amic - srs.professionalsafetyconsulting.com

Truck Fleet Risk Assessment, Revised 1-16-20 ©2020, Professional Safety Consulting, Inc. SM This report covers only the areas indicated on this form. Other conditions, hazards, deficiencies, or discrepancies not otherwise indicated may exist. This survey is advisory in nature, with the sole purpose of assistance in identifying those areas of potential concern, for which the management of the “insured” indicated above is ultimately responsible. This survey does not warrant, guarantee, or otherwise certify compliance with laws, regulations, requirements, or guidelines of any local, state, or Federal agency or legislative and/or regulating body.

[email protected] | 800-659-3025

Truck Fleet Risk Assessment Blue Ridge Specialty - AMIC

Survey Date: July 31, 2020 Surveyed by: James R Desmond, CDS Risk Name: Flat Creek Transportation, LLC

Risk Contact & Title: Phone #:

Email Address: Physical Address:

Mailing Address:

Tanya Merritt, Safety Director 334-565-3534 [email protected] 21477 W State Hwy 52 Kinston, AL 36453 PO Box 349 Kinston, AL 36453

Policy #: Effective Date:

Underwriter: Agent/Producer:

US DOT #: MC #:

EEX-BRS0008 7/17/20 Mike Gordon Russell Huston 1240983 488249

Overall Rating of Risk:

Above Average Average Below Average Not Recommended

Discussed Platinum membership Assisted insured with initial login Provided toll-free number for assistance

Enclosures: Photos Drivers List Equipment List Policy Manual Passenger Policy Brokerage Agreement Owner/Operator Contract Other: SMS Profile & Driver Hiring Standards

Major Concerns Current FMCSA rating of Conditional Unanticipated Exposures None Underwriters Special Instructions Please have the Loss Control Inspector contact the retail agent prior to scheduling the inspection. (Russell Huston with The Campbell Group, an Acrisure Agency Partner. Phone number is Office (423) 497-5005 Cell (423) 322-5230. Email is [email protected]) - Completed Progress with Previous Recommendations or New Business New Business

mailto:[email protected]

Risk Name: Flat Creek Transportation, LLC Truck Fleet Risk Assessment Policy #: EEX-BRS0008 Survey Date: July 31, 2020

www.professionalsafetyconsulting.com

COMPANY OVERVIEW OPERATIONS & AUTHORITY President: Charles Patterson Safety Director: Tanya Merritt Carrier Type: Authorized For-Hire Private Exempt Ownership Involved In Daily Operations?: Y N Y N Operates only under this authority? If No, whose? In Operation Since: 2003 Y N Authorized to Transport HazMat? Average Haul (#miles): 1600 miles Y N Ever had a DOT Compliance Review? Longest Haul (ST./ST.): AL/WA If Yes, date: 2/21/19 # Units on Road/Day: 70 Result = Sat Cond Unsat No Rating Drivers usually out for: 7 days Y N Ever had a DOT Intervention? If Yes, date: Nature of Operation: Truckload LTL Both Areas reviewed in Intervention: Driver Type: Singles Teams Both Fleet Mileage Last Year: 12,634,751 Y N Registered for the FMCSA Portal? Fleet Mileage This Year: 5,900,300 Y N Operates in Canada? Y N Operates in Mexico? Operation Type: Dump Reefers Livestock Car Hauler Flatbed Vans Other: Percent of trips within a radius of: 5% 0-50 mi. 10% 51-200 mi. 25% 201-500 mi. 60% >500 mi.

BROKERAGE: N/A NOTE: Review program, make recommendations Number of Years in Business: Are Bills of Lading cut in Broker’s name or Trucker’s name? Is the brokerage a separate corporation? .......................................................................................... Y N

If Yes, what is the name of the corporation (include “Inc., LLC, etc.”)? Do you have insurance requirements for truckers that use your service? ......................................... Y N If Yes, a) Coverage and Limits: b) Specify procedures in place to verify coverage is in place: Do you verify the trucker’s authority to haul the commodity being shipped? ..................................... Y N If Yes, how is authority verified? Are files for the brokerage kept separate from trucking operation? ................................................... Y N Additional comments: Insured's website mentions brokering freight under, "Expedited Services." This was not worded correctly, trying to convey that they will haul broker freight.

OTHER INFORMATION REGARDING INSURED:

Y N Freight Forwarder? Explain:

Y N Warehousing? If Yes, give details: Y N Authorized state inspection station? If Yes, is insured inspecting outside vehicles? Y N

Comments:

Y N Any other operations? Explain:

Y N Any other contracts? Explain:

Other Terminal Locations: None

Have you ever operated under a DOT # or company name that is now inactive or closed? Y N If Yes, explain: Name of Company: When: DOT #:



DRIVERS: # Longhaul Drivers

# Local Drivers

# Part-time Drivers

Comments

Company 130 44 8 Driver count has decreased due to COVID. Part time drivers drive for insured when they are not working in agriculture during the off season.

Owner-Operator Leased Leased from:

Compare survey request against information provided by the insured. TRUCKS & TRACTORS

Straight Trucks

Tractors Other Comments

Company 106 79 tractors are 2019 or newer Owner-Operator Leased TRAILERS Vans Reefers Flatbeds Tanks Dumps Other Comments Company 110 50 are 2019 or newer Owner-Operator Leased

If there is a difference between the number of units provided on the survey request and the number of units provided by the insured, provide reason for discrepancy. No discrepancy

TYPE OF FREIGHT & COMMODITIES HAULED Commodities Hauled

%

Maximum Value/Load (if Cargo Coverage provided)

Produce-Temperature controlled 35% $70,000 Poultry-Temperature controlled 35% $90,000 Canned/Boxed Food 15% $60,000 General Freight 15% $65,000

Any Oversized Loads? Y N If Yes, Type:

PASSENGER PROGRAM NOTE: AMIC DOES NOT ALLOW PASSENGERS. If Passengers are NOT Allowed: Is the policy: Written Not Written Y N Is the program strictly enforced? Additional information:Offending driver terminated for 1st offense transporting unauthorized passenger(s) If Passengers ARE Allowed: Y N Is it a written policy? (If Yes, obtain a copy) Y N Is program related to safety? Y N Any Restrictions? Y N Is a separate passenger insurance policy required? Y N Is a signed Hold Harmless agreement/waiver obtained? Y N Is the program strictly enforced? Additional information:

SUMMARY (Description of Operations) Located in an area that is heavily agricultural, rural, southern Alabama, the vast majority of insured's operations are teams hauling temperature controlled food products to any/all of the 48 continental states. As shown on the table above, a large percentage of the fleet is 2019, or newer.



RISK ASSESSMENT The items listed in each of the sections below are examples of elements that the insured could be using to meet the Objective. In the Summary, evaluate each section and explain whether the insured is meeting the Objective. DRIVER SELECTION/QUALIFICATION:

OBJECTIVE: 1) An effective process that is followed in each case to ensure that only qualified drivers are allowed to drive.

Selection Requirements: Minimum Age: (23) .................................................................... 24

............................................................................................................ Minimum Experience: (2 years) ......... Lead driver => than 2 years

............................................................................................................ MVR Guidelines: ............ Underwriter's guidelines provided to me

(Up to 2 minor violations in 12mos / up to 4 minor violations in 36mos / no major violations. Up to 2 accidents in 3 years.)

Written Requirements (strictly followed) Same Requirements apply to Owner/Operators Registered with the FMCSA Drug and Alcohol Clearinghouse? Have an active Drug and Alcohol Clearinghouse query account? Uses FMCSA Pre-Employment Screening Program

DOT Driver Qualification Files: Complete Applications Current Long Form Physicals Medical Certificate accepted/verified Past Employment Reference Checks Drug/Alcohol Inquiries Pre-Hire MVR Annual MVRs or CA Pull Notice Certificate of Violations Annual MVR Reviews Pre-Hire Road Test (documented) Pre-Hire Drug Test

Person(s) accountable for: Driver hiring/termination ................................................ Tanya Merritt Driver qualification files ................................................. Tanya Merritt

BA

SICs

#Driver Fitness Violations: 25 #Driver Inspections: 657 #Driver Fitness Serious Violations: 0 Did Insured provide SMS scores? Yes If yes, On-Road%: 98% Status: Above Intervention Threshold #Drug/Alcohol Violations: 13 #Driver Inspections: 657 #Drugs/Alcohol Serious Violations: 0 Did Insured provide SMS scores? Yes If yes, On-Road%: 77% Status: Below Intervention Threshold

SUMMARY: Provided driver hiring criteria is the guidance furnished by Underwriting, regarding minimum driver qualification standards. The insured has "raised the bar" to 24 years of age minimum. DQ files are initially assembled on site and submitted to a 3rd party provider, Transportation Safety Services, of Daphne, AL who retains and maintains them. None were on-site and available for direct review and observation. Personnel files were available and reviewed, containing duplicate copies of some of the items that would be contained in a DQ file. Without the ability to review them directly, I cannot confirm, or deny, that DQ files are fully compliant.



TRAINING:

OBJECTIVE: 1) Prepare/train new drivers to enable them to fulfill all of their assigned responsibilities/duties; 2) Keep drivers up-to-date on changes in policies, procedures or regulations, and to keep existing policies fresh; 3) Recognize deficiencies and re-train drivers when necessary. Subjects addressed

Hazardous materials Company rules/policies/operations Daily Vehicle Inspection Procedures Equipment familiarization Defensive Driving Regulatory compliance Company accident (scene) procedures Handling freight ELD Training

Materials used Employee/Driver Handbook Videos Outside vendor materials

STUDENT DRIVER PROGRAM: N/A

Percentage of the total fleet:

Written Student Program Outline Student manual Graduation from TT school required Students only from PTDI schools Written student evaluations Formal driver-trainer training On-the-job training Length: Continuing education

NOTE: Thoroughly review program and make recommendations

Person(s) accountable for: New driver orientation/training ............................................... Amanda Lynn Carter In-service driver training ..................... Shared responsibilities by Safety Dept. staff Total hours of training: New drivers: Classroom: 4 On-the-job: 6-8 weeks with a veteran, incumbent driver In-service drivers: Classroom: 1 hour/month On-the-job: Event based

Documented orientation/training (checklist) Owner/operators complete the same training as company drivers

SUMMARY: All new hires receive 4 hours of classroom training before 1st dispatch. New hires are then paired with an experienced, incumbent driver for 6-8 weeks. This also applies to "established teams" who apply together to drive as a team for the insured. As a condition of employment, they must be split up for the required 6-8 weeks to complete required training. Various online training options were discussed that could help to facilitate training more consistently and more efficiently. This would greatly assist with recurrent in-service training for OTR teams that are difficult to schedule for in-person training sessions. Of additional note, insured has employed the services of attorney, Jamie Nobles, to author a comprehensive employee handbook.



MANAGEMENT & SUPERVISION:

OBJECTIVE: 1) Identify, implement and practice good supervision and communication techniques; 2) Ensure that supervisors, employees and drivers understand their respective responsibilities, the consequences for failing to fulfill those responsibilities and, conversely, recognition for consistent positive conduct; 3) Benchmark or monitor progress and implement changes when necessary in order to make improvements in performance, turnover, job satisfaction, etc. Supervision

Call-in procedure/Cell Phones Satellite Communication/Tracking Devices Road Patrol Periodic Check Rides/Road Tests Regular Driver Performance Reviews Documented Driver Safety Record Accident/Violation Reviews Written Disciplinary Policies Same Disciplinary Policies apply to

Owner/Operators Monitoring CSA SMS

Safety Elements Cell Phone/ Texting Use Policy Distracted Driving (Additional) Safe Driving Policies (i.e. Speeding, Cruise Control) Written Safety Policy Statement Written Drug/Alcohol Testing Policy Compliant Drug Testing Program Safety Award/Incentive/Recognition Program for drivers Group Safety Meetings Frequency: Quarterly

Written Agenda/Topics Discussed Record of Attendance

Individual meetings Safety Committee Accident Review Committee

Annualized Driver Turnover: Average # of drivers for last 12 months: ................... 209 # of drivers replaced in last 12 months: ...................... 90 DRIVER TURNOVER ............................................. 43%

Proactive driver retention program

SUMMARY: Insured has access to a subscription to Vigillo through their contract Transportation Safety Services. Vigillo is a comprehensive CSA monitoring and analytical resource that creates items such as individual driver scorecards, rankings, etc. TSS is the insured's 3rd party administrator for DOT Drug and Alcohol testing, which is said to be in compliance.



HOURS OF SERVICE/FATIGUE ISSUES:

OBJECTIVE: Ensure compliance with applicable regulations and control fatigue issues that might result in increased crashes.

Name of ELD Vendor Verizon Reveal Is Geo Fencing utilized? (Yes or No) Yes Who monitors ELDs? Annie Westmoreland Reporting provided to management monthly? Daily

Exemption Rule followed: Driver uses paper logs no more than 8 days per 30-

day period. Drive-away/tow-away operations (if vehicle being

delivered is the commodity or is a motorhome or recreation vehicle trailer).

Driver of vehicles manufactured before year 2000, or engines manufactured before year 2000.

BA

SICs

#HOS Compliance Violations:127 #Driver Inspections:657 #HOS Compliance Serious Violations:0 Did Insured provide SMS scores? Yes If yes, On-Road%: 97% Status: Above Intervention Threshold

SUMMARY: As identified above, Annie Westmoreland is the member of the Safety Department that is designated to oversee HOS. Ms. Westmoreland addresses each violation directly with the offending driver by telephone within 24 hours. Current CSA HOS scoring of 97% would suggest that these reactive measures are not effective in controlling HOS. Options to include a higher level of training and responsibility for HOS to be placed on Operations were discussed. Safety alone cannot control HOS, this must be an organizational commitment by all relevant departments at all levels.



CRASH & LOSS INFORMATION:

OBJECTIVE: Have an effective method of reporting, basic investigation, documentation, trending & prevention of repeat accidents.

Separate Accident Files DOT Recordable Accident Register Overall Accident Register Accident Reporting Kits/Cameras Preventability Determination Formal Accident Investigation (written) Written Driver Reports

Time Frame for Submission: < 24 hours

Reporting Claim to Insured by Driver: Method: Phone Time Frame: From scene Reporting Claim to Insurer: Method: Call Time Frame: < 24 hours Technology used (please describe): Telematics Verizon Reveal Collision Systems OEM systems Camera Systems Road facing only

Accident Frequency Rates:

One-year period from: 7/1/19 to 6/30/20

Number of miles: .................................................. 12,999,519 Total # of Accidents: .......................................................... 22 # of DOT Recordable Accidents: ....................................... 13 # of DOT Recordable/Preventable Accidents: ..................... 7

Frequency Formula: [# Accidents] x 1,000,000 / Total Mileage

= # Accidents per Million Miles Overall Accident Frequency Rate: .............................. 1.69 DOT Recordable Accident Frequency Rate: .............. 1.00 DOT Recordable/Preventable Frequency Rate: ......... 0.00

BA

SICs

#Unsafe Driving Violations: 110 #Unsafe Driving Inspections: 103 #Unsafe Driving Serious Violations: 0 Did Insured provide SMS scores? Yes If yes, On-Road%: 96% Status:Above Intervention Threshold

SUMMARY / ACCIDENT TRENDS IDENTIFIED Drivers are to report crashes by telephone, directly from the scene. Written reports are required upon request from Safety, when deemed necessary. Safety makes every effort to report to the Insurer within 24 hours, by telephone, Monday to Friday, via email on weekends. The high number of Unsafe Driving violations directly correlate to the amount and severity of crashes within the past 24 months. During this timeframe, 23 DOT recordable crashes have occurred, resulting in 36 injuries. Data for the 12 month period identified above includes 2 fatality crashes, resulting in 4 total fatalities and 28 injuries, just since 11/2019. It should be noted that the vast majority of these injuries and fatalities occurred in one event involving a total of 44 vehicles in winter conditions on 03/01/20. This has greatly skewed these numbers which taints the public view of their crash data. This, and any other crashes should be submitted for an FMCSA Preventability determination if the internal investigation deems them to be Non-Preventable and sufficient support exists to make a solid case. Dashcam video is extremely helpful with support in these situations.



EQUIPMENT MAINTENANCE: OBJECTIVE: 1) Equipment adequate for the operation and kept in acceptable condition; 2) OOS rates average or better and monitored; 3) SMS score monitored and below intervention threshold

Company Equipment: Written maintenance schedule (time/mileage basis) Regular inspection intervals Written inspection checklist Work orders/documented maintenance Separate files for each unit Annual inspections on-file/up-to-date Driver Vehicle Inspection Reports Maintenance can declare units OOS

Specific replacement policy (years/miles) Tractors: As needed Trailers: As needed

Y N Does the company service their own vehicles? If No, who does:

Owner/Operator Equipment: N/A Under permanent/exclusive lease (Enclose copy of

contract.) Bobtail Coverage required

Certificates of Insurance on file Blanket company policy

Pre-Lease (written) inspections Periodic inspections (written) Annual inspections on-file/up-to-date Copies of maintenance records on file Separate files for each unit

If Yes, what is included? Preventative Minor Repairs Major Repairs Body Work

Certifications for annual inspectors Certifications for brake repairmen

Equipment Available for Inspection None # of Tractors/Trucks: 2 Unit #(s): 397, 439 General Appearance: Good Average Poor Brakes: Good Average Poor Tires: Good Average Poor # of Trailers: 1 Unit #(s): T-301 General Appearance: Good Average Poor Tires: Good Average Poor

Person(s) accountable for: Maintenance program ................. Charles Patterson, Jr. Recordkeeping ............................ Charles Patterson, Jr.

BA

SICs

#Vehicle Maint. Violations: 232 #Vehicle Inspections: 312 #Vehicle Maint. Serious Violations: 0 Did Insured provide SMS scores? Yes If yes, On-Road%: 66% Status:Below Intervention Threshold

SUMMARY: Maintenance program is in place and appears to be effective. CSA scoring is at 66%, a full 14 points below alert status, with OOS rate of 20.4%, on par with the industry average. When defects are identified in a PTI, a DVIR is completed electronically in accordance with the regulations. All mechanics are ASE certified, per insured. This does not include entry level helpers, etc.



TERMINAL SECURITY:

OBJECTIVE: Reduce the likelihood of vandalism, theft or damage to premises, equipment and/or commodities.

Terminal Address (if different than address on front page):

Security for units stored on premises # kept inside: # kept outside: All

Units locked (keys removed) Alarm System Surveillance Camera(s) Guard Service (24 hours) Lot Fenced (good condition) Gate (locked during non-business hours) Lot well-lighted

Vandalism/Theft potential: Average Higher than Average Lower than Average

Security problems resulting in losses in the previous

3 years? If so, describe:

SUMMARY: Security measures include full perimeter fencing around the lot where equipment is parked. The entire property is under video surveillance and has employee activity 24/7. Additionally, no drivers are authorized to take units home. All must be returned to the company facility and properly parked upon return from a trip before going home.



HAZARDOUS MATERIALS: N/A NOTE: Verify registration, training, emergency response, etc.

OBJECTIVE: 1) To be fully aware of any & all types of HazMat transported; 2) Be conversant & compliant with all applicable HazMat regulations; 3) Have a policy governing HazMat transportation and effective procedures practiced for transporting or storing HazMat to prevent spills, damage or other HazMat losses.

Registered, if required Registration #: Expiration Date:

HazMat hauled in LTL loads If partial loads, what is the estimated maximum % made up of HazMat? %

HazMat transported in bulk If so, what:

Hauls HazMat requiring $5,000,000 insurance coverage If so, what:

List of CDL drivers with HazMat endorsements

HazMat Table: (GROUP I materials must be placarded for any amount - Describe GROUP I materials in SUMMARY) GROUP I

1.1 Explosives 4.3 Dangerous When Wet 1.2 Explosives 5.2 Organic Peroxide (Type B liquid or solid temperature controlled) 1.3 Explosives 6.1 Poison Inhalation Hazard (Inhalation Hazard Zone A or B) 2.3 Poison Gas 7. Radioactive (Yellow III label only)

GROUP II 1.4 Explosives 1.5 Explosives 1.6 Explosives 2.1 Flammable Gas 2.2 Compressed Gas 3. Flammable Liquid 3. Combustible Liquid 4.1 Flammable Solid

4.2 Spontaneously Combustible 5.1 Oxidizer 5.2 Organic Peroxide (Other than Type B, liquid or solid, temp. controlled) 6.1 Poison (Other than Inhalation Hazard Zone A or B) 6.2 Infectious Substance 7. Radioactive (Yellow II or White I labels) 8. Corrosive Class 9 ORM-D

Training Program General Awareness Training Function Specific Training Safety Training Security Awareness Training In-Depth Security Training System to track Recurrent Training Certification that employee has been trained & tested

Security Plan Personnel Security Unauthorized Access En-Route Security

SUMMARY: Insured does not transport hazardous materials.



CARGO SECURITY: N/A NOTE: Complete if Cargo Coverage is noted on the request. If insured is sub-contracted or brokered to other carriers, and if this application requests coverage for loads moved by sub-contracted or brokered carriers, this must be completed for those carriers.

OBJECTIVE: 1) Reduce the number and severity of cargo losses and mitigate losses that occur, whether en-route, parked or warehoused; 2) Be familiar with all commodities being transported, warehoused, or otherwise responsible for; 3) Monitor and investigate any losses.

Who handles cargo security, loss, & damage? Is this person familiar with cargo claims procedures?

Terminal Cargo security plans/programs at this terminal (If so, ATTACH) Cargo security plans/programs at other terminals Means to ensure compliance with security plans Regular terminal “lot checks” to check for missing loads

Vehicles Kingpin locks Trailer door locks Tracking devices (e.g., satellites) Drivers present during loading/unloading

High Value Loads N/A Special security precautions En-route security precautions Additional driver qualifications

Drop Yard N/A Security measures for unattended trailers Regular drop yard “lot checks” to check for

missing loads

Warehouse/Dock N/A Security for cargo in warehouse/dock areas Non-Employees allowed access

Escorted Signed in/out

High value loads segregated from others

Employees/Drivers All drivers, dock workers, & helpers full-time

If not, % or # that are day labor/temps: Number of drivers assigned to each unit:

Employees screened prior to hiring (Check all that apply): Criminal history Credit check CDL/MVR Past Employment References Drug Screening

Driver training in security issues (e.g., theft, hijacking, etc.) Discharged employees instructed to leave immediately Keys, ID’s & company documents collected at discharge Employee Fidelity/Dishonesty Coverage (If so, attach certificate) Limited number of employees with personal knowledge of incoming shipments

SUMMARY: Cargo insurance is written by Tokyo Marine.



ADDITIONAL COVERAGES (Refer to Addendums): General Liability and/or Property Coverage: N/A Workers Compensation: N/A

OVERALL EVALUATION Based on the insured's Conditional rating by FMCSA, high CSA scoring and high number of roadside violations, it is clear that any policies, processes and procedures that have been in place over the last 24 months have proven to be ineffective, or have been poorly managed. The insured states that they have been in contract with a local 3rd Party safety consulting provider, Transport Safety Services, located in Daphne, AL for the past 12 years. I cannot comment regarding where the disconnect has occurred, as I am not privy to that relationship; however, it is clear that this relationship has proven to be ineffective in achieving satisfactory safety performance. Recently, Incentive Risk Management, Inc., of Locust Grove, GA, has become involved in efforts to improve the insured's safety perfomance. I can confirm this as, Risk Manager, Bill Plemmons was on site on the day of my visit and participated in the meeting, noting my comments and recommendations. As mentioned and documented in the appropriate places in this report, CSA scoring is poor. While CSA scoring usually cannot be improved overnight, there may be room for rapid improvement, as zero DataQ's or FMCSA Crash Preventability determinations have been recorded in past 24 months. All safety performance history, at least within the past 6 months, should be carefully reviewed and considered for challenge if there is sufficient meritt and supporting documentation to support same. This will be recommended in my letter to the insured as a corrective action measure. While there is much work to be done, these issues can be corrected.


August 6, 2020 Tanya Merritt Flat Creek Transportation, LLC PO Box 349 Kinston, AL 36453 Re: On-Site Loss Control Visit

Policy No. EEX-BRS0008

Dear Tanya, This letter will confirm our safety survey of your operations on July 31, 2020, conducted on behalf of Blue Ridge Specialty, as a service to you as a valued customer. As a result of the survey, we are suggesting the following recommendations to assist you in your accident prevention and safety efforts. If there are Critical Recommendations, we request a written response be sent to PSC, either by mail at PO Box 369 Kimberling City, MO 65686 or by email at [email protected], within 30 days of receiving this letter. CRITICAL - Should be implemented immediately. 1.Make every effort to address and upgrade your FMCSA rating of Conditional, which has been in place since 05/08/19. This information has public visibility and communicates a message that your company does not take the safety of the motoring public seriously. Plaintiff's attorneys will use this against you in post crash litigation any chance that they have. Rating upgrades begin by taking control of your safety performance, improving your CSA scores and submitting a request to FMCSA for a rating upgrade. You must be able to demonstrate to FMCSA that your programs, policies and procedures are effective in controlling and correcting unsafe behavior. Currently, 4 CSA BASICs are 94%, or higher. These scores must be significantly reduced as soon as possible. All safety performance history, at least within the past 6 months, should be carefully reviewed and considered for DataQ challenge if there is sufficient merit and supporting documentation to support same. 2.Your Driver Fitness BASIC score is 98%. Immediate steps should be taken to lower this score. A means of determining that each driver has the required current credentials in their possession should be established and enforced by Operations and Safety upon each contact with the driver. Close monitoring and additional changes in procedure may be necessary to lower this score. 3.Current CSA HOS scoring of 97% would suggest that current, reactive measures are not effective in controlling HOS. Options to include a higher level of training and responsibility for HOS to be placed on Operations were discussed. Safety alone cannot control HOS, this must be an organizational commitment by all relevant departments at all levels. Develop and implement a pro-active plan designed to target frequent types of driver violations. A written disciplinary policy for HOS violations, which also includes relevant members of Operations, should be developed and consistently enforced. The policy should be progressive in nature, providing for written warnings, followed by training, if necessary, suspension and possible termination for repeat violators. This policy should be strictly followed and enforced 4.Unsafe Driving BASIC score is 96%. The high number of Unsafe Driving violations directly correlate to the amount and severity of crashes within the past 24 months. Robust policies that hold drivers accountable for speeding, unsafe lane changes, cell phone violations, etc., up to and including termination, must be developed and strictly enforced. 5.In an effort to prevent and reduce accidents and ensuing losses, we recommend that you include a "Defensive Driver" and a "Distracted Driving" training program in your safety program. Drivers should be fully aware of the techniques for defensive driving and should be given refresher courses after the initial training. Most accidents, regardless of fault, can be prevented and drivers should be given that information and then held accountable.



IMPORTANT - Should be implemented as soon as practicable. 6.Follow up to ensure that your attorney, Jamie Nobles, completes your comprehensive Employee Handbook with urgency. Setting clear and concise expectations is the beginning of true safety accountability. SUGGESTED - Offered in an effort to help you enhance your safety program. 7.Utilize the PSC Web Portal (login instructions provided during assessment) for assistance with training materials, safety meetings, accident countermeasures, paycheck stuffers,and overall enhancement of the safety and loss control program. This valuable resource is provided to you as a valued policy holder. I appreciated the courtesy you extended to me during my visit. For more assistance and resources, access your PSC Insiders Circle Platinum Membership at www.professionalsafetyconsulting.com. If you should need further clarification of these recommendations, you may contact Professional Safety Consulting, Inc. at 800-659-3025. We look forward to continuing to work with you in the future. Sincerely, James R Desmond, CDS Consultant Cc: Mike Gordon, Blue Ridge Specialty Russell Huston, Agent


amic - srs.professionalsafetyconsulting.com

Documents