Clear Highways Ahead: Meeting DOT Audit Requirements
Finally, you are your own boss. You received your Department of Transportation (DOT) authority, your rig is fueled and the highway awaits on your path to prosperity as an owner-operator entrepreneur. All you need are an open road and loads to haul, right?
Trucking is a highly regulated industry, as you probably already realize. But fall out of compliance with DOT and Federal Motor Carrier Safety Association (FMCSA) rules, and you may come to a dead stop as surely as if you’d cracked a piston. But unlike an engine that can be repaired, a compliance violation can be much more disabling, leading to suspension or even loss of your license and – possibly – your livelihood.
The rules are complex, but TBS recently launched a comprehensive compliance service to help you successfully navigate the compliance process, including passing your New Entrant DOT Audit. Click here to learn more about our compliance services.
In the meantime, here are some things you need to know:
Think of yourself as both a driver and a boss. The FMCSA treats you differently in each role. For example, you, the owner, are responsible for creating and maintaining compliance documentation on you, the driver. Start by compiling a Driver Qualification (DQ) file on yourself with the following information:
- Driver’s employment application – yes, you must fill one out for yourself;
- Inquiry to previous employers verifying employment for past three years;
- Inquiry to appropriate state agencies verifying past three years’ driving record;
- Driver’s Road Test Certificate or equivalent, including a copy of your Commercial Driver’s License (CDL);
- Current medical examinations, including a copy of a valid Medical Examiner’s Certificate.
- Current (last 12 months) Motor Vehicle Record (MVR) from each state where driver holds a CDL
Learn more about these specific requirements on the FMCSA website here.
Develop a Hiring Policy
As an owner, you also must create a written hiring policy. But make sure you, as driver, can qualify under this policy. Some qualifications to consider:
- At least 21 years of age;
- No DUI convictions in the past 10 years;
- Minimum one year holding a valid U.S. driver’s license;
- Minimum three years experience on the road;
- Must pass DOT physical and drug test;
- Must meet all FMCSA rules and regulations, even if not specified here.
Create a Controlled Substance Policy and Procedures
All companies must create a written drug and alcohol policy containing procedures to handle policy violations. The policy should include:
- Which categories of drivers are subject to testing;
- List of prohibited behaviors (for example, no controlled substances);
- Description of testing procedures;
- Consequences for violations, such as suspension, fines and termination.
The FMCSA has put together a booklet called “Drug Guidelines and Policy Development” to help you create a policy that meet its requirements. Find it at the FMCSA website here.
Statement of On-Duty Hours
As part of the New Entrant DOT Audit, be prepared to produce driver daily logs or time sheets (Hours of Duty) for the past six months. The DOT may check the logs by comparing them against fuel receipts, bills of lading (BOL), and other documents, so have backup ready. Make sure you keep logs up-to-date.
The DOT also requires you to create and keep the forms listed below as part of your compliance requirement:
- DOT Accident Register
Sample FMCSA form can be found here.
- Notice of Violations
List of all motor vehicle violations or convictions in the past 12 months.
- Driver Master List
This list should include your name, address, phone number, CDL number and expiration date, hire date and other contact information.
- Equipment Master List
List each Unit number, year/make/model and description and tag. Also, retain all maintenance records.
- Safety Certification
You must be able to produce a copy of FMCSA’s Safety and Hazardous Material Regulations. Print or download them at:
Some Final Tips
You should review the FMCSA website regularly to make sure you’re current on all requirements. If you lease onto a carrier, then that carrier is responsible for DQ reviews and your compliance. If you hire drivers, you are responsible for their compliance. Make sure your drivers’ records and DQ files are clean and up-to-date when you hire them – and keep them that way.
Don’t risk a fine or suspension because you’re “too busy” to fill out paperwork. In many cases, one compliance violation is all it takes for you to get a suspension. Take time right now to review your compliance status. Your CDL and Authority is your license to earn a living. Keep compliant, and keep driving.
Information in this media is subject to change without prior notice. Although every reasonable effort is made to present current and accurate information, Truckers Bookkeeping Service LLC and its affiliates make no guarantees of any kind.