Any time a driver is placed out-of-service at roadside, it increases the chances of a company audit.
While a safety audit can occur at any time, there are many red flags that trigger the FMCSA to review a company’s operation.
Part of being prepared for a compliance review is knowing what can trigger an audit and how to prevent them from happening.
We will cover five common triggers that could prompt a DOT audit, which include:
- High CSA scores
- Roadside Out-of-Service Violations
- Failing a new entrant audit
High CSA scores can trigger a DOT audit
The FMCSA created the Compliance, Safety, Accountability (CSA) program as a method of identifying high-risk commercial motor carriers, as well as the Safety Measurement System (SMS) which uses data from state-reported crashes, roadside inspections, and investigation results from the last two years.
Poor CSA scores will increase your chance of an audit because there are certain “Intervention Thresholds” the FMCSA uses to prioritize interventions.
Interventions are based on the number of percentiles a carrier has at or above the established BASIC Intervention Thresholds.
Being at or above these threshold limits will likely trigger a comprehensive compliance review:
|BASIC Intervention Thresholds||General||Hazmat||Passenger|
|Unsafe Driving, Crash Indicator, HOS Compliance||65%||60%||50%|
|Maintenance, Controlled Substances, Driver Fitness||80%||75%||65%|
Crashes can trigger a DOT audit
While a single crash could trigger an audit, the severity of the accident will increase your chances and possibly trigger a compliance review without any prior notice.
When it comes to the Unsafe Driving/Crash BASIC indicator, too many violations could trigger an audit.
To reduce the chance of violations in this area, carriers should:
- Avoid hiring drivers with a history of speeding
- Eliminate or minimize in-cab distractions like texting and eating
- Ensure drivers always wear seat belts; and
- Encourage drivers to avoid tailgating or change lanes without signaling
Out-of-service violations at roadside inspections can trigger a DOT audit
Any time a driver is placed out-of-service at roadside, the chances of a company audit increase.
To prevent drivers from being pulled in for a roadside inspection, carriers should focus on keeping the ISS score and out-of-service ratings as low as possible, especially below the national average.
- ISS Score
- 1-49 = Passing
- 50-74 = Optional
- 75-100 = Inspect
- Driver Out-of-Service national average = 5.5%
- Vehicle Out-of-Service national average = 20.7%
While inspections do happen at random, there are common things that roadside inspectors look for when determining what drivers will be pulled in for inspection.
For example, if you have a headlight out, inspectors may assume the driver did not do a good pre-trip inspection and there could be other maintenance violations they will want to check in more detail.
Additionally, if your truck is dirty, inspectors may assume the driver is not taking care of bigger problems, like brakes or suspension.
Failure of a New Entrant Audit can trigger a DOT audit
While investigators understand that the new entrant audit is a learning curve for many new carriers, the FMCSA will monitor those who did not pass their first audit.
This is where having a firm grasp on the regulations is critical.
A lack of basic safety management controls or failure to comply with any one of the following 16 regulations will result in a notice to revoke your USDOT new entrant registration unless immediate action is taken:
- Failing to implement an alcohol and/or controlled substances testing program
- Using a driver known to have an alcohol content of 0.04 or greater to perform a safety-sensitive function.
- Using a driver who has refused to submit to an alcohol or controlled substances test required under part 382.
- Using a driver known to have tested positive for a controlled substance.
- Failing to implement a testing program for alcohol and/or random controlled substances.
- Knowingly using a driver who does not possess a valid CDL.
- Knowingly allowing, requiring, permitting, or authorizing an employee to operate a commercial motor vehicle with a commercial learner’s permit or commercial driver’s license which is disqualified by a State, has lost the right to operate a CMV in a State or who is disqualified to operate a commercial motor vehicle.
- Knowingly allowing, requiring, permitting, or authorizing someone to drive who is disqualified from driving a commercial motor vehicle.
- Operating a motor vehicle without having in effect the required minimum levels of financial responsibility coverage.
- Operating a passenger carrying vehicle without having in effect the required minimum levels of financial responsibility.
- Knowingly using a disqualified driver.
- Knowingly using a physically unqualified driver.
- Failing to require a driver to make a record of duty status.
- Requiring or permitting the operation of a commercial motor vehicle declared ‘‘out-of-service’’ before repairs are made.
- Failing to correct out-of-service defects listed by driver in a driver vehicle inspection report before the vehicle is operated again.
- Using a commercial motor vehicle not periodically inspected.
Complaints can trigger a DOT audit
Finally, anyone who finds out that a motor carrier or truck driver is engaging in negligent behavior can file a complaint with the FMCSA within 90 days from the time they learned about the behavior.
To file an FMCSA complaint, they can either call the agency at 888-DOT-SAFT or fill out an online complaint form.
Once the complaint is submitted, it becomes part of the trucking company’s permanent record in the National Consumer Complaint Database and will eventually prompt the FMCSA to investigate, especially if there are multiple recent or serious complaints.
Proactive Safety Management
Accuracy, organization, and diligence are crucial to keeping your files in order and ready for an audit at a moment’s notice and ensuring new drivers are properly qualified before operating in a safety sensitive position.
At CNS, our DQ file management system is completely customizable to your company’s needs. The consultants at CNS stay in communication with you regarding document updating, as well as offering comprehensive reports upon request, and reports of routine audits by our own DQ file auditors.
Our DOT Compliance Specialists will ensure all DQ files for your company will be ready to pass an FMCSA audit.
Beyond DQ files, our safety management programs are perfect for combining multiple services and focuses 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