DOT Audits – What You Need to Know

• Claims & Risk Management
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If you are issued a DOT (Department of Transportation) number to operate certain class vehicles in your business, you are subject to safety audits and compliance reviews administered by the DOT on a periodic basis.  If you have recently been issued a DOT number, you will most likely be audited within the first 6-18 months of being issued the number. These audits / inspections are conducted at your place of business or you can be pulled over at a DOT inspection station (we pass them traveling on our highways all the time!).  How can you be prepared?  This presentation touches on some of the basics relating to DOT audits and what you should know.

Who gets selected for audit?

• Most common audit types – full, focused, unrated, or evenly distributed between each source
• In 2017 a total of 51,300 audits were completed
  • 36,200 – involved new entrant investigations
  • 7,700 – focused audits
  • 6,400 – onsite comprehensive
• Process is typically not random, but based on one of the following:
  • CSA basic scores (85-90% of the time your score triggers the audit)
  • Complaint received
  • Follow-up from previous audit
  • On the road observation (vehicle speeding, load securement is poor, or placards are not easily legible)
  • Crash investigation
  • Within 18 months of DOT # issuance (currently there around 540,000 active #’s)

How likely are you to be pulled over for a road side inspection? Do you exhibit any of the following?

• Observed doing something unusual by an officer
• Speeding (most common)
• Visible violations – lights out, poor load securement, unreadable placards, etc.
• Electronic screening (ISS) – officer can punch in your vehicle data (license plate, DOT #, etc.) to get your CSA score, and determine if he will pull you over
• Post accident
• High inspection selection system score
• Random inspection

Mini compliance review during roadside inspection can include:

• Driver’s condition reviewed – first impressions matter!
• Records check – HOS records, active/correct license, medical card, DOT #, shipment paperwork
• Vehicle inspection – walk around or full inspection (first impressions matter – keep your vehicle in good condition and clean looking)
• You can and should challenge any investigation letter results
• Especially if you are sure there is an error
• 60% of challenges are successful

The DOT audit Process

Preparation – formal letter is sent out with requested documents needing review. Identify internal point of contact, review process with the internal team

The safety management cycle – Policies/procedures, roles/responsibilities, qualifications/hiring, training/communication, monitoring and tracking, and meaningful action.  This process should be in place in some format

Six (6) factors reviewed in all audits:

1. General Regulations: Financial responsibility will be checked as well as accident records, DOT filings match operations, vehicle markings are accurate (full and correct company name) and legible (readable within 50’ with contrasting colors).
2. Drivers: Driver selection/qualifications are per standards; drug and alcohol testing conducted and documented; MVR’s and licenses are reviewed annually; driver files are complete with application, medical qualification, road tests current; all driving suspensions/revocations are properly documented.
3. Operational: Typically, will check driver fitness, scheduling, cell phone/texting violations, and accurate hours of service logs.
4. Vehicle: Inspection and maintenance records are current/accurate; vehicle files exist and are accurate; recurring maintenance program exists and is enforced; driver vehicle inspections are conducted/documented; violations/out of service records are documented; use of qualified technicians for vehicle maintenance.
5. Hazardous Materials: Hazmat security permit exists; shipping records maintained and accurate; drivers are trained in hazardous material hauling.
6. Accidents: Rate calculated per million miles and compared to industry average; driver training exists and reflects on accident record; accident preventability program is in place to reduce frequency/severity.

Prevention/Preparation – The safety management cycle is used as a tool to attain compliance in the CSA Basics. Documentation (driver and vehicle files) meet or exceed standards.

Scoring & Rating – Scoring is based on violations uncovered.  Each factor is scored independently according to the following format:

0 points = satisfactory; 1 point = conditional; 2 points = unsatisfactory

Safety rating is assigned as follows:

• Satisfactory rating: 0 factors unsatisfactory and 2 or fewer factors are conditional
• Conditional rating: 1 factor unsatisfactory and 2 or more factors are conditional, or 3 or more factors are conditional
• Unsatisfactory rating: 1 factor unsatisfactory and 3 or more factors are conditional, or 2 factors are unsatisfactory.

Best Practices: Prevent the audit – be compliant and in control; be prepared at all times; exceed regulations; have controls in place for all the BASICS; consider conducting mock audits; act quickly when problems are discovered; fix high-risk problems immediately.

Samples of violations and respective scoring assessed per CSA BASIC:

• Driver fitness: failure to comply with out of service order (10 pts); having wrong type license (8 pts); driving CMV with wrong class CDL (8 pts); driving a CMV under the age of 21 (4 pts); failure to have proper hazmat training (4 pts)
• Hazardous Materials compliance: improper Hazard Materials securement (10 pts); Hazard Materials markings violations (5 pts)
• Controlled substances/alcohol violations: violating an out of service order involving drug/alcohol use (10 pts); using or possessing controlled substances (10 pts); under the influence of alcohol 4 hours prior to duty (5 pts)
• HOS violations: driving after being placed out of service (10 pts); driving while ill or fatigued (10 pts); submitting false logs (7 pts); failure to keep log current (5 pts)
• Unsafe driving violations: reckless, texting or speeding 15+ mpg in construction zone (10 pts); failure to use seat belt, or speeding 11-14 mph above posted limit (7 pts); following too close, improper lane change, or failure to obey traffic control devices (5 pts)
• Vehicle maintenance violations: driving an out of service vehicle (10 pts); tire defects (8 pts); suspension defects (7 pts); lights out or not working (6 pts); brake defects, or inspection report violations (4 pts); improper tie-downs (3 pts)
• Crash history: injury with hazmat release (3 pts); injuries or fatalities (2 pts)

In summary, understand the CSA Basics and how your operations are impacted. Use the Safety Management Cycle as a tool to attain compliance with DOT regulations. Make sure you have qualified drivers and that your vehicles are well maintained and properly placarded. Driving behaviors and physical condition of your vehicles can easily trigger road side inspections.  Positive first impressions can have an impact on whether you are stopped or not.

Questions or want to learn more?  Contact Mark Skuby at 610-348-2132 or mskuby@safegardgroup.com.

Also, sign up for our free DOT Inspection / Driver safety seminar scheduled for Wednesday October 3, 2018 at The Safegard Group’s training facility in Media, PA (8 am – 12 noon). Our speakers will include a safety consultant from the Hartford Insurance Company and two active duty police officers who will share their experiences and walk us through the audit process (why you get stopped, what they are typically looking for, and how can you have a successful outcome).