The total number of DOT audits and off-site audits are expected to increase 50% in 2021, compared to last year.
The Federal Motor Carrier Safety Administration and its’ state partners have struggled to physically audit a significant number of motor carriers each year. This led them to develop the Compliance, Safety, Accountability program and Safety Management System that evaluates the safety of the estimated 500,000 active motor carriers it regulates.
As this program continues to evolve, with the delayed Item Response Theory (IRT) approach to identifying at-risk carriers for intervention, the FMCSA has been experimenting with off-site audits for eligible new entrant motor carriers.
While the first operational test of these off-site audits began nearly a decade ago, there has finally been more off-site audits than on-site audits in 2020. While off-site audits were ramped up during the COVID pandemic, the last few years has seen significant trends and they will only continue to increase moving forward.
Off-Site audits rise as FMCSA expands off-site comprehensive reviews
Last year the FMCSA performed nearly 11,500 audits with 5,750 of them being performed off-site. As of the end of May 2021, they have already conducted close to 3,500 off-site reviews and approximately 4,000 on-site reviews over that same period. At this pace, the agency’s investigators are on track to perform nearly 8,500 off-site audits by the end of the year, and around 18,000 audits overall.
While off-site audits were reserved for less intensive circumstances, such as new entrant safety audits and focused reviews which involved a lower volume of paperwork, the off-site review process has become more streamlined and reliable.
This has led to the FMCSA to publish a final rule last month that includes a path to rely more heavily on comprehensive off-site audits.
The amendments, by removing the word ‘on-site’ from the definitions of Compliance review and Roadability review in § 385.3, allows FMCSA and State personnel to conduct off-site compliance reviews of motor carriers following the same safety fitness determination criteria used in on-site compliance reviews.
How do you prepare for digital off-site reviews?
While one of the biggest benefits of off-site audits to both the FMCSA and carriers is the paperwork reduction, you need to be prepared to upload compliance documentation to the agency on short notice.
This includes your:
- driver qualification,
- drug and alcohol testing,
- vehicle maintenance files,
- proof of insurance,
- accident register, and
- other compliance documents.
In off-site audits, the FMCSA requires carriers to upload records through their Safety Measurement System account. This means that if you maintain hard copies of the requested records, you will first have to digitize them to transfer them to the investigator.
Large carriers and owner-operators alike should store these files electronically, instead of the traditional filing cabinet or paper binder, and keep them up to date and compliant.
As the FMCSA continues to rely more heavily on off-site audits, carriers need to adapt. This may mean having an outside representative perform a mock audit to reveal any DOT compliance gaps you may have.
The best tip we can provide carriers is to exceed, and not “just meet”, the DOT regulations.
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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.
We offer several different program levels depending on the size of your organization, however our PSM Motor Carrier Program is the more common when considering affordability and the comprehensiveness of DOT compliance assistance.
Our PSM Motor Carrier Program includes:
- DOT audit support
- ELD management
- Driver Qualification File Management
- New driver on-boarding
- Driver safety meetings
- CSA score management
- Policies and handbooks
- Vehicle maintenance
- and more