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J. J. Keller protects people and the businesses they run. You can trust our expertise across a wide range of subjects relating to labor, transportation, environmental, and worker safety. Our deep knowledge of federal and state agencies is built on a strong foundation of more than 100 editors and consultants and 70+ years of regulatory compliance experience.

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J. J. Keller protects people and the businesses they run. You can trust our expertise across a wide range of subjects relating to labor, transportation, environmental, and worker safety. Our deep knowledge of federal and state agencies is built on a strong foundation of more than 100 editors and consultants and 70+ years of regulatory compliance experience.

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CSA - Sample 5 Why's for Emergency Response Info Violations

Violation

A roadside inspection report for a motor carrier showed the following violation: §172.602(a) - Emergency response information missing. The motor carrier will want to find out the root cause of this Cargo-Related BASIC violation.

Question 1: Why did this event take place?

Answer: The emergency response information was not with the driver the entire dispatch.

Question 2: Why didn't the driver have the information?

Answer: The shipper never gave it to the driver.

Question 3: Why didn't the shipper offer the information?

Answer: The driver didn't check the paperwork. It was overlooked.

Question 4: Why was it overlooked?

Answer: The driver was distracted.

Question 5: Why was the driver distracted?

Answer: He felt pressured by the shipper to get in and out of the loading dock.

Possible Solutions

What might be some solution(s) based on the safety management cycle and the root cause(s)?

  • Discuss the roles and responsibilities of a driver, including how to relate to shippers and receivers. Explain what drivers are empowered to do versus when to contact dispatch about a problem.
  • Offer drivers a communication tool to voice concerns about a specific pick up or delivery site. Follow-up by monitoring and tracking these driver interactions with shippers and receivers to determine if habitual problems exits (i.e. being rushed in and out). If patterns are discovered, involve customer service to speak with the parties involved.
  • Have a policy and procedures outlining the proper protocol for a driver if an error such as missing emergency response information is discovered while on the road after leaving the shipper.
  • Conduct refresher training, individual or as a driving staff, including such topics as making sure you have the emergency response information.
  • Review applicants' roadside inspection histories in the Hazardous Materials Compliance BASIC while working for other USDOT numbers. Use the Federal Motor Carrier Safety Administration's (FMCSA's) Pre-employment Screening Program (PSP) driver reports. Develop hiring standards in your company policies based on these reports.