The Department of Transportation regularly conducts audits to make sure companies are in compliance with all regulations. Since 2010, the number of DOT audits has increased, due in part to its implementation of the Safety Measurement System, which compiles data from all roadside inspections and weigh stations. The system then assigns a score to each carrier, and companies that have a high number of violations are most at risk for being audited.
Since DOT audits take place with little to no advance notice, it’s important for every carrier to make sure they’re always prepared. Keeping good records all year long that have plenty of attention to detail can help make the audit go more smoothly and will help ensure your business passes the audit.
To pass an audit, your company needs to have a system in place that is designed to keep you compliant at all times. That system needs to capture all the necessary information, and it should help keep you organized and on track.
What Kind of Audit Are You Getting?
There are different kinds of DOT audits:
- Compliance review
- New entrant audit
- Security audit
- Hazardous materials audit
The new entrant audit is for motor carriers that have recently filed with the DOT, and it will be completed within three to six months after a DOT number is issued.
A security audit looks at your safety plan, driver training and security measures. For hazardous materials audits, the DOT will review such things as training, policy, shipping documentation and labeling of hazardous materials.
The new entrant audit and the compliance review are the two most common DOT audits. A new entrant audit is a safety audit that usually takes place within a carrier’s first six months of being in business; it’s designed to make sure you are complying with all required safety regulations.
A compliance review looks at how well you are following government regulatory processes and reviews your company’s safety performance.
Preparing for Your Audit
Having the right paperwork in place means that you won’t have to scramble when the DOT shows up for an audit. Paying attention to the details can mean the difference between passing and failing an audit.
Here’s a checklist of the documents and paperwork to have readily available in the event of an audit:
__ A current copy of the Federal Motor Carrier Safety Regulations (FMCSR)
__ An up-to-date MCS-90 form showing liability insurance coverage that meets the limit required for your operation.
__ A written program/policy in place for drug and alcohol use and testing.
__ A summary of all drug and alcohol testing conducted in the past calendar year, along with the current status of any drivers who tested positive.
__ Motor vehicle records (MVRs) on all new and rehired drivers.
__ A copy of pre-employment drug tests for all drivers.
__ Proof that all drivers hold a current commercial drivers license (CDL).
__ Six months of completed driver logs on all drivers.
__ At least 14 months of valid annual inspections for all operating commercial motor vehicle equipment.
__ Complete maintenance records.
__ A current DOT security plan.
__ 90 days of post-trip inspection reports for each commercial vehicle in which defects have been found.
Updating Driver Qualification Files
Every DOT audit will include review of driver qualification files, so it is crucial that these files are always kept up-to-date. The required information for each driver’s file will include:
__ An annual documented review of the driver’s certificate of violations.
__ A record of a valid road test and documentation showing that the driver’s employment history was investigated before hiring.
__ Training materials on drug and alcohol programs, with a signed receipt from the driver.
__ Any and all instructions to drivers about convictions for moving violations. The instructions must be given within 30 days of the violation.
Reviewing Essential Processes
Certain processes must be in place and documented for your audit. Those include:
__ A current accident register.
__ A progressive disciplinary action system for drivers.
__ Written hiring policies.
__ A process for documenting drivers’ medical certificates and removing the driver if the certificate is out of date.
__ A process to keep all CDLs current, with driver removal if it expires.
__ A process for checking all drivers’ logs for accuracy.
__ A system to control working hours and ensure compliance.
Knowing what to expect from a DOT audit can help you prepare for it and also will help you maintain better records and processes. While no one looks forward to an audit, you can face it with more confidence and help it run more smoothly if you have all your records and processes in place.
Smith System’s training can provide you with everything you need to know about remaining compliant and prepared for a DOT review. Whether you have already had a DOT audit and want to improve your processes or want to prepare for future reviews, every commercial fleet manager can benefit from our DOT Compliance Seminar. Enroll now, or contact our Smith System team of experts to find out more.