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Safety & Accident

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. sarwar [ November 29, 2013 @ 07:56AM ]

    Hi..Great Post.Now i can easily prepare my dot audit.I have some information's about dot audit and i think it's very helpful for anyone.Discuss below:
    The way to pass a DOT audit is planned to be certain that you are in compliance in the beginning and that the company’s software team understands the regulations to that are subject and the things records the DOT expects to work out. Staying on top of those regulations could be more important than ever given that the Vogel Safety has introduced an exciting new enforcement and compliance device that targets the essential safety problems of both car carriers and their drivers to relief commercial motor vehicle-related collisions and fatalities. The Comprehensive Safety Researching 2013 (CSA 2010) establishes an exciting new nationwide system for having the roads safer for motor carriers and therefore the public alike. It also creates an exciting new Safety Measurement System (SMS) that measures the last two years of roadside infractions and crash data. By means of SMS, every inspection numbers, not just outof-service infractions, and both driver and additionally carrier safety performance really are monitored.

    Motor Carrier Essential safety Rating
    The motor carrier safety rating is really an evaluation given to any interstate commercial motor transporter. A safety rating will depend on a DOT audit, that is absolutely triggered in response towards request to change a fabulous safety rating, to study potential violations of essential safety regulations by motor carrier's, or
    to investigate complaints or other proof safety violations. One of three safety ratings would be issued following a US DOT audit -satisfactory, conditional, or possibly unsatisfactory. A “satisfactory” rating mean that a motor carrier has on hand and functioning adequate safety management controls to pay the safety fitness basic. A “conditional” rating means that a motor carrier
    doesn't possess adequate safety management controls on hand to
    ensure compliance along with the safety fitness standard in 385. 5
    of all the FMCSR. An “unsatisfactory” credit score means a motor transporter
    does not have the correct safety management controls on hand to
    ensure compliance along with the safety fitness standard.
    The DOT accident registry is really an important component in finding
    a company’s motor transporter safety rating. If the agency
    has more than 1. 5 reportable US DOT accidents per million
    mileage, the carrier automatically should get a “conditional” rating
    prior to when the audit even starts. Pc findings, the
    carrier could quite possibly receive an “unsatisfactory” credit score.
    The results of process roadside truck inspections could perhaps result
    in a “conditional” or possibly “unsatisfactory” rating. When all the roadside
    inspections result with an “out-of-service finding of across
    34 percent, the transporter receives an “unsatisfactory” credit score. Any
    HAZMAT deficiencies found big butter jesus started roadside inspections
    also translates to an “unsatisfactory” rating.
    Mostly, once a carrier should get an “unsatisfactory” motor
    transporter safety rating, the company has 60 days for you to a safety
    management arrange that addresses the insufficiencies identified in
    the audit and explain exactly what is being done to better its fleet
    safety surgical treatments. A subsequent on-site audit would be required
    in order to work out if the proposed “unsatisfactory” essential safety
    rating becomes final. Any time an “unsatisfactory” rating will get
    final, the carrier will have to cease interstate motor transporter
    operations.
    An onsite US DOT audit evaluates the company’s essential safety performance
    and confirms ideal and complete recordkeeping. All the
    review also determines if for example the company has adequate software
    controls in place to assure Vogel Safety compliance. A fabulous
    DOT audit covers nearly four main factors - illegal drug and alcohol testing,
    airport taxi driver qualifications, hours-of-service, and used car maintenance.

    Drug and Alcoholic beverage Testing
    DOT’s substance physical or mental abuse testing requirements includes preemployment
    illegal drug testing (382. 301), post-accident illegal drug and
    alcohol testing (382. 303), non-selected drug and alcohol trying out
    (382. 305), and competitive suspicion (382. 307). A fabulous written
    drug and alcohol testing policy is and is reviewed at the time of
    an audit to ensure contained in the grapefruit all required components really are
    covered in the protection. The policy must come to be
    distributed to CDL drivers along with signed
    receipt from each driver must remain on file
    and accessible to inspection.
    The DOT auditor reviews records to work out
    if testing complied by means of regulations,
    tests were directed on federal
    custody and additionally control forms, and workout
    for supervisors on “reasonable suspicion”
    trying out was completed. To measurement whether
    the company’s pre-employment illegal drug
    testing is sufficient, inspectors should pull
    the records relating to newly-hired drivers to
    ensure there may proper documentation on
    endorsed DOT testing forms. Any time documentation
    cannot be if new
    drivers are being tested consistent with DOT regulations, the
    audit results would be impacted. The inspectors might also examine
    the previous year’s program and testing so that 50
    percent of the company’s drivers had been randomly tested
    for drugs and ten percent for alcohol.

    Driver Qualifying measures
    As part of all the DOT audit preparation, the agency should
    pull all airport taxi driver qualification files, which carry information
    such as every driver’s license will expire and therefore the driver’s
    driving history and additionally performance. Also present on the files
    should be read me files of reference checks directed for
    all new employs that indicate previous hiring managers were contacted
    and asked to the new hire’s accident and additionally safety history.
    The driver qualification file will typically include the driver’s
    a career application, in the driver’s personally own handwriting.
    HAZMAT drivers requires clear a background check through
    FBI and other criminal agencies, as well for the Immigration
    and Naturalization Service plan.
    There should also be evidence that driver’s motor vehicle
    records (MVR) were obtained (for the last three years)
    and examined combined with documentation of any airport taxi driver training
    and testing. The files will incorporate each driver’s medical
    cards showing the answers of their last a couple of years of physical
    exams, which must remain conducted by a to ensure doctor according
    to US DOT regulations.
    Driver qualification files might indicate all training of the fact that
    driver received, written studies on traffic regulations, and therefore the results
    of company-administered avenue safety tests. Driver essential safety
    training is generally recommended that should be conducted on a
    daily basis, which may feature training at weekly or possibly month
    safety meetings. Performing a driver safety workout class once
    a year for high-risk operators or high-volume drivers combined with
    conducting ride-along observations is normally recommended practice.
    In short-term, companies should be positive about their driver’s
    safety and continually observe their performance and present
    feedback to their operators. A company’s insurance transporter might
    provide driver essential safety training classes and/or make fun of DOT audits,
    often free of charge.

    Hours of Service
    An alternative factor a DOT essential safety audit will examine is normally whether
    the company’s operators are meeting the hours-of-service standards
    and are keeping specific and complete log novels.
    The DOT expects a few months of driver logs and additionally supporting
    documents be provided during the review. A fabulous carrier is
    expected to keep your a file (electronic or paper) from each regulated
    driver. The US DOT examines these logs just for violations of:
    • Create and Manner (395. 8[d])
    • Hours-of-Service (395. 3)
    • Falsification about Logs
    Form and manner in fact is the information required relating to the
    driver’s log. Hours-of-service violations occur every driver
    exceeds the 11-hour, 14-hour, or 60-hours in 7 days or
    70 hours for eight days rules (see Dinner table 1). Falsification is
    checked using supporting documents specifically requested.
    A log must remain maintained by every airport taxi driver, according to DOT
    codes. So make sure the drivers are writing their logs
    completely and not just exceeding the maximum periods allowed
    behind the take.

    Vehicle Maintenance
    Part for the DOT audit will be verifying that vehicle and
    trailer a provider owns and/or operates boasts a written maintenance
    record that documents the car is in good remedy and
    is regularly examined, repaired and maintained. Restricted to ,
    inspections that drivers do themselves combined with annual inspections,
    vehicle maintenance logs and therefore the qualifications of those
    laborers conducting the inspections. Just about every single repair or maintenance
    activity must remain recorded - even evolving the tire.
    Each vehicle need a vehicle maintenance computer file. In addition
    to containing records at all repairs, inspections, or repairs and maintenance
    performed on that used car, the file should finally detail
    the following:
    • Supplier number (or license food number)
    • Model and additionally year
    • Vehicle individuality number (VIN) or serial telephone number
    • Tire size
    • Person (if not the car carrier)
    Thanks.
    [link|http://www.vogelsafety.com|dot compliance help]

  3. 3. 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.

 

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