DOT Compliance Audit Checklist Template

What the DOT Compliance Audit Checklist Covers

1. 1
   Phase 1 — Plan

   Phase 1: Plan the Self-Audit

   4 tasks

   A self-audit looks at the same records FMCSA examines in a compliance review: driver qualification, drug and alcohol testing, hours of service, maintenance, accidents and insurance. The answers on the first task decide which tasks appear, and every due date counts from the first day of fieldwork.

   • Set up the DOT compliance self-audit — the carrier and USDOT number, why you are auditing now, whether you carry property or passengers, hazardous materials, CDL drivers, new entrant status, the fieldwork start date and the four people; later tasks are assigned from these fields
   • Set the scope and the records period — the terminals and operations in scope and the period you will sample, normally the last 12 months, which is the period FMCSA’s rating method looks back over
   • Work out the vehicle out-of-service rate and the accident rate — roadside vehicle inspections and out-of-service results in the last 12 months, and recordable accidents per million miles, the two numbers FMCSA’s rating method uses beside the records
   • Choose the samples and ask for the records — the drivers, vehicles and days you will check in each area, and when each record owner must have the files ready; sample enough records to see a pattern, which FMCSA counts as violations in at least 10 percent of the records examined
2. 2
   Phase 2 — Drivers

   Phase 2: Driver Qualification Files

   6 tasks

   Every driver needs a driver qualification (DQ) file that stays complete for as long as they drive for you. Check what was put in at hiring and what must be renewed since. Unqualified, disqualified or medically uncertified drivers are among the most serious findings.

   • Check each sampled DQ file holds the hiring records — the signed application, the motor vehicle records from each state that licensed the driver in the 3 years before hire, and the road test certificate or the license or certificate accepted as its equivalent
   • Check the annual review of each driving record — a motor vehicle record from each licensing authority obtained at least every 12 months, and a note in the file naming who reviewed it and when
   • Check the medical certification of every sampled driver — a current certification and any medical variance in each file; for CDL holders, the CDLIS motor vehicle record from the current licensing state showing it, and for other drivers the certificate and a note that the examiner is on the National Registry
   • Check each driver’s license, CDL class and endorsements — one current license from one state, and for CDL drivers the class, endorsements and restrictions the work needs, with no disqualification
   • Record the result for driver qualification — no findings, findings to correct, or a serious finding such as a driver driving without valid medical certification, a valid license or the right CDL
   • Stop each unqualified driver from driving today — take the driver off the schedule until the gap is closed, tell dispatch, and record who was stopped, why and when
3. 3
   Phase 3 — CDL Drivers

   Phase 3: Drug and Alcohol Program

   8 tasks

   Applies when any driver needs a CDL; otherwise its tasks are hidden. Part 382 and the testing procedures in Part 40 cover the policy, supervisor training, the random pool, Clearinghouse queries, the tests and their records. Using a driver after a positive test or a refusal is an acute finding.

   • Check the policy materials and the signed receipts — educational materials that explain Part 382 and your own policies, covering every topic 49 CFR 382.601(b) lists, and a certificate of receipt signed by each sampled driver
   • Check supervisor training for reasonable suspicion — at least 60 minutes on alcohol misuse and 60 minutes on controlled substances use for everyone who supervises drivers, with the records kept
   • Check the random testing pool and the rates achieved — every covered driver and only covered drivers in the pool, selected by a scientifically valid method, tested unannounced on dates spread through the year, at no less than the minimum annual rates
   • Check the Clearinghouse queries — a pre-employment full query for every driver hired in the period, and a query at least once a year for every covered driver
   • Check the test records against the rules for each test — a verified negative pre-employment result before each new driver’s first safety-sensitive function, post-accident tests where the accident register shows one was due, and return-to-duty and follow-up tests for any driver with a violation
   • Check how long the program records are kept — 5 years for positive results, refusals, alcohol results of 0.02 or more, evaluations and program records, 2 years for collection records and 1 year for negative results, in a secure place with controlled access
   • Record the result for the drug and alcohol program — no findings, findings to correct, or a serious finding such as a driver performing safety-sensitive functions after a positive test, a refusal or without a negative pre-employment result
   • Remove each affected driver from safety-sensitive functions today — no driving, inspecting, loading or waiting to be dispatched until the driver has completed return-to-duty or the missing result is in, and a record of who was removed and when
4. 4
   Phase 4 — Hours of Service

   Phase 4: Hours of Service and ELD Records

   6 tasks

   Hours of service carry double weight in FMCSA’s rating method: each pattern of violations of a critical Part 395 regulation counts two points, not one. Check the records of duty status against the limits, then against the documents that show where the driver really was.

   • Sample records of duty status against the limits — the ELD records for the sampled drivers and days, checked against the driving limit, the on-duty window, the 30-minute break where it applies and the 60- or 70-hour limit
   • Match supporting documents to the records of duty status — bills of lading, dispatch records, expense receipts, fleet messages and payroll records for the same days, compared with the times and places on the ELD record
   • Check ELD edits, unidentified driving and malfunctions — edits annotated and confirmed by the driver, unidentified driving reviewed and assigned or explained, and every malfunction repaired within 8 days or covered by an extension
   • Check how long duty status records are kept — records of duty status and supporting documents kept for at least 6 months, and original ELD data never altered or erased
   • Record the result for hours of service — no findings, findings to correct, or a serious finding such as false logs or a tampered ELD
   • Stop the falsification and secure the records today — restore every affected ELD to working order, keep the original data and supporting documents, and decide what happens to each driver and dispatcher involved
5. 5
   Phase 5 — Vehicles

   Phase 5: Vehicle Inspection, Repair and Maintenance

   6 tasks

   Part 396 asks for a maintenance file on every vehicle, a written report when a driver finds a defect, a yearly periodic inspection of every vehicle and trailer, and certified repairs after a roadside inspection. Operating a vehicle declared out of service is acute.

   • Check the maintenance file of each sampled vehicle — the vehicle’s identification, a way of showing the nature and due date of each inspection and maintenance operation, and a record of what was done and when
   • Check driver vehicle inspection reports and repair certifications — a signed report for each vehicle on each day a defect was found or reported, each defect repaired or certified as not needing repair before the vehicle was driven again, and reports kept for 3 months
   • Check the periodic inspection of every vehicle and trailer — each power unit, trailer and converter dolly passed an inspection to Appendix A of Part 396 in the last 12 months, with proof on the vehicle, the report kept 14 months and the inspector’s qualifications on file
   • Check each roadside inspection report was certified and kept — every violation corrected and the carrier official’s certification signed within 15 days of the inspection, a copy kept for 12 months, and no vehicle declared out of service driven before it was repaired
   • Record the result for vehicles — no findings, findings to correct, or a serious finding such as a vehicle driven while declared out of service or with an out-of-service defect not repaired
   • Take each unsafe vehicle out of service today — park the vehicle until the defect is repaired and the repair is recorded, tell dispatch, and list each unit and when it returned to service
6. 6
   Phase 6 — General

   Phase 6: Accidents, Insurance and Registration

   6 tasks

   The general factor in FMCSA’s rating method covers Parts 387 and 390: the accident register, proof of insurance and accurate records. The USDOT registration update and, for hazmat carriers, the hazardous materials records complete the audit.

   • Check the accident register — every accident in the last 3 years with a fatality, an injury treated away from the scene or a vehicle towed away with disabling damage, listed with its date, city and state, driver, injuries, fatalities and any hazardous materials released, and the accident reports kept
   • Check proof of financial responsibility — the Form MCS-90 endorsement or Form MCS-82 surety bond (MCS-90B or MCS-82B for passenger carriers) at the principal place of business, for at least the minimum limits that apply to what you carry
   • Check the MCS-150 biennial update — the Form MCS-150 updated every 24 months, by the last day of the month set by the last digit of the USDOT number, in odd or even years by the next-to-last digit
   • Check the hazardous materials records — a training record for each hazmat employee covering the last 3 years, with recurrent training at least every 3 years, shipping papers kept for 1 year (3 years for hazardous waste), and a security plan or safety permit where your materials need one
   • Record the result for accidents, insurance and registration — no findings, findings to correct, or a serious finding such as operating without the required insurance in force
   • Put the required coverage in place before the next trip — no vehicle operates until the minimum financial responsibility is in effect and the proof is at the principal place of business
7. 7
   Phase 7 — Report

   Phase 7: Grade the Findings and Report

   5 tasks

   Grade each finding the way FMCSA would, then work out an indicative rating for each factor. The new entrant check appears only for carriers still in the 18-month new entrant period.

   • Grade every finding against the acute and critical regulations — acute where noncompliance needs immediate correction whatever else the audit shows, critical where it shows a breakdown in management controls and counts only as a pattern, and other for everything else
   • Work out an indicative rating for each factor — one point for each acute violation or critical pattern, two for each hours-of-service critical pattern; 0 points is satisfactory, 1 conditional and 2 or more unsatisfactory for that factor
   • Check the findings against the new entrant automatic failures — any one of the 16 violations listed in 49 CFR 385.321 fails the new entrant safety audit, and a failed audit gives 60 days, or 45 for passenger and hazmat carriers, to show corrective action
   • Find the cause behind each finding — the control that failed, such as no renewal reminder, no one owning the task, a process nobody followed or a record kept in the wrong place, so the fix stops it happening again
   • Write the audit report and walk the record owners through it — scope, records period, samples, findings by area and grade, the indicative factor ratings, and any immediate action already taken
8. 8
   Phase 8 — Correct

   Phase 8: Corrective Action and Follow-Up

   9 tasks

   The safety director or owner approves the corrective action plan, and nothing after that approval can be completed until it is given. Each area with findings gets its own corrective task, and the lead auditor checks the fixes on records made after them.

   • Write the corrective action plan — for each finding the action, an owner, a due date and the evidence that will show it worked, with acute findings first
   • Safety director approves the corrective action plan — the findings, the indicative ratings and the plan together; nothing after this can be completed until the decision is recorded
   • Correct the driver qualification findings — complete each file, get any missing motor vehicle records or medical certification, and set renewal dates for every driver so nothing lapses again
   • Correct the drug and alcohol program findings — fix the pool, the policy materials, missing queries or training, and make up any shortfall in random testing for the year
   • Correct the hours-of-service findings — retrain the drivers and dispatchers involved, fix how supporting documents are collected and matched, and change any schedule that cannot be run legally
   • Correct the vehicle findings — bring every maintenance file up to date, finish overdue periodic inspections, certify open repairs and change how defects reach the shop
   • Correct the accident, insurance and registration findings — complete the accident register and file the missing reports, put the proof of insurance on file and file the MCS-150 update if it is due
   • Check the corrective actions worked — re-sample records made after each fix, such as new annual reviews, logs or inspection reports, and record whether each finding is closed
   • Close the audit and schedule the next one — file the report, the plan and the evidence, and set the date of the next self-audit