Is it time for your annual Department of Transportation (DOT) inspection?
This can be intimidating for both new and established motor carriers. Inspections may lead to violations and expensive fines, and audits are costly and time-consuming.
An unsatisfactory rating from a DOT inspection is every company’s nightmare. Consequences include higher insurance premiums, blacklisting, and a damaged reputation. All these can result in lost profits.
With diligence and effort, though, you can avoid these negative scenarios and pass your DOT inspection with flying colors.
If your annual inspection is coming up, how can you prepare for it? Here’s our comprehensive guide to passing your DOT inspection.
Who’s Eligible for a DOT Inspection?
It comes as a surprise to many construction and manufacturing companies when they’re selected for a DOT audit.
Since they’re not in the transportation business, they think their vehicles are exempt from such regulations. This reasoning is incorrect.
The truth is that any transportation vehicle weighing more than 10,000 pounds is subject to Federal Motor Carrier Safety Regulations.
This includes different types of vehicle fleets such as:
- Trucking fleets (tractor-trailers)
- Delivery vehicles
- Taxi cabs
- Rental car companies
- Public utility vehicles
It doesn’t matter if your vehicle fleet is tiny or one of the largest in the country. As a responsible business owner, you should always prepare for a scheduled (or unscheduled) DOT inspection.
What’s Included on a DOT Review?
There are six inspection categories in a DOT inspection:
- Hazardous Materials
Inspectors will review each category and rate it as satisfactory, conditional, or unsatisfactory.
Receiving a satisfactory rating doesn’t mean a company can relax its compliance policies. It simply means that the company is doing at least the minimum expected by the DOT.
Let’s take a closer look at what’s involved in each category.
A carrier should be ready to show the following documentation:
- Liability coverage
- MCS-90 or MCS-82 form (countersigned by insurance provider)
- Accident register
- Employee training records
Inspectors will also check vehicle markings during this stage. The carrier’s legal name and DOT-assigned number must appear on two sides of every commercial vehicle.
It’s also worth noting that the company accident register must be in place for the review, even if there are no recorded accidents. Any listed accidents must remain there for three years.
All drivers operating commercial motor vehicles must have a commercial driver’s license (CDL). These should be in line with the vehicle class and have the proper endorsements.
Carriers must implement a drug and alcohol testing program for all employees. The DOT requires the following tests for all CDL drivers:
- Pre-Employment Drug Test
- Post-Accident Drug & Alcohol
- Random Drug & Alcohol
- Reasonable Suspicion
In some cases, a carrier may choose not to terminate an employee who tests positive for drug use. Records must show all professional evaluation, rehab, and Return to Duty and Follow-Up testing.
In this stage of the review, the driver file is a significant point. The inspector will examine:
- Driver application
- Previous three years’ employment verification, safety performance history, and drug/alcohol test results
- Motor vehicle record (MVR) check for previous three years
- Road test and certification
- Three years’ DOT physical certifications
- Annual written driver statement of violations
- Three years of signed annual reviews from the carrier
- Any waivers granted
- Entry-level driver training (if required)
While it’s not required to place the physical exam form in the driver file, it must be available upon request.
All businesses operating CMVs are subject to driving limitations. Drivers must keep accurate, detailed driver logs and follow all Hours-of-Service rules.
During a DOT inspection, six months’ worth of driver logs must be available, along with any supporting documents.
Carriers need to maintain either paper or electronic files for each driver. The DOT will examine these files for:
- Form & Manner. This includes all required information and the standard graph log.
- Hours of Service. Violations occur if a driver exceeds the 11-hour, 14-hour, and 60-hours in seven days rule or the 70-hours in eight days rule.
- Falsification of Logs. Supporting documents can identify if a driver deliberately falsified information in the log.
There’s often confusion for carriers using logging exceptions such as the 100-Air-Mile Exception. Even with this exemption, the carrier must follow all standard recordkeeping requirements.
Before a driver can use the 100-Air-Mile Exception, he must comply with the following four requirements:
- Remain within 100 air miles of his normal work-reporting location
- Return to his work-reporting location and be off-duty within 12 hours
- Abstain from driving for more than 11 hours in a 12-hour period
- Take off 10 consecutive hours off between shifts
It’s the carrier’s responsibility to maintain complete, accurate records for each driver. This includes daily starting and stopping times, all on-duty hours, and the 60- or 70-hour tracking rules.
A DOT inspection will expect the carrier’s vehicles to go through a program of regular inspection, repair, and maintenance.
Every vehicle should have a file that includes:
- Company and/or license plate number
- Model and year
- Vehicle identification number (VIN) or serial number
- Tire size
- Owner (if different from the motor carrier)
With the exception of annual inspections, companies must keep maintenance records for at least one year. Annual and periodic inspections must remain on file for at least 14 months. There should also be proof of periodic inspections in each vehicle.
In the case of roadside inspections, companies need to retain records for at least one year. During a DOT inspection, the reviewer will verify that the carrier completed any required repairs.
An often-overlooked component is the drivers’ post-trip inspection reports. Drivers must complete these every day and should include any problems or defects on the vehicle.
The mechanic, the driver, and the person who authorizes the vehicle back into service should all sign off on the report. It’s a requirement for carriers to maintain all such reports for 90 days.
Companies that transport hazardous materials are subject to strict federal regulations. These regulations change frequently, so it’s vital to stay up-to-date on the latest policies.
In general, all hazardous materials must be clearly marked and labeled. Shipping papers should accompany these materials and include the following:
- Material’s proper shipping name
- Hazard class
- Identification number
- Total quantity
- Emergency telephone number and response information
- Packing group (if applicable)
Placards should be present on all bulk packages and all four sides of the vehicle. Depending on the type of hazardous material in transit, there may be other requirements as well.
Any drivers who transport hazardous materials must have an “H” endorsement on their CDL. This is necessary regardless of the size of the vehicle.
Between 2013 and 2015, nearly 12,000 people were killed in highway accidents involving large commercial vehicles. One of the primary goals of a DOT inspection is to prevent future accidents, injuries, and deaths.
The DOT defines an “accident” as an incident that results in a fatality, bodily injury, or disabling damage to a vehicle. Any occurrence that falls under this category must go onto an accident register.
Companies need to keep these records for three years and present them during any DOT inspection or audit.
Now that you know what to expect on your upcoming inspection, how can you and your employees prepare?
Top Tips for Management
DOT Inspection Paperwork Checklist
If you’re notified of an upcoming audit or DOT inspection, you’ll need to gather the following paperwork or electronic files:
- List of drivers used in the last calendar year, including date of hire and/or termination, CDL state and license number, and date of birth.
- All driver files and training records
- Controlled Substance and Alcohol Policy and employee testing records
- Driver/employee payroll records
- Driver logs, trip reports, and expense records for the past six months
- Accident files for the past 12 months
- List of all company equipment (company number, license number, state, year, make, and GVWR)
- Lease agreements (if applicable) and associated vehicle maintenance records
- Vehicle registrations
- Driver vehicle inspection reports (DVIRs) for the last 90 days
- Roadside inspection reports for the last year
- Company’s gross revenue for the last year
- Total fleet mileage and insurance claim information for the last year
If the thought of all this paperwork is overwhelming, you may want to invest in fleet tracking software to help you stay better organized.
Get Everyone Involved
If you’re the owner or manager, don’t attempt to take all this responsibility on yourself. Also, don’t make the mistake of delegating it to only one person.
Because the entire company is subject to the inspection or audit, the entire company should get involved. If possible, assign different staff members to handle each of the six inspection categories.
Call a staff meeting and let everyone know what’s going on. Have your drivers double-check their logs and records and update any missing information. If possible, assign different staff members to handle each of the six inspection categories.
Stay On Top of Vehicle Maintenance
To pass your truck inspection, everything needs to be in good working order.
Have a regular schedule in place to check:
- Seat belts
- Brake systems
- Coupling devices
- Exhaust and fuel systems
- Lights and lighting devices
- Suspension and steering mechanisms
- Tires, wheels, rims, and hubs
- Windshield wipers
- Emergency exits
- Electrical cables
Identify Compliance Delays
If something is missing, it may be as simple a getting a signature or printing out a form. However, it’s not always this easy.
As you go through your paperwork, be aware of major items like missing medical exams or vehicle inspection reports. You need to schedule these in advance, so don’t wait until the last minute to resolve them.
If you failed to provide legally mandated training for your staff, book the next available training class in your area. Sometimes these only come around once every few months, so don’t risk missing out.
Create a Culture of Safety Standards
Your employees are the lifeblood of your business. Their perspective is vital to your company’s reputation. If they’re the ones the telling the DOT where to find safety violations, you don’t stand a chance of passing your inspection.
Invite your staff to express any safety concerns they may have. Listen carefully to their input and act decisively to correct any problems.
If necessary, have your HR department meet with drivers and administrative staff. They can foster and encourage open communication.
Top Tips for Drivers
Drivers can contribute much to the success of a DOT inspection by keeping the following points in mind.
Drivers spend a lot of time in their trucks and may begin to view them as their own personal “house.” While there’s nothing wrong with this, they must ensure that their home away from home is clean and organized.
If a DOT inspector sees that the cab is messy or smelly, he’ll probably assume that’s how you care for the rest of the truck. An inspector is more like to flag a driver with sloppy habits for a major vehicle inspection.
To avoid this, drivers must keep their trucks tidy and keep all required documents organized and easily accessible.
Passing a DOT inspection involves more than vehicle condition. Even if it’s not officially listed on the inspection form, a driver’s attitude can make a difference in the results.
An inspector is more likely to select a driver who is rude or argumentative for a Level I inspection. A driver who is polite and cooperative will have a much smoother experience during the inspection.
Things happen on long trips, and inspectors understand that. If a driver finds a minor issue during a pre-trip inspection, he should be up front and assure the inspector of his intention to resolve it.
Conversely, if the driver claims everything is fine and the inspector finds a problem, the inspector will cite him for it.
Final Thoughts on how to Pass a DOT Inspection
A DOT inspection sounds daunting, but it doesn’t have to be. By staying organized and keeping good records, you should have no problem passing the inspection.
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