BY JOE GUINNYou’ve most likely heard about the limousine accident in Illinois a few months ago that was the tragic outcome of a farm-out gone bad. There was a death as a result of the accident, and currently there is a lawsuit against not only the company that was operating illegally, but also the company that farmed out the run.
Accidents do happen, but you can lessen their likelihood by ensuring that you’re relying on properly operating and thoroughly vetted partners. What are you doing to be sure that the companies you use for regulated vehicles are safe and compliant?
As a former affiliate manager, I remember looking at affiliates and wanting to know if they had the vehicles my customers needed, a reliable reputation, and availability. If they met the criteria and provided the necessary W-9, proof of local permits, and a COI, I would send them the trip. You’ve heard all of this before: Check to make sure they are insured and have the proper credentials to operate. For sedan and SUV trips, this may be sufficient, but if you ever send a trip for a limousine, van, minibus, coach, executive Sprinter, or any vehicle that seats a lot of your clients at one time, then you need to go much further.
Affiliate managers play an important role in making sure that the companies receiving your work are properly vetted. Although a lot of time is spent with other affiliate managers from around the world socializing and building friendships—and yes, the best relationships are built this way—you can’t tell much about what is really going on at a company unless you do a little research.
So what should affiliate managers be concerned about when farming regulated vehicles?
First and foremost, you should inquire into whether or not the company has a DOT and MC number. A DOT number is a unique identifier assigned to motor carriers for the purpose of tracking safety by the Federal Motor Carriers Safety Administration (FMCSA). An MC number is a number that gives a motor carrier operating authority to engage in interstate commerce. The simple act of picking up your group at the airport in a van means that the company MUST have both of these, even in states that don’t require it. If the affiliate doesn’t have either of those numbers, you should find someone else for the trip—immediately. This goes for local and nationwide affiliates alike.
So how do you know if your affiliate has their DOT and MC numbers? Ask them. If an affiliate is not willing to share this information with you, then you should look elsewhere. Both numbers are publicly available and should be shared openly among affiliates.
After receiving the DOT number, you should take a second to confirm the company’s reputation by visiting the FMCSA Safety and Fitness Electronic Records (SAFER) System (available online at safer.fmcsa.dot.gov) and entering their DOT number. After clicking on “company snapshot,” you’ll want to look for the words “Authorized for Passenger”; this indicates that the company is in good standing and their operating authority has not been revoked by the DOT. Other information on the website can be misleading, as the results of audits can linger for years without any movement.
The third step in the vetting process is conducting a brief interview with the potential affiliate. A thorough vetting interview should include questions like “How do you track hours of service (HOS) and daily vehicle inspection reports?” and “Who in your company is responsible for maintaining current driver qualification (DQ) files?” The DOT requires that companies make sure that their drivers are tracking HOS, and that the company’s vehicles are maintained with written records. Companies are required to have written policies in place for these items, and those who are genuinely concerned about compliance should be able to describe and even share their written policies.
It’s also imperative that your affiliate is aware of its drivers’ records—which can easily go from a clean abstract to suspended due to unpaid parking tickets or other moving violations if no one is paying attention. The proper DQ files are integral in vetting drivers for any company as they are one of the first steps in preventing unsafe drivers from operating commercial vehicles. Affiliate managers should have a basic knowledge of what is in a DQ packet so that they can ask the necessary questions about a company’s driver vetting process. DOT requires written policies on driver qualification and the company should be able to describe who’s responsible for ensuring drivers are thoroughly vetted and that their files are constantly monitored for updates.
While catastrophes will still occur, proactively vetting affiliates can help insulate your company from the risk. [CD0616]
Joe Guinn is the Owner of Atlimo & Bus Compliance. He can be reached at firstname.lastname@example.org.