consider the program value and return against dollars spent for safety. This way, extra funding could be allocated towards the better safety programs.
• Involve other resources. It is unrealistic to do a CR every year on all motor carriers. Instead, independent contractors to assist with inspections.
• Use 80-20 rule—80 percent of the problem is caused by 20 percent of the people.
• [The FMCSA needs to find ways to] eliminate problems from front-end and reduce time.

Communication and Customer Service

• [The FMCSA should seek to] share information at time of registration, at sale and at rental.
• [The FMCSA should] continue talking to leaders of organizations and make compliance and safety the main focus.
• Communication and information sharing between U.S. Customs and federal agencies would expedite border safety inspections.
  • U.S. Customs should share information regarding commercial vehicles.
  • Both agencies need to know what hazmat materials are crossing the border.
• Information is too difficult to get. For example, the American Trucking Association (ATA) suggested that the field operations manual should be publicly available. Currently obtaining fields operations training manual requires a Freedom of Information Act (FOIA) form.

Reaching Out

• Need better publicity of existing outreach programs.
• [Having] no contact with the FMCSA until enforcement is an issue!
• Need to connect to people with responsibility and information in companies.
  • For example, the state of Georgia invites people with a “come and see us” slogan. However, for privacy purposes, they have to talk to 6 different carriers in separate rooms.
• [The FMCSA needs to] be in touch with the needs of the industry it is serving.
• ASK DRIVERS!
  • Have a hot line for drivers.

Better Communication

• Communication needs to be proactive and not just through the internet
  • Communication cannot be limited to the internet since not all organizations have internet access.
• Need to improve communications to companies and drivers that will mitigate accidents such as accident prevention strategies and accident hotspots so drivers will be more careful in these areas.
• The FMCSA needs better and simpler communication, and to cut down the bureaucracy.
  • The FMCSA needs to be more visible and create an ease of contact. Right now [stakeholders] encounter too many recorded messages.
  • [Have a] More user friendly website
    • Have form templates available on the website
  • Have a better explanation of why a credit card is needed for a no change service.
  • Use email to distribute information to carriers
• Questionnaires, phone calls, mail outs could be used to contact carriers
  • Make sure Bilingual and ESL is considered for communication strategy.
• The FMCSA regulations should be user friendly, not in legalese.

Customer Service

• The FMSCA has an image issue it needs to deal with. Stakeholders fear retribution when providing constructive feedback.
• If a company inherits bad tendencies, it needs to have access to an FMCSA person to help the company meet compliance without being hammered.
• Be user-friendly with automated phone resources and faxing in renewal forms; we need to make things easier for us and for you.
• Make more materials available, especially for smaller carriers.

Communication of Violations

• States need to notify carriers about suspended drivers.
  • This concern has been raised in the past and the reasoning was there are “No funds” available.
    • Maybe there are technologies to do this. For example, how much does email cost?
• States need a standardized manner, such as an Employer Violation Notification Program, to notify a carrier that a driver received a violation. Notify the carrier when drivers are stopped or cited.
  • This could work similar to the California pull notice program.

The FMCSA’s Internal Structure, Staffing

• Is the FMCSA is too top heavy, since there are not enough auditors?

Federal, Regional, State
[Also refer to Appendix A1.3 Partnerships/Partnerships with States, and Appendix 2.5 Compliance Reviews]

• Decentralize FMCSA’s efforts. The FMCSA should audit and train the state DOT staff to find the under trained and the non-reporters.
• Each service center should use the same criteria in determining when there is an enforcement case.
• Discrepancies between regions need to be smoothed out.

Inspectors and Auditors

• Designate certain auditors to audit larger companies and others for smaller carriers.
• There should be a different inspector for each CR. This might help in achieving a fairer follow-up CR.
• Bring accident preventability decision-making power back to FMCSA field investigators performing CRs, this time with preventability training.
• Standardize inspections and inspectors.
• Send carriers a questionnaire post-CR to ask about the officer’s performance.
  • Inspections are often inconsistent due to lack of knowledge. [The FMCSA] needs to review qualifications of the inspectors.
• Inspectors should have hands-on experience of sitting in a CMV.
  • This would help inspectors use information better.
  • This was part of the original outreach.
  • However, there is concern that inspections would not be objective if a close relationship is built between the inspector and inspectee.
• Inspectors should evaluate equipment as part of federal CR; currently this is the responsibility of the state only.
  • This would help determine whether maintenance records are valid, such as is done for airline inspections.
• The location of where roadside safety inspections occur is important not just to ensure that a broadness of inspections are being performed, but also to ensure the safety of the inspectors. This concern might be a training topic for law enforcement.

Goals

• Prioritize the programs with clearly stated goals; the results should drive priorities.
• Agency and industry are equally committed.
• Agency does good job of working with states and their enforcement activities.

Timing and Nature of Change Agenda

• Change is good and needs to occur more quickly than 6-8 years from now. Perhaps the FMCSA can make changes in bits and pieces.
• [There is] concern that change will take too long.
  • Change has been attempted in the past and it has not worked. Need to make sure that the change is effective.
• Start being proactive now; do not waste time trying to fix what happened last year.
  • Perhaps the FMCSA should have two groups: one to analyze ways to bring in new ideas for change and one to review existing policies, for example CDLIS.
• It’s hard to be a responsible carrier and talk about the urgency of safety when its 2004 and the program is entitled ‘2010’. Symbolically that says volumes about change.
• The timeline for change needs to be cognizant of technologies passing by.
  • For example, drug and alcohol testing took 2 years; now there are newer methods.
• The FMCSA needs to change to improve credibility. The agency needs to make data, the CR selection process, and SafeStat more credible to drivers, states and industry.
• Reasons to change include:
  • Change is necessary, otherwise the industry (or FMCSA) will tread water for next few years.
  • Need to change to make organizational system more cost-effective.
  • Need to change to improve efficiency and leverage.
  • Need to change to improve accident reduction.
    • Can be done through industry root cause analysis.
  • Need to change in order to take advantage of innovation.
• The more things change, the more they stay the same.
  • There is a tremendous amount of opinion that has not been adopted [by FMCSA].

A1.3 Partnerships

• Currently, there is a lack of partnering by the FMCSA.
• It is necessary for FMCSA to expand relationships and incentives for others to partner with them.
• [Any] change needs to involve third parties.
  • The government cannot do this on its own.
  • If we do not sit down and talk together to get to a process as a community, we are not going get to compliance from the industry.
  • There needs to be partnerships between DOT and state associations during audits to join forces and share information and leverage numbers.
  • The result would be less intrusion and less time taken for audits.
• Will “partners” include regulated parties?
• Partnership must include information sharing with the federal government so we can make proper decisions with proper information, for example, Commercial Driver’s License Information System (CDLIS).
• FMCSA needs to focus its partners on causal factors.

Why Partnerships Make Sense

• Getting industry on board and gaining their support will ease the FMCSA’s burden.
• Important to have some dependency on others, different layers working together. Many organizations such as: insurance, medical and third-party administrators (TPAs) are involved in the regulations but not in the reporting. These organizations have a wealth of knowledge about carriers at their disposal; the information is just sitting there, and not being accessed.
• [Partnerships are needed to improve] effectiveness. Partnerships are needed where carrier’s hands are tied, since regulation brings them 90 percent to safety but they need that extra 10 percent.
• It is more cost effective to work with partners.
• Core values and concern for safety are shared [among various industry groups].
• Small carriers, non-profits and trade organizations want to go beyond basic compliance to safety management, but compliance presents a huge task with little help and limited resources. We need to create a cooperative effort to help each other.
• Partnership could foster cooperation across agencies, including with local law enforcement agencies.
• [Partnership would] improve data exchange:
  • After all, information must come into FMCSA and then go back out again.
  • There needs to be continuous input from stakeholders as trucking safety changes.
• The FMCSA needs the trust and cooperation from industry for enforcement purposes. Strong consequences are needed if cooperation does not occur.

Desire for Partnerships

• Company head: we would love to be a partner with the FMCSA and get involved. We license insurance agents, so why not new entrants?
• Carriers want to be partners, not adversaries; they wish to work with the governing bodies and get the bad guys off the road.
  • [However, there is a] fear of the FMCSA oversight.
• Why is there an adversarial relationship with OSHA Voluntary Protection Program (VPP) programs? We ought to want to invite the FMCSA in to do things with us instead of dreading the required visit.

Possible Types of Partnership

• Integrate with insurance companies since trucks have to be insured, according to the law. For example, why not register a truck when getting insurance? [Also refer to Appendix section A1.1 Key Players/Insurance Companies for additional details.]
• Partnership between industry and enforcement. Leverage association partnership with:
  • Insurance companies.
  • Medical certification community.
  • Pre-pass.
  • State agencies.
• Reach out to the public.
• Partner with driving schools [Also refer to Appendix section 1.1/Key Payers/Third Parties: Commercial Driving Schools] and Mexican drivers.
• Partner with insurance companies and truck driving schools to influence the quality of new entrants.
• FMCSA should partner with the Federal Transit Authority on city bus transits. FTA currently has no enforcement arm, so city bus operations never get reviewed and it shows.
• Trucking companies should have compliance coordinators who communicate with DOT personnel to keep up-to-date with changes in regulations.
  • The focus should be on attracting companies to hire compliance coordinators that DOT trains along with the law enforcement and its own personnel. There should be an ability of all three groups to have a cooperative relationship instead of an adversarial relationship.

Partnerships With States
[Also refer to Appendix A1.1 Key Players/Law Enforcement and Appendix A2.1 Intra and Inter State Matters.]

• Partner with states, but do not lean on them. We need to work closer with states to make sure they are implementing the statutes and laws that FMCSA and Congress pass.
• Medical and license sharing information across state and international borders would be helpful.
• Regular audit and training of State officers should occur to keep statistics consistent.
• Leverage is needed to be open to additional partners. For example, the Georgia Department of Motor Vehicles (DMV) does a new entrance test and educates by using enforcement officers, instead use non-enforcement partners to conduct tests.
• It would be better to have the federal government maintain Motor Carrier Safety Assistance Program (MCSAP) dollars and Compliance Reviews (CRs), so that all states have consistent benefits and the same requirements.
• Different enforcement agencies read possible injuries, and accident reports differently. [Also refer to Appendix A3.2 Data/Accidents.]
• Local law enforcement should share state information, standardize reporting forms.
• Regulations need to be simple and consistent across all states.
• Build consistency across state lines: Prepass programs, overweight violations, amount of tickets, uniform points for drivers log violations.
  • The fatality goal was set for all trucks, but it did not actually reach the intra-state trucks. FMCSA must embrace that population, too.
• When the feds get updated information, send it to state enforcement. Then states can understand what they are supposed to be enforcing.
• States should notify FMCSA if an insurance agency goes out of business.

A1.4 Infrastructure, Operating Context

• Need to look at infrastructure and highways as a contributing factor to safety.
• We have an infrastructure that is at capacity. The one thing that would be the biggest help to carriers would be to improve roads.
• Secondary roads have many accidents.
• Federally funded roads are a sub-connection between investment for the best possible roads and the responsibility of users.
• For urban drivers and over the road drivers, we need to find a way to compare and equate the circumstances using something like a surface transportation classification code.
• Current infrastructure constraints include:
  • Roads at capacity, with bad congestion following a commercial vehicle accident;
  • Price of fuel going up, threatening the economics of the trucking industry.
• How about turning empty malls outside of large cities, such as New York City and Los Angeles into major distribution centers to transfer freight that is transferable from extra large trailers to smaller trucks for safer, easier deliveries?
• There has been an overlap of safety and security post-9/11.

Mechanical Safety Features in Truck Design and Technology

• FMCSA should support retrofitting, such as with wining harnesses. Retrofitting is a simple way to improve trucks mechanical safety features and technology instead of buying a new upgraded vehicle.
• The trucking industry does not have any type of 5-star safety vehicle rating for safety features like the automobile industry has for cars.
  • Make safety for drivers a priority, starting with the manufacturer.
  • In fact, there are no safety factors or standards for trucks, like survivability factors, grab rails, a good step system.
• Need to apply standard technology to all trucks; make access to these technological advances easy:
  • Detection devices that detect when trucks depart lanes.
  • Radar systems.
  • Drowsy driver detectors.
• Also implement technology on passenger cars to make them more visible to truck drivers.
• Technology is helping to elevate the problem of speeding, but governed truck engines can still be jiggered with.

APPENDIX A2. STAKEHOLDER COMMENTS REGARDING SAFETY POLICIES AND BUSINESS PROCESSES

This chapter includes comments provided by Listening Session participants around topics of policy and business processes that promote safety. The statements presented are inclusive of the substantive points made by participants on this set of topics. The goal of the compilers has been to preserve comments in their original form but, at the same time, eliminate redundancy.

A2.1 Policy

• Change “worldview” of everything being tied to fines and staying ahead of regulations to avoid negative impressions.
• Change “worldview” of only regulating “top down” and garnering support from “middle” and “bottom” through regulations and fines.
• Focus on remediation not enforcement.
• Regulations that try to be ‘one size fits all’ are the biggest straight jackets. Regulations should include flexibility for scale.
• Regulations should make things safer. If a group does not have many accidents and problems, then they need to be exempted from regulations, for example, the 100-mile radius rule.

Safety as a Strategy

• Public safety should be the greatest goal so it trumps all other issues.
• CRs look at current regulations, not at safety culture or safety as a whole ongoing process.
• The majority of time is spent reviewing hours-of-service, rather than being proactive and preventive.
• All programs should promote: ‘Safety pays off’.

Compliance Does Not Equal Safety

• Currently it seems FMCSA is only compliance-oriented.
• Safety management is a much broader approach than just regulations and compliance; the industry should think beyond rules and look to safety practices.
• Safety management and compliance are not necessarily connected.
  • Compliance can breed safety, but it is how people use and apply the regulations.
    • Regulations do work; the violation of a regulation is usually just a symptom of a larger problem, we must look closer to find the root cause of the violation.
• Just because a carrier is in compliance does not mean they are a “safe” operator.
  • Completing paper work does not equal safety.

Security Issues

• FMCSA needs to review current programs and their demand on resources:
  • For example, new security background checks for hazmat carriers were implemented after 9/11. Are these necessary or do they detract from other higher priority safety and security items? Someone does not need a driver’s license to highjack a truck.

Privacy

• ACLU privacy issues could be a barrier to information sharing.
• The Big Brother aspect is a concern. We are already in a Big Brother state.
• An authorization from the driver should be needed to release personal information for background checks.

A2.2 Regulatory Oversight

• There is a direct impact of DOT presence and visibility on carriers looking for assistance and information on what they need to do to achieve compliance.
• Oversight process is very positive because there is a policy development to ensure compliance.
• Oversight can be good, but needs to have established checks and balances.
• The FMCSA is focused on licensed carriers, but can they also recognize there are unlicensed carriers running with authority?
  • Authority issues are not being enforced.
• The oversight often fails to account for industry differences. [There appears to be a] shotgun approach to regulatory compliance. [Oversight needs to] level the playing field within the industry.

How Much Regulation?

• We are asking for too much regulation; it is up to the carrier to comply and get information [to appropriate entities in timely basis].
• Too much time and resources are devoted to appeasing the legal process.
• Carriers need freedom from oversight.

Intra and Inter State Matters
[Also refer to Appendix A1.3 Partnerships/Partnerships with States, Appendix 3.2 Data/Definitions]

• [The FMCSA needs] to explore cross-state issues.
• [There exists] disparity between intra and interstate carriers. Federal standards should apply to all because many fatalities are from the intrastate population. Federal regulations of intrastate carriers are needed.
  • In order justify the need for change, FMCSA will need to focus on reducing overall collisions.
  • Perhaps some intrastate carriers are turning back federal money because they do not have the personnel to complete CRs.
• Encourage states to expand their partners. Funding could be tied to the performance of intrastate carriers.
• Intercity versus intracity carriers should have different standards:
  • Exposure in intercity is larger. Exposure information can probably be obtained from insurance providers.
  • Miles driven should be taken into account.
• Many states already differentiate between intra and interstate. The FMCSA should take advantage of existing defined differentiations between intra and interstate and depend on the states to scrutinize.

Hours-of-Service

• Some companies are decreasing break time in order to not go over the 14 hour rule, which is often caused by congested traffic or a mechanical breakdown.
  • Some companies tell drivers to log the time they are “relieved from duty.” For example when a driver is waiting for the load to fill this can be logged as time “relieved from duty;” this clause needs to be explained better.
  • This creates an unsafe environment. [An alternative to this rule is to] install a voluntary break per hours driven.
• Current ‘hours-of-service’ creates a conflict in jurisdiction and laws; do companies obey state law or the FMCSA?
• Most hours-of-operation violations occur during nights and weekends since they are not usually monitored.
  • There must be a PRESENCE if we hope to curb violations!!

Hours-of-Service and Shipper influence

• Hours-of-service helped to modify shipper and customer behavior but not fully across all shippers.
  • Carriers have dropped shippers but other carriers will pick them up.
• [Safety] needs to be a partnership. I have had drivers call me when their hours-of-service are up, but the shipper wants them off their property; what is that driver supposed to do? Partnerships could resolve issues like this. We have accepted the 14-hour rule and time constraints.
  • The industry needs to manage time requirements and restraints with realistic expectations better.
  • Some of the existing conflicts arise between: could be resolved through negotiating and trying to resolve conflicts. It is reasonable to get to gether and talk about partnering, and look at the abusive relationship between the shipper