Your DOT Compliance Checklist: Preparing for a DOT Audit
Ready, Set, Audit! DOT Audits Can Happen at Any Time
Once you’ve mastered The 6 Levels of DOT Inspection Fleet Managers Must Know it’s important to recognize that the DOT can choose to conduct an audit of your fleet’s records at any time. Required documentation must be available on demand to demonstrate that your company has been compliant at all times. In this age of Big Data, the FMCSA (Federal Motor Carrier Safety Administration) has implemented the digital SMS or Safety Measurement System to monitor the over-the-road performance of the 5 million truck and bus drivers all across the country. The SMS collects data from all roadside inspections and weigh stations and assigns compliance scores to carriers.
Any record of numerous violations can result in a negative SMS score which can quickly trigger a DOT audit. When it does, the audit may come with little or no advance warning. With paper-based records, an unanticipated audit can have the whole fleet scrambling to lay hands on the required documents, and the larger the fleet the more chaos an audit can cause. Fleets of all sizes can benefit from Whip Around’s ability to store vital compliance documents digitally and supply them on demand in real time, no matter how dispersed the fleet may be across the country. Whip Around also keeps the fleet in a steady state of DOT compliance to maintain a robust SMS score and reduce the chances of attracting audits. When audits do happen, Whip Around is the best digital tool that carriers have to be ready at all times for all 4 types of audits the DOT may conduct.
The 4 different types of DOT audits are:
Compliance review- The DOT will focus on government regulatory compliance as well as the company’s safety performance. The compliance review is frequently triggered by a poor SMS score and is therefore also referred to as a targeted audit.
New entrant audit- This is a safety review to ensure that new carriers are complying with all safety regulations and is usually conducted within the first 6 months of operations.
Security audit- For this audit fleets should be prepared to document driver training, the company’s safety plan, as well as security measures.
Hazardous materials audit– One of the most detail-oriented audits includes a review of training, hazardous material labeling procedures, and HAZMAT shipping documentation.
Of these 4, the compliance review and new entrant audit are the most common. Any of these DOT audits require an extensive list of documents to be ready and available. As we’ll see when we go through our Audit Preparation Checklist, some of the requirements can involve some heavy lifting for fleets still bogged down by old fashioned paper-based management.
A current copy of the Federal Motor Carrier Safety Regulations (FMCSR).
A current DOT security plan.
Records of valid annual inspections for all operating commercial motor vehicle equipment going back a minimum of 14 months.
Completed driver logs on all drivers going back for 6 months.
Drug and alcohol testing report covering all testing performed in the past calendar year.
A report on the current status of any driver who tested positive for drugs or alcohol.
Current MCS-90 form documenting adequate liability insurance coverage for the fleet’s entire operation.
Provide documentation of the company’s drug and alcohol testing programs and policies.
Motor vehicle records (MVRs) on all new and rehired drivers.
Records of pre-employment drug tests for all drivers.
CDL licensing proof for all drivers
Post-trip inspection reports for all commercial vehicles going back 90 days when faults have been flagged.
If your fleet is still relying on paper records it might be a good idea to keep a forklift and crew on standby. Operational logs alone can be a burden to produce on demand even for small to midsize fleets. It’s also important to note that all commercial vehicles in the company are subject to audits, not just the big rigs weighing in at 10,001 pounds or more.
A recent 2018 report at US Compliance Services “Preparing for a DOT Audit”, points out that DOT audits have been on the rise since 2010 thanks to the deployment of the DOT’s digital Safety Measurement System. The report also highlights some of the key fleet performance indicators which can attract a targeted compliance review audit. New entrant audits can even be triggered by a change of carrier services such as expanding from intrastate to interstate commerce. Below are the common triggers for targeted audits including:
High Crash Rate– The DOT sets the bar for the fleet’s crash rate at 1.5 crashes per million miles over the road. Exceeding that benchmark can trigger a compliance review.
Critical Crash- A high profile accident or crash which results in any fatality is highly likely to cause a DOT review. If the event makes the news, for example causing a massive traffic jam, the DOT is sure to initiate an audit even if there were no fatalities.
Citizen Complaints- According to USCS data most of these complaints are actually generated by disgruntled employees with inside information which can be used against the company’s perceived weak points. Legitimate complaints can also be a trigger when drivers behave badly on the road.
Random Selection- This one comes down to pure luck of the draw and means that any fleet at any time is subject to a DOT audit. That means that any CMV which has been in the company’s possession for more than 30 days needs to be fully compliant.
DOT audits can result in only one of 3 marks. “Satisfactory” means you have passed for now, but you’ll still need to be prepared for future audits at any time. “Conditional” is the mark awarded when there are no safety risks involved but the company could still be subject to fines and insurance rate hikes. “Unsatisfactory” can cause expensive fines and the company may even be designated as “Out of Service” when serious violations are cited by the auditor.
Trucking industry leaders all agree that the key to successful DOT audits is ongoing preparation. When the DOT is using digital technology to target fleets for audits the best defense for fleet managers is to be prepared with digital technology themselves. Whip Around combines the convenience of the smartphone and the digital power of the cloud to make all documentation available on demand when the DOT auditor walks through the door. Whip Around’s real-time fleet wide digital DVIR and customizable forms and checklists can optimize any fleet’s safety, performance, and DOT compliance so please don’t hesitate to contact us.