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American Towman Magazine Presents the Week in TowingNovember 22 - November 28, 2017
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Are You Ready for Paperwork Inspections?

buried.under.paperwork e62aeBy Randall C. Resch

A California tow company owner called me recently, disappointed that his company was being disqualified by the highway patrol. Not because his company didn't meet the tow truck fleet requirements or facility requirements; but because his administrative paperwork was not in order.

He felt the highway patrol tow boss was being too sensitive that the company's paperwork wasn't in the order he expected. He was disgruntled and felt the tow boss was picking on him due to perceived problems from an earlier rotation situation that resulted in his company being suspended.

After listening to him for some time, I came to the opinion that the tow boss may have been justified.

If you're seeking to participate as a first-time rotation tower or if you're a long-time rotation provider, there's tons of paperwork required by the highway patrol. It takes due diligence and attention to detail to stay on top of the paperwork pile.

While applying for any highway patrol or police rotation bid, knowing the amount of paperwork upfront is the difference between acceptance and denial, or acceptance and eventual removal. When required paperwork is lacking or not up-to-date, you're history.

Here's a simple description of what's minimally required for most new applicants or renewal applications:

• Permit Application. Every bid has a date of deadline application in the contract. Most contracts typically do not roll over annually and must be re-submitted every year or when stipulated.

• Driver Lists. Indicates all drivers who will respond to calls for services have completed a LiveScan or acceptable background investigations.

• Tow Operator Training. Proof that all tow operators are sufficiently trained in towing and recovery procedures. Proof of training may include a requirement that tow drivers have attained TIM training separate from tow operator's training.

• Drug Testing. Proof that all responding drivers are enrolled in an employee drug/alcohol protocol.

• Insurance. Company to provide evidence of minimal liability, worker's compensation and business insurance coverages, typically naming the agency as insured.

• Inspections. Proof that each tow truck and flatbed carrier has been inspected by the state and or agency of contract.

• Hours Worked/Logbooks. For companies providing big-rig or upper class tow operations, drivers who spend time behind the wheel must have an accurate accounting of time driving vs. recorded periods of rest.

Paperwork is an endless process that requires complete documentation and archiving. Most likely, each RFP or bid offering will include the requirement that the contracting city or entity has the right to request a review of the company's records with appropriate notice during work hours. There's potential of a surprise paperwork review somewhere down the line.

I believe it's the tow company's responsibility to have and maintain complete, accurate and honest paperwork that's ready for an inspection at any time. Accordingly, if paperwork isn't in order, suspensions of 30 days or more are possible to include possible removal from the contract for violation of performance.

Owners, keep in mind that if you have an operations manager, drivers, manager or shop supervisor you've tasked with keeping paperwork up-to-date, ultimately you still are accountable to ensure that all paperwork is in order. The agency isn't concerned with an excuse that you weren't aware that the paperwork wasn't complete, archived or readily available.

Remember, law enforcement will hold you to a higher standard than other kinds of contracts. It's not a matter of personalities or them not liking you. If you're not playing by the varsity rules, it's your choice. If you're not up-to-date as to what paperwork is required of your company, perhaps it's time to attend some tow coursework or consult your attorney.

Randall Resch is American Towman's and Tow Industry Week's Operations Editor, a former California police officer, tow business owner and retired civilian off-road instructor for Navy Special Warfare. Randall is an approved instructor for towers serving the California Highway Patrol's rotation contract. His course is approved by the California law enforcement community. He has written over 500 industry-related articles for print and on-line, and is a member of the International Towing & Recovery Hall of Fame.
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