DOT audits
Commercial vehicle fleet compliance is essential.
To many wholesalers, commercial vehicle fleets are an essential cog in our wheel of success.
Commercial motor vehicles and their myriad regulations generally refer to vehicles over 10,000 gross vehicle weight. Vehicles with a GVW of 26,001 or more require drivers maintain a valid commercial drivers license. Prior to hire, prospective drivers must be vetted to ensure they have the driving record and skills to safely operate a commercial motor vehicle and are drug-free.
Various educational standards must be met by both drivers and their supervisors. Driver files with multiple documents must be maintained and updated annually. Procedures must be in place to ensure vehicles are inspected with each trip and routine maintenance is performed as well as a comprehensive annual inspection by a certified mechanic. Hours of service must be tracked and log books maintained when required.
Accidents must be tracked and measures taken to address the root cause of recordable accidents.
Maintaining a fleet of commercial motor vehicles is not for the faint of heart. No one wants to hear this: “Oh no! We received a letter informing us of an audit that will be performed by the Federal Motor Carrier Safety Administration investigator. What do we do?” Torrington Supply‘s Melanie Felladore recently received one of these letters and successfully navigated a DOT audit.
Her advice? “Relax but be prepared,” she says. “Know what you are required to do and then do it!” Some key steps in preparation are to review the list of documents that the investigator requests and ensure the proper documents are in place.
The DOT has two types of audit programs. The first is a safety audit designed for new entrants into interstate operations. SA’s are generally conducted within 18 months after the beginning of operations. SA’s provide educational and technical assistance on safety and operational requirements of the Federal Motor Carrier Safety Regulations and applicable hazardous materials regulations. The SA gathers critical safety data needed to make an assessment of the carrier’s safety performance and basic safety management controls. Audits do not result in safety ratings or civil penalties, rather a pass or fail grade. It is important to note that even if civil penalties are not taken, a carrier’s registration may be revoked as a result of failing a SA. If certain review violations are discovered during the audit, the audit may cease and a compliance review will instead be conducted. If a SA converts to a compliance review, enforcement for violations cited on the CR is possible.
The second type of audit program is the CR where enforcement for violations cited may result in civil penalties, a conditional or unsatisfactory safety rating and possibly revocation of operating authority. Essentially, both audits look at the same information. In the former the emphasis is educational and technical assistance, and the latter is on compliance and stiff civil penalties.
In each of the audits, the auditor will interview management with questions which will provide a systematic review of the carrier’s operations. Answers serve as indicators of the effectiveness of the carrier’s compliance with applicable regulations. A review of the documents will further refine the assessment. Records that are reviewed include driver files; drivers records of duty status; vehicle maintenance, including maintenance and repair records; accident register; adherence to controlled substances and alcohol use and testing requirements and education; CDL license standards; financial responsibility (insurance); transporting and marking of hazardous materials; economic regulations; and operating authority.
Additional information relating to FMCSA audits can be found at www.dot.gov. There is a great deal of information available online to help you ensure that you are meeting the fundamental requirements of the regulations and that you can continue to field your fleet of commercial motor vehicles.
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