If your company is subject to Federal Motor Carrier Safety Regulations (FMCSR), it’s likely that sooner or later you’ll deal with a DOT compliance audit. You don’t have to be a trucking company. Any outfit that operates vehicles over 10,000 pounds can be audited. This can include landscaping businesses, concrete companies and towing companies.
When you receive an audit notice, there’s reason to be concerned. In 2019 only six percent of firms escaped an inspection or audit without a violation. But if you follow a few best practices, you can get through a DOT audit with minimal hardship.
Why DOT Compliance Audits Take Place
Sometimes audits are random, and sometimes they’re triggered. Accidents attract the attention of auditors, especially accidents resulting in injury and death. Compliance, safety and accountability (CSA) points from accidents and roadside inspections can add up and lead to an audit.
Be Prepared with Good Record Keeping
The best way to survive an audit is to be prepared before the DOT calls on you. That means keeping your records up to date. Have your documentation secure, centralized and backed up.
A big source of audit violations is the driver qualification file. Common problems include missing inquiries into employment records, lack of medical certificates and not having a file on every driver.
It’s also important to maintain vehicle files, accident reports and records of drug and alcohol testing.
When the Audit Notice Arrives
Surprise audits are unusual. Normally you will receive a notice in the form of a letter, which will direct you to provide information and/or call for next steps.
Respond promptly. If you suspect the audit might not be random, it’s fine to ask. Usually, they’ll tell you. Be thorough but don’t volunteer documentation. Give them what they ask for.
Requested files might include tax information, truck insurance documentation, fiscal information, employee lists, vehicle lists and alcohol and drug forms. If they request information beyond the scope of FMCSA, it may be in your best interest to provide it anyway.
If there’s documentation you think might be relevant but hasn’t been requested, gather it but don’t give it to them at this point.
If your documentation doesn’t look right, don’t change it or make anything up. If you’re caught at this the DOT will not only severely penalize you but will never stop auditing you.
During the Audit
Have a quiet, private space to meet with auditors. Don’t offer food; they’re not allowed to accept it. Arrange your schedule to avoid interruptions. Don’t volunteer information or provide more documentation than was requested.
If your files include irrelevant details, remove them. If you’ve gathered unrequested documents that could be relevant, keep them in a nearby room and retrieve them if necessary. You don’t want auditors fishing through files they haven’t asked to see.
DOT Compliance Audit Outcome
After the audit you’ll receive a rating of Satisfactory, Conditional or Unsatisfactory. If you’re rated Satisfactory, great! Keep it up with the safety practices and record-keeping that got you where you are.
A Conditional rating means there’s at least one item to be corrected. The good news is that you haven’t failed, and the DOT doesn’t see you as a safety risk. There are likely to be fines, and you’ll have to create and submit a Safety Management Plan to correct any infractions.
An Unsatisfactory Rating is what no one wants. You could be shut down. At the very least, you’ll have to devise and carry out a program to reverse that rating.
