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How to Prepare for a DOT Audit

The DOT has just informed you that your transportation operation will be audited. Are you prepared? Do you know what records will be reviewed? Do you comply with the regulations?

July 2009, Work Truck - Feature

by Steve Frisch

Companies that have been subjected to a DOT compliance audit often describe the experience as similar to a root canal. However, a DOT review of your transportation safety program records and evaluation can be pain-free if your company's management team understands the regulations to which they are subject and what records the DOT expects to see. 

Who Can Be Audited?

In 11 years of transportation consulting, many companies have contacted me regarding an audit, claiming, "We are not a trucking company, so we did not know we were subject to all of these regulations." Often, the primary business of these firms is non-transportation (construction, manufacturing, etc.), and they operate commercial motor vehicles to support that business. 

Regardless of the industry, any employer, employee, or vehicle involved in the transportation of property or passengers in interstate commerce, with a vehicle of gross vehicle weight rating (GVWR) or combination weight rating (GCWR) of more than 10,000 lbs., is subject to Federal Motor Carrier Safety Regulations (FMCSR). 

Companies operating solely in intrastate commerce are subject to applicable state regulations regarding commercial motor vehicles. 

A DOT on-site audit evaluates a company's safety performance and confirms proper and complete recordkeeping. The review also determines if the company has adequate management controls in place to ensure FMCSR compliance.  

As a brief review, the points covered in this article are not necessarily all-inclusive. The motor carrier is responsible to know and comply with all FMCSR regulatory and recordkeeping mandates. 

A DOT review is divided into six inspection categories called factors:  

  • General
  • Driver
  • Operational
  • Vehicle
  • Hazardous Materials
  • Accidents 

Each factor is reviewed and rated Satisfactory, Conditional, or Unsatisfactory. A satisfactory rating does not mean a company can relax its compliance efforts. Satisfactory simply means a company is doing the minimum the DOT expects of a carrier's safety program in that factor.

Factor 1: General

A carrier should be prepared to show documentation demonstrating it has proper liability coverage in place for the type of carrier and cargo. Section 387.9 of the FMCSR contains a schedule of limits. 

Carriers should have ready for examination the MCS-90 or MCS-82 form (382.15). This form is countersigned by an insurance provider representative.  

In a Factor 1 review, the DOT will also request to see a company's accident register. This document lists accidents that meet the definition of an "accident" as found in Section 390.5 of the FMCSR and are commonly called "DOT recordable accidents." 

The review determines if a carrier maintains an accurate record of these accidents. The record must contain the information required by Section 390.15, which includes: 

  •  Accident date
  • Location (city and state)
  • Driver's name
  • Number of injuries
  • Number of fatalities
  • The presence of hazardous materials other than fuel spilled by any vehicle 

Even if a carrier has had no DOT recordable accidents, it is required to have the accident register in place for review. If an accident entry appears on the register, it must remain for three years from the date of the accident. 

Vehicle markings may also be checked during a DOT review. Commercial motor vehicles must be marked on two sides with the carrier's legal or single-trade name (whichever appears on the MCS-150 form) and the DOT-assigned number proceeded by the letters "USDOT" (390.21).  

Another key part of a Factor 1 review are training records. The FMCSR requires motor carriers to train not only drivers, but also any employee who may be involved in regulatory compliance, on the applicable regulations. To demonstrate an adequate level of management control, it is strongly suggested carriers keep detailed records of any transportation safety-related training provided employees.

Comments

  1. 1. Shay [ April 17, 2013 @ 07:04PM ]

    Is a company who is no longer in business subject to these audits?

  2. 2. Joel Madrid [ December 28, 2013 @ 09:28PM ]

    Texas Training Center also known as TTCsafety.com is a great resource with Consultants for DOT Facility Audits, DOT Compliance and they even have a DOT Inspections Compliance Seminar that is held quarterly in Odessa, Texas or can be held anytime of year at your trucking facility.

  3. 3. Bill [ August 10, 2014 @ 07:27PM ]

    I find this information very enlightening. As in dealing with any law enforcement agency have the information they request "Ready", in order, and Only the information they request. Only present more information in the same fashion when they request it. That is to say: If the officer request your drivers license give him your drivers license. Not your insurance card and registration for the vehicle your driving. If he further requests your your insurance card then present him with your insurance card and not your registration. Listen carefully and the officer will tell you what he wants to know. Inform him of this and do not present the potential for further problems unless requested. Not only does it waste the officers time. It opens up the possibilities of unforeseen and unnecessary problems that both your company and the officer do not actually wish to deal with unless presented and thereby forced to deal with out of obligation. Knowing what they are looking for and knowing what they "may" request is important for preparation only. In the event they request something... Boom, here it is. The officer request further information, Boom, here it is. "to me" this is what makes this information contained in this article so valuable.

  4. 4. David Dimock [ February 23, 2015 @ 07:12AM ]

    Does anyone know of a class to teach company admins DOT compliance and the paperwork needed to pass future audits?

  5. 5. Michael [ March 18, 2015 @ 01:56AM ]

    Can a company change a mechanics comments on a DOT issue ?

  6. 6. sue rodrigues [ March 19, 2015 @ 01:34PM ]

    I can hear the drill for the root canal already while waiting for first audit.(jk) Thank you for the information, it was very helpful.

  7. 7. Zack [ April 15, 2015 @ 12:17PM ]

    Is there a company that I can hire to help me prepare for my audit? lol

  8. 8. John [ April 21, 2015 @ 10:52AM ]

    @Zack- please send me an email and I will see if I can help you with your upcoming audit.
    John

  9. 9. Lisa [ May 07, 2015 @ 10:29AM ]

    Zack, I know several companies depending what area you are based out of. send me your email and I could give you a list of companies that can help you.

  10. 10. Lisa [ May 07, 2015 @ 10:29AM ]

    Zack, I know several companies depending what area you are based out of. send me your email and I could give you a list of companies that can help you.

  11. 11. Elana [ May 28, 2015 @ 11:45AM ]

    We help carriers with all sorts of things rather it be finding direct shippers or tools needed to grow their operations sadly, we help companies bring in more business and get new contracts but we are not so familiar with the auditing end, one of my guys says he has to go to a place and wait to be audited with 200 more carriers, does this sound normal? Like I said we deal more with finding business opportunities for carriers than audits lol...if you need runs or training or dispatchers or want to grow or find shippers we can help, but audits I am at a loss lol anyone please email me [email protected] thanks

  12. 12. Jim [ June 24, 2015 @ 10:47AM ]

    I am so confused. I'm only pulling a 21' (total length w/tongue) food concession trailer. I have to go through all of this?

  13. 13. margo [ July 11, 2015 @ 09:17AM ]

    Can anyone answer this, if my company "created" documents to make it look like things in the qualification file had been signed years ago, forced drivers to backdate things prior to DOT coming in, and falsified records to make it appear they had sent out the required drug test request form to previous employers when in fact they never did..how bad is that for the company?

  14. 14. Edgar Vasquez [ August 26, 2015 @ 02:33PM ]

    If you are in the Washington DC, Maryland and Virginia area I will be more than happy to help you prepare a successful DOT audit. I specialize in bus companies. Send me and email with your information and I will get back to you promptly.

  15. 15. Cari Dominguez [ August 26, 2015 @ 05:23PM ]

    We help carriers with Company Structure formation, USDOT permits, authority, IFTA, Safety Audits, etc in English and Spanish in the Dallas-Fort Worth, TX area, Phone 214-559-8966
    [email protected]

  16. 16. Angel [ September 29, 2015 @ 07:05PM ]

    Maryland info

  17. 17. Stephanie [ October 13, 2015 @ 10:58PM ]

    Hello! I work in the office of a truck garage doing office administration and data entry. Basically I keep track of the paper trails that document all the repairs done to our fleet. I was hoping you could provide me with a resource that can tell me what exactly needs to be detailed in these reports. Basically I want to know what my paperwork should be documenting if my company were to ever be audited.

    Thank you!

  18. 18. Wronged [ December 13, 2015 @ 06:44AM ]

    I work for a company that outright refuse to fix the commercial truck I drive for them because I'm not a brown noser and have been reporting the same problems on the vehicle well into a year now .
    This company earns 30-50 million a year and plainly disregards any safe and legal operations required by DOT !
    What state inforcement agency will actually fix the problem ???

  19. 19. Monica A Lafaille [ May 02, 2016 @ 02:29PM ]

    The company I work for has just applied for a DOT # BUT we only use rental box trucks and NONE of my drivers need a CDL, do we still need a safety audit? Im extremely lost and confused

  20. 20. Janet [ June 15, 2016 @ 08:33AM ]

    If an investigator has been to the company previously can a different investigator be requested. Can an investigator demand to change an existing company policy if it's not in violations

  21. 21. juste [ June 18, 2016 @ 11:11AM ]

    please I need help about DOT audit, I am a new operator.

  22. 22. John Bruch [ June 21, 2016 @ 09:37AM ]

    @juste- please contact me with specific questions and I will do my best,

    [email protected]

  23. 23. Kimmie Samuel [ June 21, 2016 @ 09:59PM ]

    operated truck about 5 months no longer own truck have*nt owned truck sinse 2014 so DOT#2486657 no longer belong to me gave truck back to Prime Acres Management out of Woodville Texas

 

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