A fact of life in professional driving is the audit. The Department of Transportation (DOT) takes its role as federal regulations arbiter very seriously and conducts its necessary audits of terminals and headquarters with a fine toothed comb. Safety teams live for preparing for these audits, but often they find themselves overwhelmed by their responsibilities and uncertain of where to direct their time and resources.
This Ultimate Guide is meant to be a resource to help understand, prepare for, and pass DOT audits and eliminate that uncertainty. In this guide, you will find:
Safety and Compliance managers have always dreaded an audit from the Department of Transportation. The overwhelming sense is usually that auditors are out to get companies for little errors and cheap fines. That might be true in some cases - every auditor is different - but the reasons they come to conduct audits at your terminal are almost always the same. Even in a pandemic world, auditors are busy looking out for negligent or careless management of safety protocols in order to keep our roads safer. But what are the main triggers for a DOT audit?
DOT audits can be a focused or full compliance review, as small or large as an auditor sees fit. To meet time constraints, focused audits tend to focus on one or two record types, such as hours of service. If an auditor finds issues in that group, the audit may expand to more drivers or more records, or convert the audit into a full compliance review, which will cover all major records.
At the conclusion of an audit, the auditor gives a grade of Satisfactory, Conditional, or Unsatisfactory. Satisfactory is of course a passing grade. Conditional suggests multiple violations that could incur fines and requires the company to submit a corrective Plan of Action to the DOT within 60 days to upgrade the status. The dreaded Unsatisfactory grade means major violations were found and could likely lead to hefty fines and, presumably, a followup audit in the future to ensure the corrective Plan of Action submitted has been followed. In the most severe cases, a terminal is shuttered or the company may even be shut down and have their DOT number revoked. There is also the uncommon grade of Unrateable, which is usually reserved for small, focused audits that would not feature enough records to get a full grade, but could still lead to fines if violations are present.
The major flags that DOT auditors tend to look for include: drug and alcohol testing violations of any kind, unlicensed or incorrectly licensed drivers, drivers who are not medically qualified, incomplete or missing maintenance records, driver log violations, operating vehicles that haven’t passed inspection or haven’t received necessary repairs, or any kind of record falsification. These are problem areas that are easy to address for a safety team on top of things. Begin to review these areas as well as the rest of your DOT paperwork and you will not have to worry about triggering a DOT audit.
On our podcast “Solving the Driver Problem”, we cover a variety of topics that attack the pain points facing managers and safety teams everyday in professional driving. Two episodes directly address the state of audits and safety in a changing, ever-more-digital world.
First, our episode featuring Clay Merches covers the “rules of the game” in safety. Merches is the president of LEC transportation safety consulting and a safety expert. He and AvatarFleet president Scott Rea discuss how to adapt your safety efforts to make DOT regulations palatable and easier to navigate when trying to stay compliant.
We also talked to longtime safety expert Irwin Shires and asked about his experience with managing DOT audits. Shires discussed how the digital, remote audit option is changing both how the DOT conducts its typical audits and how companies prepare for them.
It helps to know specifically what the DOT is looking for when they arrive to perform an audit. Below is our breakdown of the requirements of the driver qualifications file, as well as some of the other key items that often draw the DOT’s attention and likewise the most likely to lead to warnings and fines.
Managing your DQ Files doesn’t have to be a thorn in your side. You should never lose a wink of sleep when you find out you’re going to receive a DOT audit.
Save yourself precious time by utilizing a simple checklist and technology to automate the communication and document uploads from your drivers. No more hours wasted pushing papers.
This checklist is a summary from FMCSA 391 and is designed to help you ensure no little detail is missed when you’re creating DQ files.
There are several other records you will or may have to collect during a driver’s hiring process. Some of these, such as the criminal background check, typically are stored in separate paperwork from the Driver Qualification folder in a distinct HR folder of kind. With software systems, you can automate the folder labeling of these kinds of documents, as well as training documents, in a separate folder. Others, such as drug and alcohol test results, must be kept separate in their own specific folder per DOT rules for privacy and legal reasons. Consult both the DOT regulations and your state’s regulations regarding some of these specific records in order to make the best decisions regarding how to organize these other record types. However you choose to organize your records and streamline the audit, provide the auditor only what they asked for.
Rehired drivers who have left the company for more than 30 days must have a new and separate DQ File created upon their return to your company. This requires new documentation for all pre-hire records. You may use a valid CDL in lieu of a road test. You can build on any successfully conducted Verification of Employment during the original screening process and then conduct verifications for any period since leaving your organization. In addition, drivers who left the company for more than 30 days must undergo a new drug test.
In addition to these necessary items for your driver qualification files, you will also want to have the following critical items accounted for as they can be requested during an audit:
Managing this checklist for your fleet is a taxing process. Use the A-Suite to automate collecting, building and tracking your DQ files. Get back to more important tasks than paper pushing by trying the A-Suite Free today:
No one has ever accused the government of being cutting edge technology adopters. Without a literal act of congress, the FMCSA will have to audit your files in person for it to be on the record. That changed with the COVID-19 National Emergency Declaration which allowed for remote audits to go on the record. Emergency Declaration or not, this digital trend was started before COVID-19. For this reason, compliance software has never been more critical to track and store your hundreds of driver documents for ease of access and transfer. The perks in saving trees and time through digital recordkeeping (and money in the process) have caught on are a part of several recent changes, such as the establishment of the Clearinghouse and more widespread inclusion of electronic documents and signatures, that point the way to a digital future.
In light of this trend, compliance software has increased in popularity and value as a more efficient and effective system of record keeping than the old school file cabinet, leading to both fewer day to day headaches and less uncertainty when the DOT knocks at your door for an audit. But why would you pay for something your safety team already does themselves?
Compliance software will continue to grow in popularity as professional driving and the FMCSA adapts to the 21st century. In addition to making day to day life easier and more efficient for drivers and safety teams, they can also help ease your mind about potential DOT audits. If you know exactly where everything is at all times, you worry a lot less about getting fined or worse. Try out a compliance system like A-Suite for free and see if it can help you out in getting compliant and set for audits.
Compliance software will continue to grow in popularity as professional driving and the FMCSA adapt to the 21st century. In addition to making day to day life easier and more efficient for drivers and safety teams, they can also help ease your mind about potential DOT audits. If you know exactly where everything is at all times, you worry a lot less about getting fined or worse. Try out a compliance system like A-Suite for free and see if it can help you get (and stay) compliant.
Some other resources that might help you prepare and stay up-to-date on DOT audits:
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