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CSA - Sample 5 Why's for Placard Violations

Violation

A roadside inspection report for a motor carrier showed the following violation: §172.516(c)(6) - Placard damaged, deteriorated, or obscured.

The motor carrier will want to find out the root cause of this Cargo-Related BASIC violation.

Question 1: Why was the carrier cited?

Answer: The placard was damaged in the placard holder.

Question 2: Why was the placard damaged?

Answer: The driver was rough as he forced the placard into the holder at the beginning of his trip.

Question 3: Why did the driver not take care when placing the placard in the holder?

Answer: He never really thought about. It was identifying the load, and he thought it met the standards.

Question 4: Why didn’t the driver understand the rules requiring that placards be in good repair?

Answer: He claimed he was never trained on it.

Question 5: Why was the driver never trained on this topic?

Answer: The driver was trained on the topic of placard condition during new hire orientation. There has not been any additional training since. It has not been 3 years since the initial training for the required recurrent hazmat training.

Possible Solutions

What might be some solution(s) based on the safety management cycle and the root cause(s)?

  • Assign the role of reviewing your carrier’s current hazmat training materials. Supplement where needed to include function-specific scenarios and expectations placed on the drivers. Drive home points that are problem areas.
  • Review your policy and procedures for repeated careless actions such as forcing the placard into a holder causing damage or affixing an adhesive placard on a damp surface.
  • Communicate expectations to drivers on monitoring the condition of the placard while en route, including damage the driver might inadvertently cause or as the result of weather. This might include reminders in paycheck stuffers, on posters, additional safety meetings, and the like.
  • Periodically review your roadside inspection violations, looking for patterns and areas that might require additional refresher hazmat training for specific drivers or your driving staff as a whole — more frequently than once every 3 years.
  • Be consistent in disciplinary actions based on company policies if a driver fails to abide by your policies and procedures.

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