A U.S. Department of Transportation (DOT) audit can happen at a moment’s notice. Following regulations and always being prepared for a DOT audit are essential to maintaining compliance and passing the audit without issue. This guide outlines what to expect during a DOT audit and the key preparation steps.
What Is a DOT Audit?
DOT governs audits to ensure compliance with regulations from the Federal Motor Carrier Safety Administration (FMCSA). Also known as a safety audit, there are three different safety audit types, depending on your circumstances:
Security or Hazardous Material Audit
This audit analyzes training, shipping records, storage policies for hazardous materials (hazmat) and labeling systems. As part of an audit, you will provide the correct shipping paperwork for each load you transport and keep these documents on file for at least one year. You must store paperwork related to hazardous waste materials for a minimum of three years.
Compliance Review
This audit confirms you adhere to DOT and FMCSA regulations. Roadside inspections; low Compliance, Safety, Accountability (CSA) scores; and complaints could lead to a Compliance Review, which a federal or state safety investigator typically carries out. The investigator will review your company’s safety record and check your status of avoiding violations.
New Entrant Safety Audit (NESA)
This audit type occurs within the first 12 months and verifies whether you are adhering to safety regulations and compliance measures. If you are a new entrant, expect to be in this bracket for your first 18 months after receiving your DOT number. The FMCSA conducts audits either online or in person. Although audits can occasionally happen without notice, new entrants generally receive some advance warning.
How to Prepare for a DOT Safety Audit Checklist
Follow the checklist below to make sure you have the correct procedures and DOT audit documents required to pass without violations:
Alcohol and Drug Testing Policy
You must keep pre-employment drug and alcohol testing records, any on-the-spot checks, and a log of any related incidents to pass an audit.
Correct Insurance
Also referred to as MCS-90 forms, you need to show proof of adequate insurance as part of an audit. As a commercial motor vehicle (CMV) carrier, you must have insurance to cover costs relating to injury or property damage caused by your company.
Full Vehicle List
All transportation carriers must keep an updated vehicle list, including the registered state, vehicle identification number (VIN), plate number and unit number.
Hazmat Shipping Papers
Auditors must have access to hazmat shipping papers for the audit checklist. These papers include details on emergency response and an identification number.
Copies of Current Guidelines
To familiarize yourself and your team with current FMCSA regulations, it is a good idea to keep physical copies on hand for periodic review. When working with hazmat transportation, review the Hazardous Materials Regulations (HMRs).
Proof of a Commercial Driver’s License
Every driver needs a commercial driver’s license (CDL) with the proper endorsements to be eligible to work, which requires passing a skills and knowledge test.
Driver List
You must maintain a comprehensive list of all employed drivers. The list needs to include a driver’s full name, license State, license number and the date they joined your company.
Driver Duty Records
Regulations require drivers to log the hours they have worked every 24 hours in a duty record or Record of Duty (ROD). Supporting documentation can include fuel receipts and toll records.
Medical Certificate
All drivers must undergo a medical exam from a registered medical examiner every two years. You, as the employer, and the driver should each have a copy of their medical certificate.
Vehicle Inspection Reports
A qualified inspector must check over all vehicles once every 12 months. Similarly, an annual inspection is required for each segment of a combination vehicle.
Accident Log
Record any accidents that have occurred within the last 365 days in an accident register. Details must include the accident date, location, driver name, injuries or fatalities, and record whether hazardous materials leaked at the accident location.
DOT Audit Safety Ratings
After a Compliance Review audit is complete, your company may be assigned a safety rating by the FMCSA. However, not all audits and investigations result in a safety rating. If you receive a rating, it will be one of the three options below:
- Satisfactory: Your company has implemented all necessary safety management controls and measures, comparable with its size, to comply with the relevant requirements.
- Conditional: A review has determined that operations are at risk of not meeting compliance regulations under the Safety Fitness Standard. However, there is no immediate threat to safety, and operations can continue.
- Unsatisfactory: An unsatisfactory rating means your carrier lacks the safety management controls to meet regulations.
Reasons for Failing a DOT Audit
Many reasons could be behind your carrier failing an audit and receiving an unsatisfactory rating. Based on the audit preparation checklist above, violations could include:
- Operating a fleet without the correct insurance.
- Insufficient recording of accident reports.
- Poor maintenance, repair and inspection of vehicles.
- Hiring unqualified drivers or those without a medical certificate.
- Improper alcohol and drug testing protocols.
- Not storing hazmat shipping papers.
What Happens if You Fail an Audit?
After an audit is complete, you can expect to receive a letter within 45 days, which will explain why you failed the DOT audit. The letter will also detail instructions for creating a Corrective Action Plan (CAP) and the time frame you need to submit this plan by.
In your CAP, you must clearly outline what you aim to accomplish to fix any problems you failed to address. The letter itself should detail the violations identified during the audit, allowing you to create an implementation plan easily. Failure to return the CAP on time may result in civil penalties and potentially lead to the loss of your authority to operate commercial vehicles.
Become Audit Ready With DOT Hazmat Training
Failing a DOT audit due to easily fixable problems can harm your reputation and potentially result in the closure of operations for an extended period. The comprehensive hazmat training programs from Hazmat School prepare you and your employees to comply with regulations.
Whether it is teaching the handling of hazardous materials, proper storage methods or disposing of materials, our training programs are based on real-life situations to deliver maximum impact.
Ready to gain all the vital skills and knowledge from our hazmat training programs? Get in touch with us about enrollment at Hazmat School and continue your journey to maintaining compliance with DOT audits.
Manages Hazmat School’s E-Learning courses and blog. Kirstie has extensive experience in the online training and education industry. Kirstie has worked with courses that offer a variety of safety and environmental certifications that satisfy OSHA, EPA and DOT requirements.
