Every trucking fleet relies on its operating authority to do business. In Ontario, it is known as the Commercial Motor Vehicle Operator’s Registration or CVOR. The math varies by jurisdiction, but the principle remains the same; have your interactions with law enforcement been positive or negative? Is your fleet’s behaviour improving or deteriorating over a given time period? Quite simply put, your CVOR is akin to a driver’s licence for the company. Most of us are familiar with the demerit point system that exists in Ontario, some of us have had personal experience. When we are convicted of some traffic offences there are points added to your license based on severity, eventually enough points are accumulated, and there are a variety of sanctions available to the government up to and including licence suspension. The CVOR regime operates similarly, as fleet managers, and safety professionals we must keep a close eye on this data and a proactive management approach should be considered.
The CVOR measures a fleet’s on-road safety performance over a rolling 24-month period. The more miles a fleet travels, the more points it can accumulate over those 24 months before attracting sanctions. There are 3 major areas that the CVOR system pays attention to: Collisions, Inspections & Convictions.
Our drivers have a profound effect on the fleet’s CVOR rating, they are our last line of defence before a vehicle hits the road. When a driver presents a CVIR or ticket, we must investigate the reasons why the driver attracted the ticket in the first place and if necessary, challenge the ticket in court. Drivers and operations staff must be well informed as to what their legal obligations are as well as any recent changes to legislation. Refresher trainings are imperative as in recent years regulations are seemingly in constant flux, especially south of the border.
Driver behaviour must be closely monitored, if a driver receives a provincial offence notice (ticket) or CVIR showing defects or OOS conditions, it is good practice to review that subject thoroughly with the driver before their next dispatch. In doing so we may identify a knowledge gap or some other underlying reason for attracting the ticket. Thankfully, most drivers do not make a conscious choice to violate the law.
Every interaction with enforcement officials both positive and negative is recorded in a fleet’s CVOR level II abstract which should be reviewed periodically. Fleets should consider adopting a robust management system internally which tracks interactions, weighs offence severity, and records corrective actions in-house. By doing so in conjunction with leveraging telematics and camera data (if available) we can begin to identify our fleet’s riskiest drivers and cycle them in for training in hopes of flattening the trend before too much enforcement attention is attracted. It is important to review every Commercial Vehicle Inspection Report (CVIR) and ticket received as well as track the data and corrective action taken. The CVOR analysts in St. Catharines most certainly pay attention and are on the lookout for carriers who seemingly are not living up to their obligations.
Looking at the framework of a driver behaviour management system, lets start with the questions we should ask. Do drivers & operations staff comprehend their legal obligations and potential consequences for non-compliance to both themselves and the organisation as a whole? What happens in your organization when a driver presents a CVIR or ticket? Does it get filed? Is the data tracked and trends analysed? Does it get paid without question? Is it reviewed by a legal professional? Are you even receiving these documents? What corrective action is taken to prevent future occurrences? Keep in mind there is no silver bullet when it comes to modifying driver behaviour in the fleet. We must analyze what is going on to ensure we are solving problems efficiently and identifying underlying causes.
Most trucking fleets have some sort of compliance administration system implemented, typically, they receive and review the CVIR’s and ticket after the fact. Some company policies include taking disciplinary action, other companies refer tickets to legal professionals in the view of challenging the ticket in court. This type of system is not proactive in nature and can come at great expense long-term. Some companies employ field safety staff, they travel around and observe drivers while performing their tasks. Depending on how that program is administered, the field team can be viewed as internal traffic police. Again, this is not the goal either, the goal is to ensure our fleet is knowledgeable, operating safely and timely feedback is shared with management. I believe that every fleet should have some sort of field safety presence. Fleet managers should strongly consider adopting a proactive stance, where problems are sought out and corrected. By doing so, we may avoid attracting sanctions under the CVOR regime. Some of the sanctions available to the MTO under the CVOR regime include: Warning letters, fleet size limitations, permit seizure & cancellation, eventually CVOR cancellation after which a person or related person(s) may no longer obtain a CVOR ever again!
Do not hesitate to leverage technology especially when it comes to engaging highway drivers. Often, it is difficult to service the customer and remove a driver from the board for extended periods of time. Consider using remote meeting software such as zoom, skype or teams to interact with the driver. Consider assigning online training and knowledge verification; be aware that a SME should be available to the driver so that they may ask any questions and seek clarification while completing the online content. Strongly consider limiting the number of unsuccessful attempts before referral to a SME for virtual face-to-face facilitated training if necessary.
In a post-Humboldt environment trucking fleets are attracting much attention from insurance carriers, government stakeholders and enforcement officials alike. Rest assured, insurance companies are paying close attention to a fleet’s CVOR experience and adjusts premiums in kind.