Everyone who knows transportation and transportation management realizes the emphasis and role that FMCSA plays across just about everything in your organization. Whether it is HR, Legal, Claims, Maintenance...whatever, FMCSA has its controlling hand of FMCSRs involved. It also won't take you long in your transportation management career to understand why FMCSA asserts most of your problems, and theirs originates in the HR or hiring department. Most of those problems can be avoided at the onset of a hire. Especially a driver hire. For instance, the FMCSA Pre-employment Screening Program (better known as PSP) has determined that companies have reduced their crash rate by 8% and driver out-of-service rates by 17%. While not all carriers utilize the PSP, it emphasizes the importance you should place on hiring the safest, most responsible drivers available. I recommend using a staged approach to hiring drivers, or employees in general, as it provides the opportunity to eliminate unqualified, problem candidates early on in the process. This will save you time, money, and effort and allow the devotion of resources to the best candidates.
Before we start, especially if you're relying on terminal managers to do your screening, avoid the "Check the box" mentality. Hiring managers get in a hurry, they need a seat filled, and they check the box. Many employers provide checklists, as do most DQF tracking systems like Tenstreet, LLC. The trouble with checklists is people often check the box to validate the task is complete. The follow-up to that is, was it reviewed? Often times it's there, present, but has the information been validated or even reviewed? In one case we saw a driver who completed a post-offer agility test through WorkSTEPS. WorkSTEPS advised that the candidate was not recommended for hire based on their inability to physically perform necessary driver functions due to bad hips and knees. The candidate was a fall hazard, a comp claim in the making. The box for the agility test was checked verifying a result was present in the file but didn't read it. On the first day of work, new hire fell off the vehicle and never worked a day costing hundreds of thousands of dollars in a comp claim. WorkSTEPS may not be legally required but serves as an amazing program that determines if a driver is fit or physically capable for duty not just medically qualified for work via a med certification. This assessment does cost but think of it as an investment hedging against future claim costs and to determine how much the potential hire will cost you and your company in the long run. Don't check the box. Validate the content. It's there for a reason.
Stage 1 - Application. A driver's application is also FMCSR prescribed since it is a safety-sensitive function and in some cases State specific. An application can expose a variety of information providing insight that would determine whether this is the best candidate. Part of this application review process is the employment history search and ensuring there are no gaps in their employment history. The last portion of this is a part that makes Tenstreet, LLC a true time saver, employment verification requests. You have to send them to previous employers in some cases and if you're on the receiving end of the process for a previous employee, you MUST respond to it. Tenstreet automates this process for you and you're able to schedule resending of the electronic request if you receive no response through their "Xchange" process. A lot of screening content you will collect will tell you matter-of-fact data regarding the person or their identity, much of which could be arbitrary or false. Employment verifications are the one place where past employers can describe and articulate actual performance-related data. Were they terminated? Did they show up for work? Were they injured? Would you hire them again? Are they on time or do they call out for work? Get the big picture from people who have work-related experience with the candidate.
Stage 2 - Verification of Initial Eligibility (Barrier Review) - So you like the candidate. Let's make sure we rule out the barriers to employment first. I like to start with what I call the barrier review. This will ensure that everything they are absolutely required to have to fill the position is present and verified. A Driver's License is a good place to start. While a copy of the physical license is required you want to ensure that you have a reputable vendor to run both pre-hire and annual Motor Vehicle Records for the driver in the event they're hired on. Jim Hulburt who runs Partnership Screening International in Richmond Virginia does an amazing job and I prefer him and his personal attention to his customers. MVRs can be used to validate if the driver has a license in more than one state, that their license is valid for both personal and commercial needs, that they're medically self-certified with their state DMV and finally it will advise on what their accident and citation history looks like. You'll need to ensure this was done within thirty days of hire.
Moving on, if they are a CDL holder, the Clearinghouse query is required. This ensures they are not prohibited from hire. Prohibitions from hire occur when they have tested positive for drugs and/or alcohol for another motor carrier or that they have not completed SAP. Most respectable carriers require a PSP query. Some don't require it because it would restrict their hiring pool too much which would create further bottlenecks to seat filling. That's exactly the purpose. While an MVR will show convictions and accidents and citations, a PSP will show everything convicted or not, even warnings the driver has received at the roadside. I've seen drivers with perfect driving records but that have PSP records three pages long. They're not the same.
Stage 3 - Conditional Screening - Ok you really like this person and they're qualified at the barrier level. You've made them a conditional offer so now we can get more intrusive. Medical questions can be asked, etc. I mentioned agility testing earlier and while it isn't required agility testing or medical questionnaires can be a lifesaver in the world of rising fraudulent claims and nuclear verdicts. Medical certifications are required for those, not in an exempt status (That's a different topic). Medical certifications come in 3-month, 6-month, 12-month, and 24-month certifications. Typically anyone with a valid card generally is eligible for hire. You may decide as a matter of policy that you require a minimum one-year certification. Totally up to you. Part of the medical certification process is that you verify that the medical practitioner completing the examination is in the national registry of medical examiners. Not everyone can complete driver's exams. Next, you'll need a drug test. A certified result must be present before you can dispatch the driver. My preference is HireRight. If there is a problem they employ great, attentive reps like Sheila Lauterbach who can keep you straight. They can also facilitate your ongoing substance abuse and alcohol screening needs such as reasonable suspicion, random program management, and post-accident testing.
At this point, you have received all your documentation and you'll need to ensure you have reviewed it all and that it is a solid hire. Your last stage will be ongoing screening. Drivers are no longer required to complete a Certificate of Violations but they are required to have at least a 1-year review of their MVR. I still encourage the completion of COVs when you run an MVR. It's a validation tool you can use to ensure that the driver is up front and that the hiring manager is checking them against the MVR. Depending on your driver base or policy, you may decide that running MVRs more frequently is the right decision. At any point, a driver may have a suspended license for something like child support enforcement. Without the review, you'll never know. There are also a host of other forms I encourage. For instance, on-duty and multiple employer verification forms, CDLIS acknowledgment, drug and alcohol disclosures and consents,
It is vitally important to have vendors you can rely on for appropriate screening management. I have built integrated systems with every vendor you see tagged here and the flow is inclusive. No need for platform fatigue by logging into thirteen different vendor sites, just integrate it all and let it go. With LogRock Inc. entering the IT compliance space I expect serious competition in the future.
While Driver Qualification Files and appropriate screening are required in most, if not all cases of driver hire, it's more important now than it has ever been. We live in a highly litigious society and nuclear verdicts are becoming more common. Whenever you have an accident or litigation involving a driver, the plaintiff's counsel will ask for several things. The first of which is usually the driver qualification file. They'll want to review to ensure the driver was properly screened, they were qualified, and they were trained. While they'll also ask for maintenance records and a host of other information, the most important starting point is the driver's qualification and screening. The question will be, could this have been foreseen, and did the company negligently entrust this vehicle to someone they shouldn't have? Don't let this happen to you. Even in a pinch, choose the best candidate to ensure your future and the future of your company remains a success.
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