DOT Safety Audit 101: Key Insights for Commercial Motor

What is FMCSA Safety Audit and Why is it Important?

According to the Federal Motor Carrier Safety Administration (FMCSA), a DOT safety audit is “a review of a motor carrier’s records designed to verify that a carrier has basic safety management controls in place to ensure compliance with applicable Federal Motor Carrier Safety Regulations (FMCSRs), Hazardous Materials Regulations (HMRs), and related record-keeping requirements.

A safety audit is part of the New Entrant Safety Assurance Program, which affects U.S. and Canada-based motor carriers that apply for a U.S. Department of Transportation (DOT) identification number. The program monitors the safety performance of new entrants during their initial 18-month period of operation. If you pass the safety audit, you will be granted permanent authority to operate in interstate commerce. If you fail the safety audit, you may face enforcement actions, such as fines, penalties, or revocation of your operating authority.

How to Prepare for FMCSA Safety Audit?

To prepare for a safety audit, you need to understand the requirements and expectations of the FMCSA. You also need to maintain up-to-date records and conduct periodic inspections and maintenance on your commercial motor vehicles (CMVs). Here are some tips to help you get ready for a safety audit:

Review the FMCSA regulations and guidance that apply to your operation. You can find them on the FMCSA website or in the Motor Carrier Safety Planner.
Gather and organize your records and documents that demonstrate your compliance with the regulations. These may include your insurance coverage, driver qualification files, drug and alcohol testing program, hours of service records, vehicle inspection and maintenance records, hazardous materials transportation records, and accident history.
Conduct a self-audit or internal review to identify and correct any issues or gaps in your safety management system. You can use the Safety Audit Resource Guide to help you with this process.
Cooperate with the auditor during the safety audit. Provide accurate and complete information, answer questions honestly, and show evidence of your safety practices. Be professional and courteous throughout the audit.
Follow up on the results of the safety audit. If you pass the audit, you will receive a satisfactory rating and continue to operate normally. If you fail the audit, you will receive a conditional or unsatisfactory rating and be subject to enforcement actions such as fines, penalties, corrective action plans, or suspension or revocation of your operating authority. You should take immediate steps to remedy any violations or deficiencies and improve your safety performance.

What are the requirements of DOT safety audit?

To pass a safety audit, you need to have the following documents and records ready for review by the auditor:

A copy of the Federal Motor Carrier Safety Regulations (FMCSRs) and Hazardous Materials Regulations (HMRs)
A copy of the MCS-90 form or proof of financial responsibility
A policy for drug and alcohol testing program
Pre-employment drug test results for all drivers
Random drug and alcohol test results for all drivers
Post-accident drug and alcohol test results for all drivers
Motor Vehicle Records (MVRs) for all drivers
Proof of CDL for all drivers
Driver qualification files for all drivers
Driver logs or electronic logging device (ELD) data for all drivers
Vehicle inspection reports for all vehicles
Vehicle maintenance records for all vehicles
Vehicle identification numbers (VINs) for all vehicles
Vehicle markings for all vehicles
Out-of-service criteria for all vehicles
Hazardous materials registration (if applicable)
Hazardous materials shipping papers (if applicable)
Hazardous materials placards, labels, and markings (if applicable)
Hazardous materials packaging specifications (if applicable)
Hazardous materials emergency response information (if applicable)
Hazardous materials security plan (if applicable)
Accident register for the past 12 months
Reports of accidents for the last 12 months
Preventability analysis for the past 12 months
Corrective actions for the past 12 months

You should also be prepared to answer questions from the auditor about your operations, policies, procedures, and practices. You should be honest, cooperative, and professional during the audit.

What are the common violations in FMCSA safety audits?

Some of the common violations in FMCSA safety audit are:

Allowing a driver to operate with a suspended or revoked commercial driver’s license (CDL) or with more than one CDL.

Failing to implement or conduct an alcohol and/or drug testing program for drivers.
Not having a DOT-compliance certificate from third-party administrators.
Not using the appropriate method to record hours of service or falsifying the driver’s record of duty status.
Not keeping inquiries into employment records in the driver qualification file or using a driver before receiving a pre-employment result.
Using a commercial motor vehicle that has not been periodically inspected or that has been declared out-of-service for safety deficiencies.
Not properly maintaining vehicle logs and records or failing to correct defects noted on previous inspection reports.
Improper loading or securement of cargo.

Key Takeaway

FMCSA safety audit: a review of a motor carrier’s records to verify compliance with federal safety regulations and related requirements. It is part of the New Entrant Safety Assurance Program for new carriers that apply for a DOT identification number.

Importance of safety audit: Passing the safety audit grants permanent authority to operate in interstate commerce. Failing the safety audit may result in enforcement actions, such as fines, penalties, or revocation of operating authority.

Preparation for a safety audit: reviewing the FMCSA regulations and guidance, gathering and organizing records and documents, conducting a self-audit or internal review, cooperating with the auditor, and following up on the results.

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