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Safety & Accident

How to Ace a DOT Safety Review

May 2008, Work Truck - Feature

by Joe Bohn - Also by this author

The Department of Transportation’s (DOT) push for stricter state enforcement of Federal Motor Carrier Safety Regulations (FMCSR) has raised the potential for fleet audits in many locales.

Due to the regulations’ complexity (detailed at, it’s easy to become tripped up. A complacent attitude such as, “We’ve been running our fleet a long time, and we’ve never been audited,” can be equally dangerous.

An accident or roadside inspection, for example, can open a fleet to a full audit. If the fleet is found negligent in complying with regulations, it can be heavily fined or even operationally shut down.

In case of accidents, a high SafeStat score or negligence in complying can lead the fleet to significant exposure to litigation and claims for punitive damages by the plaintiff. (See sidebar for information on SafeStat scores.)

As poor risk management with significant downside exposure, noncompliance or litigation is worth striving hard to avoid, notes Vivek Khosla, director of product management for PHH Arval.

Small Trucks May Be Affected

Even as they provide guidance on vehicle ordering, commercial fleet management firms such as PHH Arval counsel clients on which vehicles require DOT compliance and ensure clients’ ongoing compliance with the requirements.

The DOT regulations begin coming into play on vehicles or combinations of vehicles at 10,001 lbs. gross vehicle weight (GVW).

Many fleets mistakenly assume that because the truck is small — a ½- or ¾-ton model below 10,001 lbs. GVW, for example — it is automatically and always exempt from regulation. However, by attaching a 4,000-lb. trailer to a Chevrolet Silverado, for example, its gross combined weight rating (GCWR) exceeds the 10,001-lb. governmental regulation limit. Therefore, fleets must pay close attention to any trucks that can potentially exceed 10,001 lbs. GCWR, once a trailer is attached.

At that point, companies must obtain a DOT number/decal and follow various FMCSR guidelines. The driver must have a medical exam, for example, documented on a DOT form. Employers are compelled to keep a driver file, including items such as certificate of road test evaluation, background check on moving violations, and log of hours spent on the road. Employers also must provide documented driver training in various regulations.

Determining Intrastate vs. Interstate

For the purposes of an audit, the DOT also must know the number of interstate versus intrastate trucks and drivers in a fleet operation.

Fleet failure to differentiate between these categories and maintain the necessary records is another common mistake, according to Dixie Burbank, vice president of ITS Compliance, Inc., headquartered in Sun Prairie, Wis. ITS partners with Wheels Inc. to offer compliance services for Wheels’ leasing customers.

Intrastate trucks and drivers must comply with DOT regulations or individual state regulations, whichever the fleet chooses to follow. However, if the trucks or the goods are hauled across jurisdiction lines, the trucks and drivers are interstate regulated, Burbank adds.

Many states have adopted the FMCSR in its entirety, even for intrastate drivers and trucks. Fleets must stay current with state regulations and track state changes to the FMCSR.

Companies also often delude themselves into thinking that they’re exempt from DOT requirements because they only operate intrastate, Jeff Robley, national truck sales manager for ARI, points out.

That may be true for operators in a few states, such as Texas and Wisconsin, but only if their trucks weigh less than 26,000 lbs. GCWR, and they’re not delivering items shipped to the companies from out of state.

Whenever a fleet delivers items sent from out-state to its warehouse, for example — even if its deliveries are local — the transport technically falls under the furtherance of state commerce, subjecting it to DOT regulations.

Some states, such as California and North Carolina, also have their own in-state commercial truck requirements. California regulations, for example, exceed those of the federal government, requiring operators of trucks over 10,001-lb. GCWR to have commercial driver license (CDL).



  1. 1. H Blacker [ September 28, 2017 @ 07:51AM ]

    I read your articles How to Ace a DOT Safety Review and How to Prepare for a DOT Audit.
    Ti found each of these helpful but notice that the articles were written in 2008 and 2009 respectively.
    My question is whether or not the information is still accurate and up to date?
    Thank-you very much for your time.
    H Blacker
    Safety Director
    Carolina Eastern Vail Inc.


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