Everything is going smoothly for your trucking business. But all of a sudden, a representative from the DOT has just called and informed you that you’re going to be audited next week. “Wait, what? But am I prepared? What document records will be reviewed? Do I comply with the regulations?”

So many questions, now you’re in a panic mode. You shouldn’t be! In this article, we’ll walk you through what you need to do and how to prepare for that big day (next week?).

Who Are the Subjects For A DOT Audit?

Any employee, employer or a truck involved in the transportation of passengers or property in interstate business and with a truck or vehicle of “gross vehicle weight rating” or a combination weight rating of over 10,000 pounds can be audited, even if you’re not a trucking company. You got that correct. So even if your company is non-transportation, let’s say manufacturing or construction but it is operating to commercial motor vehicles for operation, you’re subject for an audit.

The on-site audit evaluates your business’ safety performance. The inspector will then confirm of correct, updated and complete documentations/recordkeeping. This review will also check your management controls set up in order to ensure its compliance with the guidelines of the FMCSR.

What Are The Types Of Audits?

1. New Entrant review involves all the safety audits that begin after you started operating with the USDOT number, usually within the first six months of your business. [You must check your performance through completing the compliance checklist and required documentation for every audit type]
2. Compliance Review is the on-site inspection to figure out your motor carrier’s fitness.
3. Security review involves the training, security-related measures as well as plan. It may also include a Hazardous Materials review if you’re transporting hazardous materials.
4. Hazardous materials review is an inspection of the requirements regarding the transportation of hazardous materials, including shipping papers, training, policies, container labeling, placards and markings.

Checklist: Questions to Answer

1. Can I produce the latest copy of the FMCSR?
2. Can I provide them with the latest accident register?
3. Can I produce the updated MCS-90 along with the required insurance coverage limit noted?
4. Does my company have a system in place for driver’s disciplinary action?
5. Do I have a well-placed hiring criteria or policies, which are followed by rehires and new hires?
6. Do I have a system in place ensuring the latest physical and medical examinations of my drivers?
7. Do I have records for ensuring that the CDL licenses are valid - and current?
8. Are my commercial motor vehicles and power units marked with US DOT number and company name?
9. Am I requiring my employees to send me violation reports on time?
10. Are the driver’s qualification files in my system complete and do they reflect a valid documented inspection and review of the driver’s certificate of violations yearly?
11. Do these qualification files reflect current records of valid road tests?
12. Can I produce accurate and updated qualification files? Are these files reflecting a current, complete and correct investigation of previous work history of my employees?
13. Does my business have a written documentation on the policy and program for alcohol and drug testing?
14. Can my business produce the past summary of all the required tests along with disposition of any driver that has been tested positive?
15. Did I obtain Motor Vehicle Records on every rehired or newly hired driver?
16. Are my supervisors given training for the recognition of alcohol and drug in my drivers?
17. Did I provide the alcohol and drug training information and materials along with a signed receipt in the qualification file from my driver?
18. Can I produce records of my drivers holding valid CDL licenses, along with correct endorsements based on the size of the truck or vehicle and type of commodity transported?
19. Can I provide the DOT with pre-employment drug test copy for each of my drivers with a CDL license?
20. Do I have a record and copies of the previous calendar years’ conducted random drug test results?
21. Is the driver qualification file in my system reflecting accurate and complete instructions to the drivers about conviction notifications, which include any moving violations within 30 days?
22. Do I have a system that is recognizing disqualified drivers, highlighting their termination from service or any following reinstatement to the position?
23. Did I document driver logs for every driver in the past six months?
24. Do I have a complete record of my disciplinary action policy, which states the non-compliance with service hours?
25. Are the logs inspected and checked for correctness using software system or independent document system?
26. Can I provide the last 14 months’ annual inspections for the commercial motor vehicle equipment I have – both trailers and tractors?
27. Do I have a system monitoring service hours?
28. Can I produce the latest security plan required by the DOT?
29. Did I require my new drivers to provide me with their past week’s on-duty time report?
30. Do I have maintenance records for all equipment?
31. Can I produce the 3-month post-trip inspection report copies for motor vehicle equipment?
32. Did I keep the Hazardous Material Registration? Can I provide it during review?
33. Are my employees involved in Hazardous Materials trained and with proper documentation on my record system?
34. Are the shipping papers for the Hazardous Materials review prepared and kept for the needed period of 375 days?

After answering those questions, check out the following on what documents to prepare for the audit.

Things to Prepare

1. Drivers’ list, including current, leased and terminated ones, along with their hiring dates, termination dates, license numbers, date of birth and CDL state license
2. Training records
3. Payroll records
4. Testing records on controlled substance – should include the last calendar year with the results and statistical summaries
5. Qualification files of all drivers
6. Alcohol and Controlled Policy
7. Random testing selection list of the last calendar year for each selection period,
8. Records of time sheets and logs (duty status) for the previous six (6) months; and if the truck or tractor has GPS, then its signals, for the last six months, must be provided
9. Expense records and driver trip reports (previous six months), along with fuel and scale receipts (EFS, COMDATA) and all related documents
10. The last 12 months’ Motor Vehicle accident files
11. Company’s equipment list with information on license number, company number, make, year, state and GVWR
12. If applicable, associated maintenance records and lease agreements
13. Vehicle registration records
14. Maintenance records for all vehicles owned, owner-operator leased or leased equipment
15. The past 90 days’ driver vehicle inspection reports (DVIRs)
16. The last 365 days’ roadside inspections
17. Total mileage records for your fleet
18. Gross revenue of your company in the last full year
19. Endorsement for the motor carrier policies of insurance in the last policy, MVS-90 copy
20. The last calendar year’s insurance claim information
21. If applicable, PHMSA’s Hazardous Materials Registration Form copy
22. If applicable, Bill of Lading of Hazardous Materials

How to Prepare for the Audit

Prepare for dual reporting

Consider yourself – as both the company owner and the driver. Remember that the FMCSA will treat you differently based on your role.

You will be accountable and responsible for devising and keeping compliance documentation on the driver in your system. You can begin by compiling your DQ file, which must include…

• A filled out form of the driver’s employment application
• A driver’s road test certificate along with a CDL copy
• Previous employers’ inquiry to verify employment record for the previous three (3) years
• Copy of the latest medical examinations, such as a valid medical examiner’s certificate
• State agency inquiry to verify driving records for the past three years
• The last 12 months’ MVR from every state where you driver is holding a CDL license

Create and implement a hiring policy

You should also have a written hiring policy. However, see to it that you can qualify for such policy if you were the driver. There are certain qualifications needed, such as…

• A driver must be at least 21 years old.
• You must require a driver for a DOT drug and physical test results.
• The driver should have at least a year of a valid US driver’s license.
• He or she should not have a DUI conviction for the past 10 years.
• A minimum of three years experience should also be one of your policies in hiring new drivers.
• The driver must be compliant with the rules and regulations of the FMCSA, as stated on their official website.

Devise a system for Controlled Substance Policy and Process

Each company should have a written policy on substance and alcohol policy, which should also contain the procedures in handling any violations. The policy must include the following information:

• A list of prohibited behaviors
• A list of consequences for violations, which include termination, fines or suspension from service
• Each testing procedure’s description
• Which driver categories must undergo alcohol and substance testing

(Learn more from FMCSA’s implementation guidelines for drug and alcohol regulations )

Create a record system for statement of on-duty times

If you’re a new entrant, you must be ready to provide the reviewer with your drivers’ daily logs, which include duty hours, for the past six (6) months. The inspector may review the logs through comparing them with other documents, including bills of lading, fuel receipts and other associated documents. Be certain that you back these files up and keep them updated. In addition, the DOT also requires companies to maintain forms for compliance requirements.

• Violation notices
• Mast list of equipment – with information on year, make or model and tag and description; also required are maintenance records
• Safety certification – such as the Safety and Hazardous Material Regulations’ copy
• Master list of drivers – including name, phone number, address, CDL # and expiration date, contact information and hire date
• DOT Accident Register

IMPORTANT REMINDER TO STAY OUT OF TROUBLE

• Always visit and review the FMCSA website to keep yourself updated with any additional requirements.
• If you leased a carrier, they should be the ones to comply with the requirements and DQ reviews.
• If you are hiring drivers, you’re the one responsible of their compliance, so be certain that their DQ files are updated and clean when hiring them. It does not stop here, though, as their DQ files must always be updated and clean. Otherwise, you’d risk a suspension or fine because you’re occupied and you neglect essential paperwork. Just remember this: A violation is the only thing it takes for suspension, so always review your status. You can avoid reaching the dead end for your business by keeping your business compliant with the FMCSA. Every factor involved is rated,

Ratings

• Satisfactory;
• Conditional;
• Unsatisfactory

But getting a SATISFACTORY rating isn’t the end of your journey in terms of compliance efforts, but it only means you’re doing the DOT expectations, at a   minimum, in that specific factor (General, Driver, Operational, Vehicle).

[For example, you must prepare and produce proper documentation reflecting you have proper liability coverage for the type of cargo and carrier.]

Summing Up

The trucking industry is a highly regulated one – and you know that.   And by failing to comply with the Federal Motor Carrier Safety Association and Department of Transportation requirements, you’d be at risk of being suspended as one of the consequences. But unlike a repairable truck engine, a violation is much more disabling – that might even result to loss of your license and livelihood.

And while the rules are complex, you can get by and comply with those requirements by following the tips we’ve shared on “how to prepare for an audit” – helping you navigate through the process with ease and less stress.

Topics: DOT Comliance

About Trux Solutions

We know you aren’t just looking for a safety and complianceservice and  management company; you are looking for a solutions provider. At Trux Solutions, we tell our carrier customers to do what they do best – haul freight safely and on time – and let us take care of the rest.

We are an independently-owned and operated commercial transportation consulting company that specializes in helping our clients turn their safety programs into profit centres because we know that a safe carrier is 40% more productive and generates more profits.

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