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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 Improper Licensing

Violation

A roadside inspection report for a motor carrier showed the following violation: 383.23(a)(2) - Operating a CMV without a CDL. The motor carrier will want to find out the root cause of this Driver Fitness BASIC violation.

Question 1: Why did this event take place?

Answer: The driver was operating truck weighing 18,000 pounds with an attached trailer weighing 12,000 pounds, but did not hold a Class A CDL.

Question 2: Why did the driver operate the vehicle without the proper license?

Answer: The supervisor only looked at the weight of the power unit for applicability to CDL licensing. He did not understand that when a power unit is under 26,001 pounds, you would look at the weight of the trailer and combination weight. If the trailer is at least 10,001 pounds and the combined weight is at least 26,001 pounds, it requires a CDL.

Question 3: Why did the supervisor not understand the CDL requirements?

Answer: He never received training on the Federal Motor Carrier Safety Regulations (FMCSRs), specifically the definition for commercial motor vehicle (CMV) in §383.5.

Question 4: Why wasn’t the supervisor training on the FMCSRs?

Answer: No one was assigned the role of creating a training program.

Question 5: Why wasn’t an FMCSR training program created?

Answer: The company is a private carrier that transports its own equipment and supplies — so FMCSR training is often missed.

Possible Solutions

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

  • Create a policy and procedures on the assigning of drivers to vehicles based on licensing.
  • Assign the role of creating and maintaining a master list of:
    • drivers and their licenses; and
    • truck and trailer weights and required license when operated.
  • Develop a training program for drivers and supervisors on the Federal Motor Carrier Safety Regulations, including key CMV definitions.
  • Monitor effectiveness of training and policies through cross referencing truck or truck-trailer combinations with the assigned drivers.