Did you receive an email or phone call requesting an FMCSA safety audit or comprehensive compliance review?
What is an FMCSA Safety Audit or Compliance Review?
A safety audit or compliance review is an examination of a motor carrier’s records in all categories of safety compliance by a safety investigator from the FMCSA.
Any motor carrier can be selected for a compliance review at any time, but generally selections are based on multiple BASIC stats being over threshold or as the result of a serious accident or complaint.
While there are many different types of audits a carrier can face, the mindset and procedures are similar when preparing for any audit and the best defense is knowledge about what happens in an audit.
Let us look at the comprehensive review process, common violations auditors look for, and eight best practices when preparing for an FMCSA audit.
Scheduling an FMCSA Compliance Review
Regardless of the reasons you were selected for an FMCSA audit, the DOT officer or state representative will contact you to schedule the compliance review, primarily by phone, and then email.
Motor carriers should not delay responding to the DOT auditor because ignoring their requests—especially the “no contact letter” or “demand letter” for scheduling an audit—could lead to fines of up to $10,000 and/or suspension of their operating authority.
When you are scheduling the DOT audit date, carriers should plan for two weeks to one month to prepare, but should understand that audits can be scheduled with only 48-hours of notice.
Note: In certain situations, like after a serious crash, the compliance review audit could happen without any prior notice.
After scheduling the review date, the auditor should provide the carrier a list of items they want you to provide along with a current list of carriers and vehicles that have operated in the previous 12 months.
How to prepare for the FMCSA audit
Generally, carriers only have about 2 weeks to prepare for an audit. However, following audit preparation best practices and staying organized on a regular basis will prevent any last minute scrambling.
All carriers will inevitably be subject to some type of audit, so it is never too early to prepare, and going above and beyond the DOT compliance requirements will only make this process smoother.
Impressing the DOT auditor and keeping them in a good mood throughout the audit goes a long way.
There are 9 steps of a comprehensive compliance review, which are:
- Opening Interview
- Driver Qualification Files
- Hours of Service
- Drug and Alcohol
- Financial Responsibility
- Accident Review
- HAZMAT, if applicable
- Close Out Review
While all recent files must be made available for the auditor to review, they will only look at a sampling of the files and look for the commonly missed items.
However, they will likely start by reviewing drivers that have a red flag violation on file and look closely at every area that has had a previous violation on record.
This is where paying attention to details can mean the difference between passing and failing an audit.
Below are common issues inspectors look for in each step of the compliance review.
Driver Qualification (DQ) Files
When it comes to DQ files, the most common items missing are:
- the annual motor vehicle record,
- a list of violations from the drivers, and
- a record of the annual driver review
Hours of Service (HOS)
For hours of service, auditors will request all supporting documents, such as bills of lading, fuel receipts, weight tickets, lodging, and more.
If carriers withhold any supporting documents, the violation is weighted the same as having a false log. This is a common area where non-compliant carriers think they can hide information that could prove hours of service violations, but inspectors know what to look for.
Drug and Alcohol
The most common documents missing from drug and alcohol files are:
- pre-employment test results for each driver
- reasonable suspicion testing results
Another common issue are carries diluting the random drug testing pool by having non-CDL drivers in a CDL-only pool. While this may be an innocent mistake, this reduces the chances of required drivers being randomly selected for a drug test.
There are five areas in a maintenance review, which are:
- annual inspections
- preventative maintenance schedule
- random or repair maintenance
- daily vehicle inspection reports
- DOT roadside inspections
The auditor will look for any vehicle that was operating with an out-of-service maintenance condition by comparing when a maintenance issue came up and when the repair was fixed.
Best practices when preparing for a DOT audit
Now that you understand the common violations found in an FMCSA safety audit, how can you prevent these violations from happening to you?
There are 8 best practices every carrier should prioritize:
- Maintain good record-keeping procedures – keep all documentation current and accurate
- Good company policies – Focus on hiring, work, and discipline
- Proof of consistent Hours of Service – monitoring, auditing, and corrective actions for logbook violations
- Maintain good vehicle maintenance records – DVIR, annual inspections, and preventative maintenance
- DO NOT wait until the last minute to get files ready
- Establish a voluntary “Cooperative Safety Plan” – file it with the FMCSA to address any underlying issues that have or could potentially lead to safety issues and improve its performance
- Conduct Mock DOT audits – Third-party experts can go through the audit process to identify issues that need correcting
- Act quickly to fix any problems discovered – Pay special attention to high-risk issues
Are you being reactive or proactive?
The best tip we can provide carriers is to exceed, and not “just meet” the DOT regulations.
At CNS, our DOT Compliance Programs focus on Proactive Safety Management (PSM), a mindset that will ensure your fleet’s safety and compliance is always in order and ahead of the FMCSA.
Our PSM Motor Carrier Program includes:
- ELD management
- Driver Qualification File Management
- New driver on-boarding
- Driver safety meetings
- CSA score management
- Policies and handbooks
- Vehicle maintenance
- and more