When I discuss accident investigation and the ensuing results with companies or managers, I sometimes hear, “Well, my driver wasn’t cited, so it wasn’t preventable.”  Those who have been involved in any serious claim or litigation and held accountable to some extent even though their driver did not receive a citation will certainly chuckle at this statement, as I do.

Indeed, there is a big difference between criminal and liable. A citation handed out to a driver judged to have violated a documented law holds him accountable for his actions. Liability deals more with perceived contribution to an occurrence as opposed to violating a law. The difference between criminal and civil law is criminal focuses on violations of a specific set of rules, while civil law deals largely with everything outside of the judgment of those responsible for enforcing those rules.

Liability is a term that likely means more to some than others, though it should be important to you regardless of your specific situation because you, the carrier, ultimately pays for those liabilities you have incurred.
In a traditional insurance arrangement that is typical of most companies when an incident occurs, once an operator submits a claim the assumption is it becomes the insurance company’s problem. From that point, the insurance company settles the claim and ultimately, based upon the liability and resulting cost of a carrier’s claims, determines what they expect the carrier’s future losses to be, and adjusts the insurance premium accordingly. (Note: While other market factors can influence insurance costs, premiums typically reflect prior losses and other operational factors.)

In non-traditional or alternative risk insurance arrangements the liability aspect is usually more transparent to carriers. They have a more vested interest in the outcome of claims submitted given the potential to actually earn back some of their premium.

Since increased liability leads to increased claim costs and ultimately a higher cost of doing business, it makes sense that controlling liability is important to controlling costs in the long run.

So, what operational concept is inversely proportionate to liability? Safety programs and processes of course.
A comprehensive and well-executed safety management program will limit a carrier’s liability to the extent possible in any given situation. Many operators learn this the hard way as they grow the company, though small operators who understand the concept can get ahead of the game and ultimately reach a level of sophistication that comes with growth and experience.

Experience tells me the larger a carrier becomes, the bigger the chance to be bitten by the liability bug and suffer its related costs, and most likely to adopt a more robust safety program.

Here are the top liability producers that every operator should address and control.
Subjective hiring — Make sure there is a method in hiring. Establish guidelines for the skills and behaviors a candidate must bring to the job in your company and make them stick.

Lack of or inconsistent oversight — Review all employee errors, violations of company policies, regulations or laws and unsafe driving behavior on a regular basis to determine if anyone poses unnecessary or unusual risk compared with other employees.

Absence of accountability — When an employee missteps the company should inform the employee of the error and take some type of corrective action, whether counseling, training, etc. A framework for disciplinary action is generally included in an accountability system to deter similar behavior in the future.

Insufficient documentation — Without documentation to prove that you routinely conduct liability-reducing measures, you will have a hard time convincing anyone interested that this is a standard practice you actually completed as scheduled. BR

Matthew A. Daecher is president and CEO of Daecher Consulting Group, Inc., Camp Hills, PA.

Two stories overshadowed all others in the bus industry in 2011: the implementation and realization of the new Safety Measurement System (SMS) and the resulting consequences and attention a string of unusually severe motorcoach crashes generated.
While there are probably some operators who do not care much for the new SMS, the consensus from a safety viewpoint is this system does what it was intended to do: identify carriers that have issues managing regulatory requirements. How the system interprets certain violations and ranks operators are still contentious areas, but as a whole the new system provides much more information about carriers and their management than the Safestat system it replaced. More information for both regulators and consumers is a good thing.

The unfortunate fatal bus crashes in the first half of the year sharpened regulator and enforcement attention, which had already been at a heightened level for the last several years. Strike forces across the nation and stricter enforcement of violators have resulted in more passenger carrier vehicle inspections and stricter enforcement of violations than the industry has ever seen.
The results of these accidents also re-focused attention on previously introduced legislation aimed at increasing bus safety and provided basis for new legislative offerings as well. Combined with proposed and soon-to-be federal motor carrier safety regulations affecting the commercial vehicle industry, it is fairly easy to guesstimate what the future will hold for carriers in certain areas.

Seat Belts: While three-point belts on new coaches are a given, it is unlikely we will see a retrofit requirement issued for older coaches. Given the life cycle of coaches and the question of economics versus benefit, the optional retrofit of some coaches would simply be too burdensome. However, I would expect standards issued for those who do choose to retrofit their older coaches.
National Registry of Medical Examiners: This would establish a database of examiners qualified to conduct physical examinations on commercial drivers and likely include some type of educational component for the registered examiners. It should be a non-issue for carriers who already use designated examiners and hopefully are comfortable that they are familiar with the certification criteria, guidance and physical demands of the commercial drivers they examine.

Speed Limiting: This proposal is less of a factor for the bus industry than trucking, but nonetheless may become reality if it is included in legislation under consideration. It would require speeds be limited to 65 mph and would likely include all large commercial vehicles.

Drug and Alcohol Test Database: Long overdue, this missing link in driver history evaluation would limit the chances of drivers with past drug or alcohol abuses not apparent on a driving abstract to get hired and work for most legitimate carriers.

Medical Certification and Sleep Apnea: There is growing indication of a revision to the physical qualification criteria, due mainly to fatigued driving issues and the sleep apnea movement. If sleep apnea screening is mandatory at prescribed body mass indexes, carriers will need to determine if they are willing to pay for such screening for potential hires and even current drivers. It would be wise for operators to begin now investigating options and costs for screening. This will help reduce occupational clinics from potentially benefiting unscrupulously from the need-for-screening diagnosis. Any apnea screening should take place independently of a company’s physical examination provider. Since the opportunity to change the physical qualification criteria is not often presented, it is entirely possible and warranted that FMCSA may review and change other areas of the qualification criteria as well.

Safety Fitness Determination: The continued implementation of the CSA program will include a rule allowing the Federal Motor Carrier Safety Administration to change carrier safety fitness ratings based primarily on a carrier’s SMS data. While we can expect plenty of challenges to this rulemaking, if it does pass carriers would be susceptible to frequent, perhaps monthly, evaluations of their safety fitness rather than only during routine compliance reviews. How do operators prepare for this eventual reality? Make sure processes and procedures to manage regulatory compliance are effective in maintaining BASIC scores below thresholds. Aiming for rankings below the 50th percentile should keep a carrier in good shape.

While there has been non-stop action on hours of service rulemakings for property carriers for some time, there has been little mention of hours of service changes in passenger carrier circles. Currently, a new hours-of-service rule for trucking is being published. While it barely mentions passenger carriers, those in the bus industry should not turn a blind eye to this issue. I believe the intent is to adjust passenger carrier hours of service, and once the trucking side is settled, or at least in a new round of litigation, we will see hours of service changes for passenger carriers introduced. FMCSA is simply giving too much attention to the subject to think otherwise. If and when it does introduce new rules, those who have been ahead of the curve in planning will suffer the least pain. All carriers get calls for trips that just don’t seem right; trips they should not allow. If your operation is growing more dependent on these questionable types of trips it is definitely time to think about diversifying.

Electronic Hours of Service Recorders (AOBRDs): This highly sought technology by enforcement is on its way to reality through one of two methods: rulemaking or congressional action. In fact, it was recently included in highway funding legislation under consideration. It is widely accepted in trucking circles, and whichever way it becomes required, passenger carriers can expect to be included.

While we have yet to see the real benefit of this technology from the perspective of roadside enforcement, it will prevent anyone from fudging handwritten logs. Most current AOBRD systems are manually adjustable, which makes any non-adjustable data such as GPS locations key to their effectiveness.

What should you be doing now? Talk with your vendors of the current technology-based systems on your vehicles to see if they plan to integrate AOBRDs into their systems. Most will. If you have contracts coming due for renewal, evaluate systems from other vendors. Make sure any agreements guarantee their AOBRD system will meet all future guidance regarding enforcement interfaces without incurring additional costs.

Driver Training: An entry-level driver training regulation has been on the books since 2004 that requires training for all commercial drivers with less than one year driving experience prior to July 2004. This regulation was subject to litigation largely based on its required topics, or more correctly, the lack of, and has been routinely ignored and not enforced. A proposal in 2007 to modify the training requirements was unsuccessful. The FMCSA will announce another attempt next year. This is not a bad idea and it will require a more robust training program.

This leaves carriers in two scenarios: hire only those experienced drivers who can demonstrate they have met the training requirements, or provide the training themselves to inexperienced drivers or those who lack the proper documentation. To simplify compliance most carriers will want to provide the training themselves. This means that if you do not have an in-house driver training program, you may want to start thinking about developing one or establishing a relationship with a training school or program which is likely to be able to meet any proposed requirements. BR

Matthew A. Daecher is president and CEO of Daecher Consulting Group, Inc., Camp Hills, PA

By Thomas Bray

The Federal Motor Carrier Safety Administration (FMCSA) CSA enforcement program is not just about the front office and the driver. Naturally, the maintenance facility plays a critical role in keeping unsafe vehicles off the road.

The most common and most severe violations under the CSA grading system cited during roadside inspections point directly to the maintenance team.

Tire tread depth less and 2/32-inch             Severity level 8
Stop lamp violations                 Severity level 6
Brakes out of adjustment                 Severity level 4
No proof of annual inspection             Severity level 4
Defective brake hose/tubing             Severity level 4
Defective/no lighting/ reflective devices         Severity level 3
Oil and/or grease leak                 Severity level 3
Inoperative headlamp                 Severity level 2
Accessories in unsafe condition             Severity level 2
Used, unsecured or no fire extinguisher          Severity level 2

The CSA program tracks a total of 22O maintenance-related violations. Around 170 driver scores are maintenance-related. The violations that create the most damage in the scoring system include:
Out of service vehicle                 Severity level 10
Tire defects                     Severity level   8
Suspension defects                     Severity level   7
Defective lights                     Severity level   6
Steering defects                     Severity level   6
Brake defects                     Severity level   4
If a vehicle maintenance violation results in an out-of-service order, the severity of the violation increases by two.
Any reported violation affects the driver’s CSA score for 36 months; the company score for 24 months.

Catch the small stuff — Vehicles often come under inspection once the officer or inspector spots something visibly wrong — something broken or out of place. Mechanics must repair or correct such easy-to-notice defects before the vehicle hits the road.
Repair and document — A safety-related defect reported by a driver needs to be corrected and documented before the vehicle is driven again. Do not force drivers to operate defective vehicles.

Keep and store accurate maintenance and inspection records — They must be available for at least 12 months.

Implement a documented preventative maintenance program — Prevent problems before they arise — rather than deal with them after a violation.
Qualify mechanics to do the work — Do not perform brake work or annual inspections without proof the maintenance staff can meet the qualification standards for such tasks.
Show proof of inspection — Keep a decal or copy of the annual inspection form on board.

Poor inspection and maintenance reflects in the violations on roadside inspection reports, which affect the scores that carriers receive in the CSA vehicle maintenance category. A conscientious and effective maintenance program for safe and proper working vehicles is the only way to keep the CSA scores low.

CSA scores improve as more time passes with more clean inspections since the last violation.

Thomas Bray serves as Senior Editor, Transportation Management, for J.J. Keller & Associates, Inc.

The year 2011 continues to challenge the passenger transportation industry. The series of crashes that seem perfectly timed to keep the story fresh are having a negative effect on the image of the industry; not to mention the related fallout and pressure from the public, politicians, regulators and enforcement.

Most of the high-profile crashes have involved curbside operators, that segment of the industry long suspected and criticized as being unsafe and non-compliant. These companies tout ultra-cheap fares and non-traditional point-to-point service coupled with vague domiciles, which many believe is a carefully designed tactic to elude the typical inspection processes.

In light of the recent accidents, maybe those doubting these operations are correct. Although a number of time-tested companies have emulated this successful business model, what makes one operator safer than the other? How does anyone know who is safe? These are not rhetorical questions.

Stereotyping is certainly not the proper way to judge any passenger carrying company. I have walked into operations I thought were going to WOW me, only to leave disappointed and scratching my head. I also have walked into operations expecting the worst and seeing the best. The fact is this: Great companies operate on one end of the spectrum and lousy companies at the other. Mediocre, or just plain lucky companies, operate somewhere in between.

Safe is not regulatory compliance. Instead, compliance should be incorporated into the design of a sound risk management program that produces safe as its byproduct. Safe does not mean a carrier has never had an accident; it is what a carrier does to prevent accidents and how they respond to them when they occur.

Safe is an intangible result of beliefs, practices and the making good choices. Nor does Safe mean a carrier does not have any regulatory violations. Rather, it is how they address their issues to prevent infractions from reoccurring.

The media has sensationalized the terrible bus accidents this year, using ammunition courtesy of the new FMCSA Safety Measurement System (SMS). Now implemented nationwide, this new system is receiving its own share of attention, particularly as operators begin to feel the effects of its more detailed measurements and evaluation criteria. The storyline is that unless you understand the regulations and violations, and choose to drill down deep enough into the data to fully understand violations cited against a company, the SMS can be misleading.

Proponents will say this system does well to capture and identify the issues, hence the reason the carriers involved in crashes had BASICs that exceeded the thresholds. It signified them as carriers with significant issues. Opponents claim the system is misleading and penalizes carriers unfairly for “nuisance” violations that have little correlation to crash risk.

Indeed, the correlation between exceeding thresholds and crash risk does not necessarily represent of an unsafe operation. It is only representative of a carrier that did not comply with a written regulation, regardless of the effect the violation had on actual safe operations. And this true representation is really the other side of the story. It provides a look behind the scenes of each transportation provider.

These failures point to a breakdown in the system management process that needs to be in place to limit these violations. It is apparent that many operators developed or executed their management processes only to the point that they consistently managed their major out-of-service violations — the only violations that counted under the old Safestat system.

Frankly, this was not much of a challenge. It only required knowing the most serious violations and focusing efforts in those areas to prevent them. They simply did not bother with violations they considered unimportant. Now the new SMS requires a more comprehensive management system to address all violations, a challenge and change in mindset many good operators now face.

If you find yourself with high BASIC percentile rankings due to these “nuisance” violations, it is time to review your system management processes. Don’t blame the new system; look at the regulations you have not complied with and figure out why your management process didn’t correct your non-compliance when it occurred. Fixing the processes to address these matters will make a better company. And, right or wrong, outsiders will perceive you as a safer company.

Matthew A. Daecher is president and CEO of Daecher Consulting Group, Inc., Camp Hills, PA.

Photo 1: A sample of the removed main bearings makes a case for single multi-viscosity engine oil.

In an earlier column [BUSRide, March 2007, Safety and Maintenance; A surprise find in the world of tribology] I discussed our use of single weight engine oil I use in four-stroke cycle engines, specifically the DDC S-60 motors. This column is in response to the comments BUSRide readers posted to that article.

Most of the comments were from “bus hobbyist” with little or no experience with DDC engines. Comments ranged from “Who cares?” to an “urban myth diagnosis.”

The express purpose of that article was to bring to the attention of professional motorcoach operators that despite Detroit Diesel Corporation (DDC) recommending 15W-40 wt (multi-viscosity) engine oil in the S-60 engine, we use 40wt (XHD) oil with no problems at all. I called DDC and asked if that would create warranty issues, and they stated it would not. Now 14 years later and five million accumulated (collective) miles, I am happy to report that the project was successful — and I can now show BUSRide readers the direct proof.
Here is my reason for using the 40wt (XHD) oil in the Series 60 engines — as well as my Cummins and Ford PowerStroke engines. In 1997 my entire fleet featured DDC Series 92 and 71 engines, for which Detroit Diesel mandated the use of single weight engine oil to prevent catastrophic failures. My fear was we could make a catastrophic mistake of our own during maintenance by adding the wrong oil to a particular engine. To simplify this, and to eliminate the risk, I decided to go with single weight oil across the entire fleet regardless of the engine type or its manufacturer.

Photo 2: The connecting rod bearings are largely undamaged and show very little wear relative to their mileage and age.

Yes, I was aware, and still am, that 40wt oil may have start-ability issues in the cold. But hold on. I live in Chicago, the city that claims to have invented winter.
Although we have 100 percent indoor parking, to this day we have never experienced a problem related to temperature with this oil.
Simply stated, a multi-viscosity oil use spolymers to modify its behavior. As the temperature changes it actually acts as two different weight oils. The polymers are coiled when the oil is cold, which allows for better oil flow through the engine. As the temperature increases, the polymer chains unwind to prevent thinning of the oil.
Some examples of the success of 40wt oil in a four-stroke cycle engine are our PowerStroke engine with over 500,000 original miles. Our four original DDC S-60 engines have a combined total of 172,000 engine hours and 4.3 million miles.
As a preventative maintenance measure, we recently changed the main and connecting rod bearings on the four original S-60 engines. Photo 1 shows a sample of the removed main bearings. Photo 2 shows a sample of the connecting rod bearings. As you can see, these bearings are largely undamaged and show very little wear, relative to their mileage and age.
Photo 3 shows a main bearing from an engine with an oil pump-related problem. The damage is not to the extent the bearing would be spun. During the engine-hours the oil pump was manifesting its failure, the 40wt oil was providing additional protection that single weight oil would not have.

Photo 3: The damage to this main bearing is not so extensive the bearing would be spun.

So one conclusion is that in addition to long term engine protection, single weight oil can also provide protection during internal engine failures. Lastly, single weight oil delivers another benefit during lube oil dilution. During a failure related to the fuel system as diesel fuel is entering the crankcase a single weight oil will assist in maintaining oil pressure until technicians can determine the cause of the failure fuel issue and make the repair.
Operators should refer to the owner’s manual for details, and discuss with the manufacturer if single weight oil is appropriate for use in their engines.

Christopher W. Ferrone is president of Americoach Systems Inc., Glenview, IL, an engineering firm specializing in transportation, technology, analysis and safety.

Figure 1

Regular readers of BUSRide have probably seen the plethora of industry talk in advance of the implementation of the CSA 2010 Safety Measurement System (SMS). While I’m not one to crow, “I told you so,” now that we are only a few months into the new measurement system, it appears the chickens have already come home to roost.

You may recall in one of my articles last year I warned that the new system was less forgiving — and that the time was near to “sweat the small stuff.” Well, that time came on March 12, 2011.

That was the morning that a coach returning from a casino run in Connecticut rolled on its side and was literally split in two by a highway signpost structure. As with most horrific accidents, this was indeed the perfect storm with the worst possible consequences. To date, fifteen passengers were killed and countless others seriously injured and traumatized.

In my previous article I warned that “the small stuff that gets written up during terminal, destination or en-route inspections will count against a carrier’s score in any given BASIC.”  This incident has clearly emphasized this point.

The March 12 accident, along with another multiple-fatality accident three days later, resulted in the first high-profile interactions between the press and the SMS. And neither the press coverage nor the SMS design painted a favorable picture of the Company involved.

Let me first say that I don’t know the bus operator in any detail (that I know of anyway). I am not knowledgeable of their practices or even detailed violations. But, considering how many companies I do know well, and their SMS statistics, it’s fair to say that what the media has penned and what may be the truth could be two completely different stories. And that is why any operator should be cleaning their chicken coup.

SMS data for the operator involved indicates Behavior Analysis and Safety Improvement Category (BASIC) scores in two of the seven BASICs. The carrier score in one BASIC, Fatigued Driving, indicates that the threshold of the 50th percentile has been exceeded, and thus, the carrier is noted as having “exceeded the intervention threshold” via a warning symbol. The carrier overview, as reported through February 25, 2011, is depicted in figure 1 above.

If you were a reporter covering this story and saw this, you’d think you found the golden egg. Indeed, there were a lot of reporters who thought they had found that egg; story after story talked about the Company’s problems with fatigued driving (and maintenance) – especially considering the post-crash implications that fatigue may have been the cause of the crash. The articles focused on the multiple citations for driver fatigue issued to the carrier and trumpeted their ‘alert’ status.

Here’s the headline from just one – “The company whose tour bus crashed on Interstate-95 at the Westchester-Bronx border killing 14 passengers has been cited for fatigued driving often enough in recent years that it was put on alert by the federal government.”

Realizing a goal of journalism is to get folks to read the article, I think I would have written the articles in exactly the same manner. And, if anyone involved in a serious accident would expect nothing less.

With the new SMS, it’s all right there on the carrier overview. Even if you chose to look deeper, by actually looking into the violations under the Fatigued Driving BASIC, you may interpret it the same way. You see, whether or not the violations in the Fatigued Driving BASIC are actual hours of service violations or simply form and manner log violations, they are all serious violations, which result in fatigued driving to anyone who doesn’t know much about the regulations, the citations, or the business.

The qualifiers describe just about everyone who hires you to provide transportation service, as well as the general public who reads the paper and watches TV, and who may one day think of hiring a bus operator.

The rest of the story?  One 10-hour violation, two logs not current violations, and two form and manner violations. Under the old Safestat system, only the 10-hour rule counted against your score; under the new SMS, they all do. The violations those in the industry have typically looked at as ‘the small stuff’ are now a lot bigger and can negatively affect your image and business. So, until EOBRs become reality and (theoretically) take away a lot of those small log violations, you have your work cut out for you in keeping the roost clean. Oh yeah – don’t forget about the other BASICs too – and ‘small stuff’ in each one!

Matthew A. Daecher is president and CEO of Daecher Consulting Group, Inc., Camp Hills, PA.

Photo 1: The Delta-P sensor removed for a closer look.

As everyone knows, diesel engines now come with an Exhaust Gas Recirculation System (EGR) to help with pollution through the reduction of NOx. It does this first by adding exhaust gases to the air intake side of the engine to lower the combustion temperature. Adding CO2 to the intake increases the heat capacity and lowers the combustion temperature. It also reduces the oxygen content of the intake air due to the addition of the CO2 from the exhaust gases. Both EGR actions reduce the production of NOx.

What also now comes with the new engines are more difficult electronics to manage. The two most typical EGR failure modes are the EGR valve itself and the differential pressure Delta-P switch.

So far at American Sightseeing we have only had to change one complete EGR valve. We have changed quite a few Delta-P sensors on both the Detroit and Cummins engines.

Recently, I spent a good deal of time diagnosing an EGR problem that created an overall engine performance problem. The bus would not reach its maximum programmed road speed and it would buck violently just at the onset of acceleration to reach maximum road speed. This produced the typical E.G.R. fault codes.

However when tested, the EGR itself and the Delta-P sensor checked out fine.

PHOTO 2a: The plastic adaptor plate that directs the flow of exhaust to the sensor had a broken pipe. PHOTO 2b: The break in the adaptor place created a leak in the system that the ECM could monitor.

Removing the Delta-P sensor for a closer look (photo 1), I found the plastic adaptor plate that directs the flow of exhaust to the Delta-P sensor had a broken pipe (photo 2a & b). This, of course, led to a leak in the system that the ECM could monitor. We installed a new part and the engine ran fine, allowing the bus to reach maximum road speed without the bucking and black smoke.

One key point to remember: when you change out this part with a new one, make sure you clean out the two small hoses connected to the adaptor plate to eliminate any remaining broken debris remaining in the hoses. Otherwise the hoses will clog and result in a consequent code and problem with the engine. For your reference, DDC upgraded the old part and gave it a new part number. For DDC S-60 engines, the old part number is 23535850. The new part number is 23536986. Remember, when ordering parts, always use the engine serial number. They are only $17, so buy a few extras. I am sure you will use them just as we do in our shop.

2010 did not disappoint as an eventful year in the passenger transportation industry. The inevitable seat belt regulations were announced, and in December the long-anticipated Safety Measurement System, better known as CSA 2010, became reality for all operators. The sluggish economy continued though glimmers of hope and positive thinking about a rebound were prevalent throughout all industry segments.

This year promises more regulatory changes to the landscape that will affect motor carriers. New Hours of Service rules are in the works along with electronic on-board recording (EOBR) regulations. We’ll see new Entry-level driver training rules and maybe even some changes to the physical examination/medical certification regulations.

Without knowing how these will affect current operations, companies will undoubtedly be busy digesting and adapting to necessary changes in operations.

However, considering the delayed implementation of many of these new or soon-to-be regulations, the most immediate concern involves adjusting to and managing the new Safety Measurement System (SMS) carrier scorecard. Those operators in operational test states or those who took advantage of the data sneak preview offered by the FMCSA likely have their game plan in motion. Those who didn’t bother to check their data ahead of implementation due to a false sense of security provided by the old Safestat system may be in for a rude awakening.

With the publication of the SMS data, many carriers may have already made their New Year’s resolution to improve their statistics in certain BASICs. However, while this resolution may be very critical to some operators who have not been minding the store, I propose a different resolution.

I suggest a resolution that involves the other side of carrier operations — vehicle maintenance. More specifically, a resolution involving the working environment in which an operators perform their maintenance activities.

There are obvious reasons to pay attention to this particular area of maintenance operations — as well as some not so obvious reasons. Obvious reasons include workplace injury management and compliance with workplace safety regulations. The not so obvious include employee morale and company perception.

Every operator knows the potential negative effect workplace injuries have on profitability.  Though not many serious injuries actually occur in the maintenance shop, the fact remains it is   a dangerous area where the potential for serious injury is always present.

When it comes to regulatory compliance, it is well documented that OSHA inspection staffs have increased under the current administration. While transportation operations have not been one of OSHA’s main focus areas in the past, couple more inspectors with the fact that OSHA is required to investigate any employee complaint, and it becomes a winning formula for increased scrutiny in all industries, including the passenger transportation industry. Finally, ask any operator who has been the subject of OSHA scrutiny and it is easy to understand why bus and coach operators should pay closer attention to workplace safety regulatory compliance.

If the obvious isn’t convincing enough to adopt my proposed resolution, then consider the not so obvious reasons.

I have been in many shops in my time, and they range from the proverbial New Year’s resolution “eat off the floor” to the truly incredible, and not in a good way. The actual state of the facility is usually dictated by the habits of the shop/fleet manager who is generally in charge of the upkeep.

If it’s a dirty shop, it may have an old-time – though competent – mechanic, who’s used to such an environment that he has probably operated in for countless years. However, his belief that a shop is “supposed to look that way” may not resonate with other mechanics working under him. Though I don’t have any studies to reference, I can’t imagine that employee morale and productivity is better in a disorganized and dirty shop.

Also, considering the difficulty in finding qualified technicians these days, the appearance of the shop and working environment it provides could be a deciding factor for an applicant deciding where to put his or her skills to work. Furthermore, it may be a factor for current mechanics who may be considering looking into other employment opportunities for whatever reason.

Looking at it from another perspective, what if your shop appearance was a factor in a customer’s decision to use your company versus another? While shop appearance is not typically used in marketing, and customers do not typically see the shop – even those who do visit the offices – there’s not any reason it couldn’t be used to differentiate your operation. Ask yourself – all other things being equal – would you choose the operator with a clean and organized shop or one with a dirty shop? Maybe a more relevant question: If your biggest customer saw your shop, how do you think it would affect their perception of your operation?

Whatever the state of a maintenance facility, its condition is ultimately the responsibility of senior management. To allow it to exist in whatever state confers their implicit approval. Maintaining a proper and compliant environment in the shop ultimately comes down to commitment and accountability.

Matthew A. Daecher is president and CEO of Daecher Consulting Group, Inc., Camp Hills, PA.

Knowledge comes from both direct and indirect observation. Indirect observation teaches by showing what others have failed to do. BP’s failings at numerous levels to maintain safety on its drilling rig are a perfect example. The company did not have a clear plan or even a secondary plan. In fact it appears that the company even failed to heed the warnings signs in the drilling process.

Every operation has someone in charge of safety. While the safety department has the responsibility of handling compliance, training, testing and discipline as necessary, the begging question is if these activities actually ensure authentic, practical and tangible safety measures.

I believe they do. But I also am always looking for better ways that improve my safety program.

Safety that works involves building a collection of small viable actions in a process that is ongoing and always changing. Each action by itself may not appear safety related, but as one part of the total collection, each step such as vehicle inspections, preventative maintenance, regulatory compliance, driver control measures, training and common sense all add up to what I call true safety.

Morning start

The operative term here is add up. I start every Saturday morning at the garage at 3 a.m. This gives me extra time to fine-tune my safety program without interruption. I start with over-pit inspections to ensure the reliability of the buses going out on the highway that day. While some may view reliability as being sure the vehicle is useful for the day, utility is very low on my list of items to worry about directly. Certainly reliability is important. An unreliable vehicle always compromises safety when it fails in some way. Reliability is a safety function in my system.

Unusual noises coming from the vehicle usually indicate a problem. A sense of smell also serves as a useful tool. Walking by a bus that has the odor of gear oil usually indicates a hub seal is leaking. Hearing an odd noise or detecting an odor and not checking it out represent poor safety behavior. Caring is the most basic element of true safety.

Don’t be a robot or merely a box checker. Take the safety department to a level of care where everyone knows to stop and look for problems at their least provocation.

Once the buses move to the ready line for drivers to pick up, I speak with each one individually to check their fitness for the day. I want drivers to be wakeful and alert, arriving on time and not rushing to make a diving clock-in. Drivers rushing for the clock are most likely late for their report time, and subsequently late for their order — not the mindset true safety. The drivers’ behavior and best practices are paramount. Personal appearance and mental attitude figure strongly in a truly safe operation.

We discuss the weather and the effect it will have on driving that day, and have a solid plan to deal with the conditions. A safe carrier gives its drivers the option and even encourages them to stop driving as the situation may require.

We review the destination or event for the group and assess the passengers. Are they children, adults or teens? In the event of time-sensitive events with a starting time, the drivers receive instructions to not let the passengers influence their operation of the bus, or where to position the bus for unloading and parking. Passengers often try to control the driver for their personal benefit. The driver is in control and must be the only person making the decisions.

Instruct the driver to not allow a person at the venue provide assistance or direction with backing up or close quarter maneuvering of the bus. Assume ground personnel are not qualified to assist the driver with these tasks. The driver has command of the bus and should not take any type of direction from anyone else. If the situation requires assistance, the driver should get out of the vehicle and have a look for himself.

We recently had a driver back into a tree causing damage to the bus. When he returned to the garage I interviewed him to discuss what had happened. In classic fashion I determined three minutes of unrelated detail. Once I made it clear that this was a problem for me, he admitted he allowed someone back him up around a car that was in the way. I informed him that this accident was chargeable and preventable due to the fact that he let someone control him as opposed to being the person in full control of the bus.

Do not let the current level of safety lull the company into a false sense of security. This is not to suggest the safety department is not doing its job, but checking boxes and filing paperwork is hardly what we are talking about here. True safety is a process of constant attention, evaluation and re-evaluation.

Christopher W. Ferrone is president of Americoach Systems Inc., Glenview, IL, an engineering firm specializing in transportation, technology, analysis and safety.

I recall a great episode from Seinfeld where Jerry muses over the wear of the tires on his BMW, wondering, “Where does the rubber go that wears off the tire?”

This is truly an enigma. Who sees tire material from wear on the roadway? On the other hand, attend any Indy Car race and the small balls of tire rubber collecting on the track are very noticeable. As tires wear the material does in fact deposit onto the roadway, but it goes undetected because it happens so gradually.

It’s easy to take tires for granted. But, like Jerry, it’s good to stop and remind ourselves of all that goes on with a set of tires.

The mechanical function of the tire casing is to contain the air pressure that supports the vehicle load, assure the function of the suspension by absorbing road irregularities, resist lateral drifting and centrifugal force, and transmit the torque necessary to move and stop the vehicle.

A number of factors affect the condition of a tire: the nature of its application for line haul, stop and go traffic or mix of both; the number of axles on the vehicle, overall maintenance of the tire during its life cycle and especially inflation pressure.

Suspension and alignment

The major suspension and alignment adjustments control tire wear and condition. Technicians must monitor toe-in and toe-out, caster angle and camber angle. However, not all vehicles have a front axle that allows the control of these adjustments. Therefore it is of vital importance to know the type of front axle on all vehicles and the allowable adjustments.

The most controlling factor in tire wear may be its inflation pressure. For every 10 psi a tire is under-inflated, the life cycle of the tire is reduced by 10 percent. The amount of air in the tires affects the weight distribution between the wheels. An under-inflated tire does not carry its share of the load. This condition affects torque, traction, steering, alignment, braking and cornering, and may cause pulling from side to side.

A tread separation usually means the tread has separated from the casing, disconnecting from the outermost steel belt. The outermost steel belt has become detached from the lower steel belt and the rest of the casing. Tread separation can be the entire tread or simply a section of the tread. This usually occurs later in the life of the tire casings unless a traumatic event has occurred.

A hole or some sort of damage that starts in the sidewall is normally the cause of a sidewall failure. Curbing the tire, striking a sharp object, age cracking and other structural issues all contribute to sidewall failures.

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It is my belief that operators should never use retread or recapped tires on a motorcoach for any reason. When they experience failure they can damage the vehicle with the delaminated tread that is rotating with the tire casing, just as a circular saw would cut air hoses and suspension bellows during this type of failure.

The four to six year mark

Typically the life cycle for a tire is four to six years, which corresponds to the average useful life of a tire casing. Despite the condition of the tread, tires should be taken out of service when they reach the four to six year mark. The DOT number embossed on the side of the casing notes the age of the tire. The last three numbers indicate the week and year of manufacture.

Technical staff must understand what affects tire condition and respond proactively. They must routinely monitor wheel alignment, inflation pressure and suspension adjustments in order to maintain proper tire performance. Additionally, if the vehicle has a steerable tag axle, technicians must also monitor those components to ensure the expected life cycle for the tag axle tires.
Bus and coach operators should always refer to CFR 49, Appendix G for tire out-of-service regulations.

Christopher W. Ferrone is president of Americoach Systems Inc., Glenview, IL, an engineering firm specializing in transportation, technology, analysis and safety.