On Safari with Mike Dodd
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Mike Dodd at the controls for Jim Mikus' review
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On a clear mid-June Tuesday morning, Jim Mikus pulls into his company's parking lot just east of Cleveland, and sees a huge motor home parked amongst his cylinder delivery trucks. The unfamiliar vehicle bears Missouri plates, yet Mikus is not alarmed or suspicious — the sole occupant, Mike Dodd, has been expected for an appointment arranged several months earlier. The meeting has the potential to save Mikus's business hundreds, even thousands of dollars.
A pre-inspection
Mikus is a co-owner of Advanced Gas
& Welding Solutions, a medium-sized independent distribution
operation stocking gases, valves and welding gear. Customers
include both walk-in tradesmen and deliveries to facilities that
range from small shops to large, well-known manufacturers around
the region. AGWS occupies a unit that is part of a commercial
strip-building next to a busy railroad line, and has another,
smaller satellite operation about 20 miles to the southeast.
Dodd, on the other hand, has been an independent Department of Transportation (DOT) and security consultant for the Gases and Welding Distributors Association (GAWDA) for the last 6 years. Before that, he spent 26 years working in various positions with Union Carbide-Linde, which later became Praxair. Dodd's visit to AGWS is to help Mikus prepare for the possibility of a DOT audit, an official visit that can sometimes occur without warning.
"There are different kinds of audits that the Department of Transportation can pull on a shop," explains Dodd. "With a full compliance audit, an inspector will give at least 48 hours notice that they'll be arriving. However, since 9/11, DOT has added a security audit in which an inspector will just appear at your door one day and ask to see your books and facility."
Business owners who aren't prepared for a DOT audit can find themselves saddled with fines, in addition to the costs incurred in correcting citations. Dodd provides a complete facility and paperwork review with the owner, and presents a printed list of recommendations (a "trip report") that will help a distributorship pass inspection. While he's on-site (which can last from one day to several days), Dodd can perform a training session for the entire staff, including drivers, on key operation and safety points, along with cylinder filling and requalification training. Perhaps most importantly, while any business owner could easily find much of the compliance information on the Internet, Dodd leaves the client with an organized system of file folders and data that just needs to be put into a safe place until the appropriate time for updates.
Consult and advise
A short time after AGWS opens for
the business day, Mikus and Dodd sit down at the company meeting
table. "There are three groups at DOT who share an interest in the
compliance of shops like yours," begins Dodd. "They're the Trucks
and Drivers group (Federal Motor Carrier Safety Administration),
the Cylinders and Hazardous Materials group (Pipeline and Hazardous
Materials Safety Administration), and the FAA group (if you ship
hazardous materials by air). All of them have inspectors that can
audit an operation. If your business is purely within the state,
you'll be 'lower on the DOT radar,' but know that eventually you'll
be audited."
The soft-spoken Dodd continues: "DOT's mission in life is to get the accidents down. They want safe, qualified drivers, and safe, qualified vehicles, so know that there will be a lot of thrust in these areas." His opening remarks over, it's time for Dodd to pore through Mikus's operation. After a stack of new manila file folders are produced from a storage cabinet,-Dodd goes through a list of necessary documents, occasionally directing Mikus to take another folder, write a particular title on the tab, put the collected documents inside and set the folder atop a growing pile to one side of the workspace.
Occasionally, there's a bit of sidetracking to break the tedium. "Do you know what is considered a 'weapon of mass destruction' in our business?" Dodd asks Mikus. "Bulk flammable liquids on wheels, and poison gases. During the Vietnam War, the government tried to create a bomb based on a container of propane, but they couldn't get the air-fuel mix consistently right to make an effective explosive, so they gave up the project." Regarding poisonous gases, Dodd mentions that engineers in Iowa have been working on an additive that would "color" someone pink, if they've been illegally handling anhydrous ammonia, a product often used by agricultural customers.
By lunchtime, there's already a sizeable stack of manila folders on the table, each with key operations documents for filing. Dodd is pleased - Mikus has been better than many past clients in maintaining his files, though there's some fine-tuning that's needed here and there. "This is great," Dodd says to Mikus. "You've already created this hazardous materials shipping paper and you've been using it. There's just one problem, and that is that the inspectors do not want to see abbreviations for the gases transported on this." Dodd also asks for access to a computer with Internet access, on which he demonstrates to Mikus that, at the DOT website for businesses (www.dot.gov/business.html), there are many tools for gas distribution business owners. The site has subheadings for topics such as Hazardous Materials, where one can find standardized forms for incident reports, emergency response guidebooks, and more. Dodd points out that many of the tags and placards necessary for a gas distribution business are available from a label-making operation called J.J. Keller (http://jjkeller.xpressmyself.com). Additionally, a three-hour hazmat training session for the entire staff at AQWS has been arranged to take place when all the drivers are back in the shop at 3 pm.
Road tour
Later, Dodd reflects on his consulting
business. "People really do appreciate the personal touch," he
says, "and I like the interaction." Once in a while, he notes, a
company challenges him on visits to "the competition." "I have to
go in with blinders on," says Dodd, "because I'm helping everyone.
When a client says, 'You're helping my competitors,' I reply, 'No,
I'm costing them money. Your competitors are now going to be
compliant --instead of charging less for goods and services because
they're cutting corners, they're responsible to operate the same as
everyone else.'" The client, says Dodd, usually understands that
he's leveling the playing field.
For ten months out of twelve, Dodd is on the road visiting companies across the continental United States, even welding distributors that are not GAWDA members. He inherited the consultant position from another person, but four years ago he decided to forego hotels, rental cars and air travel for the personal comfort of his motor home. "I'm in the eighth week of my current ten week tour, which will cover 25 distributorships on a swing covering the northeast quarter of the country. I'll log 5,500 miles on this trip. " All of Dodd's trips are arranged according to a map and a calendar, with attention to seasonal weather conditions, so he typically will be in southern states when the north goes cold. Conversely, Dodd avoids the South during hurricane season.
In his evenings, Dodd cooks his dinner, organizes his notes and writes up the trip report. He usually spends two to three days with a client, and then he's back at the wheel and on the road to the next appointment. Jim Mikus, on the other hand, will have a business ready for the moment a DOT auditor appears in the doorway. Both men will rest easy this night.
For more information, Michael Dodd can be reached at MLDsafety@hotmail.com
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Following are the typical points covered in one of Mike Dodd's DOT Compliance Reviews. Would you have these items ready and accessible when asked?
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