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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 Rest Break Violation

Violation

A roadside inspection report for a motor carrier showed the following violation: 395.3(a)(3)(ii) - Driving beyond 8-hour driving limit since the end of the last on duty, off duty, or sleeper period of at least 30 minutes. The motor carrier will want to find out the root cause of this Hours-of-Service Compliance BASIC violation.

Question 1: Why did this event take place?

Answer: There were more than 8 hours of driving since her last interruption to driving of 30 minutes or more.

Question 2: Why did the driver operate the vehicle beyond 8 hours without a 30-minute interruption?

Answer: She was running behind due to traffic congestion associated with road construction in her 7th to 8th hour of driving time.

Question 3: Why didn’t the driver stop before the road construction?

Answer: She was unaware the road construction was ahead.

Question 4: Why was she not aware of the road construction?

Answer: She did not check the state transportation websites as a part of her trip planning.

Question 5: Why didn’t she look at all variables when looking at her dispatch route?

Answer: She was relatively new and did not recall the training she had to check for road construction and other delays and plan accordingly.

Possible Solutions

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

  • Revise new hire training on trip planning, and include training exercises before an actual dispatch (e.g., use of an atlas, state websites, etc.).
  • Assign the role of reviewing route plans to Dispatch, including fueling and break locations. For a specified time period (e.g., 2 weeks), Dispatch will monitor:
    • New drivers; and
    • Existing drivers who are unable to meet on-time deliveries or have consistent hours-of-service violations as a result of trip planning.
  • Create and enforce a policy and procedures on potential delays learned of before and during dispatches, including communication between the driver and Dispatch.
  • Train Dispatch on hours-of-service regulations so dispatchers know a driver’s available hours.
  • Communicate roles and responsibilities in your trip planning policy and procedures to drivers, Dispatch, Safety, and Customer Service.