The Carrier Safety System’s Purpose: Compliance and Beyond

Introduction

Welcome to article two of ten in this series on trucking company safety systems!  In the previous article, I explained what the purpose of a system is and how safety management systems give companies the ability to better meet their objectives through regular and consistent effort.

In this article, I will be describing the purpose of the safety management system in a general trucking company.  While the methods used by a carrier to manage safety and compliance objectives vary greatly, many of the outcomes are legislated requirements with which carriers must demonstrate compliance.  As a result, major themes within safety systems will show considerable similarity between different organisations.

The Purpose of a Carrier Safety System

As mentioned above, carriers in Alberta must comply with the same legislation as their competitors.  While not all transportation legislation applies to all types of operations, carriers that perform the same type of work will have very similar requirements in terms of compliance.

Even carriers that are based in different jurisdictions have similar safety and compliance requirements.  For example, consider a dry van full truckload carrier based in Alberta compared to a dry van full truckload carrier that is based in Montana.  Montana-based and Alberta-based carriers have different requirements for driver qualifications, insurance, hours of service, and weights and dimensions.  But, each jurisdiction still has legal requirements for driver qualification and the other items listed; it is just the specific criteria and details that are not the same.  As a result, the safety systems in each company can be very similar even though their metrics will differ.

The following subsections explain the main purposes of the safety management system at a trucking company.

Compliance

Oftentimes, safety systems are thought of in terms of compliance with the law.  The law sets the minimum level for safety performance and carriers are free to exceed the level of safety prescribed by the law.  However, they are not free to be non-compliant.

Striving for compliance with transportation regulations should not be considered the same as striving for safety.  Safety laws exist to provide business owners and managers with a framework for establishing safe company operations, but these laws are not meant to be the cure for all problems associated with risk, worker health, and safety.

Furthermore, a lot of transportation compliance has very little to do with safety.  For example, consider the International Fuel Tax Agreement (IFTA).  An IFTA membership is meant to simplify the payment of road use taxes by carriers that operate in multiple Canadian and American jurisdictions [1].  Carriers that have an IFTA membership must comply with the rules regarding proper IFTA reporting.  This is important: non-compliant carriers can face penalties.  However, a carrier’s system for IFTA compliance does little to keep drivers and the motoring public safe.  It is only a method of complying with tax regulations.

Carrier safety systems are often pressed into service for compliance with regulations that do not directly pertain to worker health and safety.  This is because transportation companies are heavily regulated, and employees who are good at researching and interpreting legislation are necessary throughout the operation in areas outside of safety.

Occupational Health and Safety

Occupational health and safety (OHS) legislation is concerned with protecting the health and safety of workers.  In Alberta, a trucking company may be regulated by Provincial OHS rules or Federal OHS rules; this is determined by the operating status of the carrier [2].

Complying with transportation regulations like border crossing requirements and complying with OHS legislation are tasks that are quite different yet are often managed by the same people and systems.  This is especially true for smaller companies where office employees are required to fulfill a variety of roles.

In general, OHS requirements for trucking companies are the same as they are for other companies.  Trucking companies must conduct hazard assessments and implement controls to protect the health and safety of their workers; trucking companies are also required to pay for Workers’ Compensation Board (WCB) coverage and may be able to receive WCB premium reductions through the acquisition of a Certificate of Recognition (COR) which demonstrates a minimum standard of performance for the carrier’s safety system.

In the trucking industry, OHS requirements and transportation-specific safety requirements are often heavily segregated.  Due to the complexity of complying with transportation-specific requirements (like those listed under Alberta’s Traffic Safety Act), carriers may sometimes neglect their OHS requirements.  Remember, even though transportation safety is complicated and requires effort, there is no excuse for non-compliance with OHS requirements: the safety system must tend to all applicable safety regulations.

Transportation Safety

In Canada, transportation safety standards are created and published by the Canadian Council of Motor Transport Administrators (CCMTA) and then used by the provinces in the creation of their jurisdictional transportation legislation [4].  There are 16 such standards published by the CCMTA, and all together they are referred to as the National Safety Code (NSC).

NSC is a common acronym spoken and heard by those in Alberta’s trucking industry.  You may hear a vehicle described as an “NSC vehicle”; this description is generally meant to indicate that the vehicle in question is large enough to be regulated by the NSC standards as they are legislated by the province in question.  Other times, a company that performs non-transportation-related work may grow to the point where they decide to purchase one or more NSC vehicles; at this point, the company becomes a carrier, and all of the NSC regulations apply to their operations.  It is not uncommon for companies to learn this the hard way when one of their vehicles is stopped by roadside commercial vehicle enforcement and tickets are written for a lack of compliance with rules of which management wasn’t aware.

A carrier’s safety system must meet all of the requirements for NSC compliance.  Unlike compliance with tax or border regulations, NSC regulations are primarily concerned with the safe operation of commercial vehicles and the protection of lives and property.  Carriers should not only comply with the minimum NSC-related legislation that applies to their operations but should aim to surpass these requirements in an effort to protect their workers and the general public.

NSC versus OHS

Like occupational health and safety (OHS) regulations, NSC regulations are designed to provide protection for the physical safety of people.  However, trucking companies are different from many other companies because a considerable amount of their work is performed in public spaces where non-worker drivers and pedestrians abound.

One professional friend of mine, Jeremy Woolward, speaks passionately about the difference between a carrier’s OHS obligations and its NSC obligations: “the occupational health and safety part of the safety system is to protect the company’s workers; the National Safety Code part is there to protect the public” [5].  This is an important thought: trucking company owners and managers are responsible for safe operations in a working environment where they have relatively little control over workplace hazards than managers of a controlled environment might have.

In short, a carrier’s safety management system must consider OHS and NSC responsibilities and mitigate risk from hazards that occur in a more controlled environment like a private truck yard and the risks present in a largely uncontrollable environment like a public roadway.

Risk Management

Another important purpose of a carrier’s safety management system is the management of the organisation’s risk from incidents that can occur involving workers, drivers, and vehicles.  Some might say that, when you really get down to it, risk management is the only purpose of any safety system.

Present-day trucking companies that are not self-insured face incredible costs related to insuring their fleet and drivers; self-insured companies are still not immune from the repair costs and possible lawsuits that can result from a collision.  Reducing the risk of collisions and other unsafe actions not only benefits health and safety, but it also financially benefits a company when it comes time to renew insurance coverage.

Summary

The above sections have provided an overview of the main purposes of a carrier safety management system.  Without a doubt, such a system must cover many different elements of the company and should strive for more than compliance. 

As this article series progresses, I will dissect different components of carrier safety management systems and take a look at how they all work together to serve the company and its workers.

References

1 - “International Fuel Tax Agreement (IFTA)”, Government of Alberta, accessed September 7th, 2021, https://www.alberta.ca/international-fuel-tax-agreement.aspx

2 - “Commercial carrier operating status”, Government of Alberta, accessed September 7th, 2021, https://www.alberta.ca/commercial-carrier-operating-status.aspx

3 - “Get a Certificate of Recognition (COR)”, Government of Alberta, accessed September 7th, 2021, https://www.alberta.ca/get-certificate-recognition.aspx

4 - “National Safety Code”, Canadian Council of Motor Transport Administrators, accessed September 7th, 2021, https://www.ccmta.ca/en/national-safety-code

5 - A paraphrased quotation from an early-2021 phone conversation between the author and Jeremy Woolward, an Albertan safety professional who was working for a Calgary-based carrier at the time.