Best Practices to Prepare for a DOT Audit
The best way to prepare for a DOT audit is to PREVENT a DOT audit in the first place, I promise!
Even though most compliance reviews are conducted online these days, any compliance review will take up a significant portion of your time and energy.
The mere mention of these words is enough to cause most trucking company owners a slight panic attack! You should try to do all that you can to avoid these uncomfortable examinations of your entire business!
The preparation for a successful Compliance Review, or DOT audit, begins well in advance of the inspectors first reaching out to you.
Remember that the purpose of a DOT audit is to ensure that you have established “adequate management control of”… pretty much everything that the FMCSA regulations cover. This control must start at the top management ranks and be communicated to everyone.
The message across your organization has to be “Safety is our highest priority!”
Avoid Unwanted Attention from Law Enforcement
The first and most obvious way to avoid DOT scrutiny is to try and stay out of the DOT’s sights as a target for an audit. Now with the Compliance, Safety, and Accountability (CSA) program, in full effect, keeping your BASIC scores well below the ALERT thresholds is critical.
You can learn more about how the FMCSA uses the CSA program to keep score by using the link above.
A key to successfully managing your CSA BASIC scores is to ensure that your drivers are operating safely and complying with all FMCSA regulations while on and off the road.
While this may seem like a pie in the sky dream, focusing on the basic “blocking and tackling” violations is critical.
Drivers should avoid drawing unwanted attention from law enforcement by avoiding being BUSST’ed!
BUSSTed is my super corny acronym for:
- B Burnt Light Bulbs
- U Unrestrained Drivers
- S Speeding
- S Signs (Failure to Obey Traffic Devices/Signs)
- T Texting or using a cell phone while driving
Pro Tip: These 5 “BUSSTed” violations are “Gateway” violations and account for about 90% of all violations found at the roadside each year.
I call these violations “Gateway” violations because these are all easily observed by law enforcement. They serve as an invitation for an officer to pull your truck over and see what else might be amiss…perhaps with your driver’s ELD records, brakes or tires?
If they’re not pulling your trucks over for one of these 5 violations, then they’re not inspecting the rest of the truck, trailer and driver. It’s very much a game of picking the “low hanging fruit”.
The Inspection Selection System
The ISS Is not your friend!!
The FMCSA prioritizes trucks for inspections at weigh stations using their “Inspection Selection System” (ISS) scoring process.
The more problems that are found during roadside inspections, the higher your BASIC score in each of the categories will be.
The higher your BASIC scores (especially in the Hours of Service and vehicle maintenance BASIC areas), the more often your trucks will be inspected at weigh stations due to the ISS.
This is one of the primary numbers that the DOT inspectors inside of the chicken coop will use to determine if your driver and/or truck should be inspected.
So, it is critical that you monitor your CSA scores at least monthly in order to ensure continued compliance.
Proper Recordkeeping for a DOT Audit
If your roadside inspections are a bit too far gone and you have a couple of alert triangles haunting you every time that you check your CSA BASIC scores, then you had better be good to go when the FMCSA or State DOT calls you.
Pro Tip: Those drivers and vehicles that were involved in the most recent roadside inspections with violations are almost certain to be audited during a compliance review!!
Where you should spend your time preparing depends on what BASIC category those triangles are in.
Driver Related Compliance
If your Unsafe Driving, Controlled Substance and/or Driver Fitness scores are high, focus your time and efforts on making sure that your driver qualification files are in great shape.
Start by focusing on drivers who had roadside violations during the last 12 months. That’s the most likely files that will be pulled for audit!
Hours of Service
Is your HOS Compliance BASIC score in alert status? Make sure that:
- Drivers avoid using personal conveyance excessively
- Drivers are using personal conveyance properly
- There is very little “Unidentified Driving Time” showing in your system
- Drivers are not unplugging or obscuring the signal on their ELD device
- That you have complete supporting documents for each of your driver’s trips for the last 6 months.
Vehicle Maintenance
Is your Vehicle Maintenance BASIC score not looking too good? Make sure that:
- You have all of your repair receipts for all vehicle maintenance violations discovered during roadside inspections over the last 12 months
- You have DVIR (Daily Vehicle Inspection Reports) for any defects detected during the last year
- You have up to date Annual DOT Inspection for all trucks and trailers in your fleet
- You have a vehicle maintenance file for each truck and trailer that includes a record of when all repairs and maintenance was completed over the last 12 months (at least).
Start by focusing on trucks and trailers (or buses) that had roadside violations during the last 12 months. That’s the most likely files that will be pulled for audit!
Pro Tip: It doesn’t matter if you only have independent contractors or owner-operators working for you. If a truck is running under your authority, you must have a complete and accurate vehicle file for that truck (and trailer)!!
How To Improve Your Chances of Being Audited
There are a few very good ways to jump the compliance review line ahead of other trucking companies. If you want to avoid a compliance review, avoid these situations at all costs:
- Having 2 or more BASIC scores above 90% for more than 2 months in a row
- Having a Vehicle Out of Service Percentage score above 34% combined with a Vehicle Maintenance BASIC Alert
- Having a crash with a fatality
- Having any violations for drivers operating while their license is suspended
- Having one (or more) “Red Flag” violations:
- 1. Operating an out-of-service vehicle.
- 2. Driving while declared out-of-service.
- 3. Possessing alcohol, using alcohol or being under the influence of alcohol within four hours of being on-duty.
- 4. Driver use of drugs or possession of drugs.
- 5. Driving a commercial vehicle while disqualified (391.15).
- 6. Disqualification of the driver from operating a commercial vehicle.
- 7. Driver operating a vehicle type for which he or she lacks a valid license.
- 8. Unqualified driver.
- 9. Operating a commercial vehicle with the wrong CDL group.
- 10. Operating a commercial vehicle without a valid CDL license.
- 11. Operating a commercial vehicle with more than one driver’s license.
- 12. Driving a commercial vehicle while disqualified (383.51).
If any of these violations are found at the roadside or at weigh stations, then expect that your DOT audit number will be called much sooner rather than later!
Prepare for a DOT Audit: Proper DOT Recordkeeping
The Federal Motor Carrier Safety Administration (FMCSA) is the law of the land when it comes to motor carrier safety.
You must keep your Driver Qualification Files and other records in order to prove to the auditor that you have control of your safety and compliance programs.
Also, be sure to update your MCS 150 on a regular basis! This will help with your Unsafe Driving and Crash BASIC scores.
Even though it may be after-the-fact, once you know there is a problem or opportunity to improve, you have the opportunity to design a plan to correct it (the DOT refers to a “good faith effort”, in industry we may call it CYA).
All of this data, whether it is designed to meet FMCSA requirement or internal operations metrics, should be audited as promptly as possible for both legal and performance reasons.
All carriers should have a weekly or even daily internal audit program to check records that are turned in. These records must be organized and maintained to be ready on short notice.
When working with the FMCSA you’ll learn quickly that “if there isn’t a document to prove it, then you didn’t do it”.
Counseling and correction if applicable should be done BEFORE they are filed if possible. Holding employees accountable for their performance is essential to any long term audit success and ultimately, profitability.
The daily operational demands of a fleet can often overshadow the priority of safety, even in a well-run company.
Internal audits may be postponed or they may be skipped altogether because you don’t have time that day. Records might begin to get backlogged and not filed. Sometimes, life just gets in the way!
If you find yourself in this situation, having a trucking safety manager like our My Safety Manager program can make all the difference!
We will conduct regular simulated DOT audits to make sure that you’re always “audit ready”!
These “mock audits” will provide an opportunity for us to help fine tune and correct any issues before the DOT calls or worse yet, after there has been an accident and what could have been prevented has just happened and it’s too late.
A Successful DOT Audit Should Be A Secondary Goal
3000-5000 fatalities happen every year involving a commercial motor vehicle. 70% of these are the other vehicle’s fault.
That leaves 30% of the fatalities (approximately 1500 per year) who have been killed because of something we did or didn’t do in our industry.
Passing a DOT audit is not our primary objective for a solid safety and compliance culture—safety of your employees and the public should be the primary focus of all carriers.
None of us want to be involved in any way with hurting someone or calling a spouse to say that their partner is not coming home. Preparing for a DOT audit will reap incredible benefits for your company, your employees, and the public.
Our trucking safety and compliance experts can help you prepare for a DOT audit!
If you’re DOT compliance review didn’t go well and you ended up with a Conditional DOT rating or an Unsatisafactory DOT rating, we can help fix your conditional rating!
Simply call 1-855-211-5550 to learn more!
My Safety Manager is a leading provider of fleet safety management and trucking compliance services for fleets of all sizes.
Our specialized safety management solutions help deliver results—safe drivers out on the road who are staying compliant with FMCSA regulations.
We work with you to create customized solutions that meet your unique needs, taking what’s typically far too much work off your plate so you have more time to grow your business!
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