Author: Michael Dodd

Have you received a warning letter from the DOT asking you to review your record and improve your overall score? Several of our members have received such letters. This is not a letter that you want to get. It is a warning letter that, in so many words, means that if you do not improve your score, then you may be visited — another way of saying that you may get an audit. You may look at your overall record and review your score by going to the Safety Management System (SMS) website at this address: ai.fmcsa.dot.gov/SMS/. This site allows…

March 2nd Deadline for OSHA Electronic Submission of Injury and Illness Records Per OSHA 29 CFR 1904.41, March 2, 2019 is the deadline for electronically reporting your OSHA Form 300A data of injury and illness records for calendar year 2018. Is my company required to participate? Employers with establishments having 250 or more employees as well as establishments with 20 to 249 employees in certain high-risk industries must submit their 2018 300-A Summary information to OSHA. The high-risk industries are listed by North American Industry Classification System (NAICS) codes in Appendix A to Subpart E to Part 1904. I can…

There were several DOT Compliance Reviews (audits) conducted on GAWDA members in 2018. In the past, these audits were typically initiated as a security review, and while the inspectors were on site they reviewed other topics such as shipping papers, driver qualification files, alcohol and substance abuse programs, hours of service records, vehicle files and other DOT items as desired. Now that the Safety Measurement System (SMS) is in full swing, we have members with high scores being targeted for an on-site audit. You will also be visited if you request to become a party to a special permit for…

Simplified Sample Procedures Available for Food Gases – Qualified Facilities The new Food Safety Modernization Act and 21 CFR 117 allow for easier and modified compliance if your company can claim “Qualified Facility” status. There are two ways to claim Qualified Facility status. The most common way to meet the Qualified Facility definition is if your entire company sells under $1,000,000 per year of food gases. The modified requirements reduce the burden for Hazard Analysis and Risk-based Preventive Controls (HARPC) and for the Supply-chain Program. If you wish to claim “Qualified Facility” status and take advantage of these modified compliance requirements, you must submit an “Attestation”…

Special Permits There are two kinds of DOT special permits: permits for manufacturing packages that are different from approved specifications, and permits that let you do things differently than what is found in the published regulations. A special permit is an alternative method of complying with the Hazardous Materials Regulations. It will cover a new process, product or materials that are not specifically referenced in the regulations. You need to apply and obtain authority from DOT to hold a special permit. This is known as “party to” status. On File at Each Location If you have a package that has a special…

Risk! I don’t have to explain the concept of risk to any of our GAWDA member company owners. They deal with it every day because they are in business. What I do need to talk about is how to reduce that risk in the areas that I deal with: DOT, OSHA, EPA and Homeland Security, along with cylinder filling and cylinder requalifications. Fellow GAWDA consultant Tom Badstubner and I just completed another compliance seminar. Held at member company Weldcoa, it was a duplicate of the seminar held at Chart earlier this spring. This year, our information was all about surviving…