Is your company up-to-date and compliant with all Department of Transportation rules and regulations? Are you prepared for a DOT audit? Is your company even subject to DOT regulations? If you don’t know the answers to these questions, it may be time to take a look at your fleet’s degree (or lack) of compliance.
Who is Subject to DOT Regulations?
Some companies mistakenly believe their fleet is not subject to DOT regulations because they are not a trucking company. What many do not realize, however, is that a DOT number is required for any vehicle involved in interstate commerce that meets any of the following criteria:
- Transports hazardous materials of a type and quantity that requires an intrastate commerce safety permit.
- Has a GVW (gross vehicle weight) or GCWR (gross combination vehicle rating–applies to truck and trailer combinations) exceeding 10,001 lbs.
- Is used or designed to transport more than eight passengers for compensation or more than fifteen passengers without compensation.
In addition to the aforementioned federal regulations, 32 states require intrastate commercial motor vehicle registrants to obtain a DOT number. If this is the case in your state, there may be additional requirements to consider.
What Does a DOT Audit Involve?
In the course of a DOT audit, the auditee will be required to show documentation demonstrating their compliance with various regulations. This is intended to yield an accurate picture of both the company’s safety record and the propriety of their recordkeeping. In the event of an audit, a company should be prepared to show the following:
- Proof of liability coverage meeting the minimum levels of financial responsibility required by motor carriers.
- An MSC-90, countersigned by an insurance provider.
- The company’s accident register of DOT recordable accidents.
- Driver licensing, training records, and drug & alcohol testing records.
In addition to the documents listed here (and any others which the audit may require), driver logs will be examined to determine if these, too, are in compliance. The logs will be checked for violations of FMCSA driver regulations. These are numerous and can make keeping accurate records of driver activity difficult. Using automated vehicle tracking solutions can simplify this and help you meet DOT compliance and safety guidelines.
Commercial vehicles that meet certain qualifications will be subject to a review of maintenance and inspection issues during an audit. This is why it’s important to have on hand a vehicle maintenance file, containing records of any and all maintenance performed, for each qualifying vehicle. Inspection reports, including roadside inspections and post-trip inspections, should also be kept in these files.
DOT Compliance Checklist
There is a lot to remember when it comes to DOT compliance, which is why it’s important to prepare ahead of time for the possibility of an audit. To save yourself a headache down the road, make sure of the following:
- All DOT recordable accidents have been recorded.
- Drivers’ qualifications and performance records are current.
- All drivers are familiar with DOT/FMCSA regulations, have received a current copy of the FMCSA rules, and have signed a compliance agreement.
- A vehicle maintenance program has been created and successfully implemented.
- Pre- and post- trip inspections (for all vehicles) are performed and documented.
- Drivers’ hours of service are properly documented.
- All CMV entry-level driver training requirements are met.
- All commercial motor vehicles have DOT numbers.
It’s important to keep in mind that, in addition to these, steps should be taken to ensure compliance with DOT drug and alcohol policies. These steps include providing employees with relevant educational resources, performing and recording the results of pre-employment drug tests, and implementing a system for conducting regular random drug tests.
While no one will ever describe a DOT audit as a pleasant experience, much of the difficulty of the process can be minimized with careful planning, proper training, and good recordkeeping. By familiarizing yourself and your drivers with what is expected of compliant carriers, you can remove much of the confusion and uncertainty associated with DOT compliance.