Risk & Safety

What to Expect from an FMCSA Mock Audit

Ella Baker
What to Expect from an FMCSA Mock Audit
Reading time 10 Mins
Published on Aug 16

It’s only a matter of time before your company is the subject of a DOT Federal Motor Carrier Safety Administration (FMCSA) audit. Failing an FMSCA audit can mean the end of the line for your fleet. FMSCA mock audits allow you and your team to proactively find and correct problem areas in your policies and fleet before the DOT finds them for you. Sheakley’s Mock Audit services examine your files to ensure that your team is prepared to face an FMCSA audit.

The basics

DOT FMCSA audits are broadly meant to evaluate a company’s safety performance and to confirm that it is conducting proper and complete recordkeeping. DOT reviews are generally divided into six inspection categories called factors. Each of these factors is meant to ensure that the company has adequate management control and practices in place to ensure compliance with FMCSA regulations. These factors are:

  • General
  • Driver
  • Operational
  • Vehicle
  • Hazardous Materials
  • Accidents

An individual FMCSA audit may include any or all of these factors. For each factor that is part of an individual audit, DOT inspectors assign a rating of Satisfactory, Conditional, or Unsatisfactory.

A satisfactory rating means that your safety program is in compliance with the minimum requirements of the factor that has been reviewed. Sheakley’s FMCSA mock audits focus on each of these factors to ensure that your company is able to achieve a Satisfactory rating when the DOT comes to call.

Factor 1: Generally required DOT information

Factor 1 audits cover generally required DOT information that demonstrates proper liability coverage is in place for your carrier type and the cargo you transport. The vast majority of Factor 1 audits focus on your recordkeeping when it comes to insurance and incidents, so our Factor 1 mock audits focus on helping ensure that you have all of your paperwork in order.

The first thing that our safety experts look for in a Factor 1 mock audit is proof of liability coverage. We will help you ensure that your MCS-90 or MCS-82 form is properly completed and countersigned by your insurance provider.

Next, we review your company’s accident register for a list of all accidents that meet the requirements of a DOT recordable accident. Our safety experts ensure that you have all of the necessary information in your accident register, including:

  • Date of the Accident
  • Location
  • Driver’s Name
  • Number of Injuries and Fatalities
  • Presence of hazardous materials other than fuel spilled by any vehicle involved in the incident

Any accident recorded must remain on the register for three years from the date of the accident. It’s important to remember that, even if you have no DOT recordable accidents, you must still keep the accident register in place for review during audits.

Factor 1 mock audits also include a review of all vehicle markings. We review a sample of your fleet’s vehicles to ensure that you are compliant with all FMCSA requirements. Training is another key component of Factor 1 mock audits. Our safety experts review your training records to ensure that your fleet drivers are receiving the necessary training to ensure regulatory compliance. Our experts suggest that carriers keep detailed records of any transportation safety-related training opportunities provided to employees. Check out our calendar of training opportunities and events for information about the ongoing safety programs offered by Sheakley.

Factor 2: Driver qualifications and requirements

Factor 2 audits focus on commercial driver’s licenses (CDL), driver qualifications, and drug and alcohol testing. Our Factor 2 mock audits focus on reviewing and ensuring that your driver files are complete and that your drug and alcohol testing programs are up to par so that you’re ready for when the DOT comes to call.

As the employer, the DOT expects carriers to demonstrate that all drivers have valid driver’s licenses with the appropriate class and endorsements necessary for participating in the fleet. As part of your driver files, your system should also include the ability to track license expiration dates.

Drug and alcohol testing program review is a significant portion of Factor 2 audits, so our mock auditors will focus on ensuring that your testing program is in compliance. All carriers must have a drug and alcohol testing program that is separate from any other company-required testing. The DOT also requires that carriers make a good faith effort to obtain three years’ worth of testing results from previous employers.

Not only must you have a written policy that specifies when and how tests are implemented, but also the potential ramifications for drivers who fail to take the test or for those who test positive. A signed acknowledgment of the policy must be included in each driver’s file. We will review your policy to make sure that it complies with FMCSA regulations and make suggestions for any recommended changes or edits to ensure that you don’t get dinged by the DOT during an audit.

In addition to ensuring that you have the appropriate tests in place for all CDL drivers, Factor 2 mock audits also ensure that your testing programs comply with FMCSA regulations, that tests were conducted appropriately, and that all managers have received appropriate training on Reasonable Suspicion testing.

Another significant portion of Factor 2 mock audits is a thorough review of your driver qualification files. Each driver file must include:

  • Driver application with all required information
  • Previous three years of employment verification
  • Safety performance history, if applicable
  • Drug/alcohol test results
  • Motor vehicle record (MVR) check for the previous three years
  • Road test and certification
  • Three years of DOT physical certifications
  • Entry-level driver training, if required
  • Three years of annual MVRs
  • Annual written driver statement of violations, which the driver is licensed
  • Three years of signed annual reviews from the motor carrier
  • Any waivers granted

Our safety experts allocate a great deal of time and effort during your mock audit to ensuring that all of your driver files are complete, current, correct, and contain the same information in the same order. We recommend that carriers place only those items specifically required by the DOT in the driver files. Other records or documents that the carrier may want to keep or feel are necessary for fleet management may be placed elsewhere.

Factor 3: Operational components

Hours of Service are the largest component of Factor 3. Every fleet is subject to driving limitations and hours of service recordkeeping requirements. Our mock audit helps ensure that you have the six months of driver logs and supporting documents necessary to help you receive a satisfactory rating on your Factor 3 audit.

Carriers must maintain either an electronic or paper file on each regulated driver. Driver logs must be returned to the carrier within 13 days of completion. During your mock audit, driver logs are examined for:

  • Form and manner to ensure that all necessary information is present
  • Hours of service to ensure there are no violations of the 11-hour, 14-hour, and 60-hours in seven days or 70-hours in eight days rules
  • Falsification of logs to ensure all information is accurate by checking again supporting documents

Factor 4: Vehicle requirements

DOT requires that all fleet vehicles operated by a carrier for 30 or more days be enrolled in a program of regular inspection, repair, and maintenance. Factor 4 mock audits ensure you can effectively demonstrate that your fleet inspection, repair, and maintenance program complies with all FMCSA regulations.

Carriers must maintain a vehicle maintenance file on every vehicle they operate. Our mock audit team will review your records to ensure that your vehicle maintenance files contain records of all repairs, inspections, and maintenance performed on the vehicle, in addition to the following required information:

  • Company name and license plate number
  • Model and year
  • Vehicle identification number
  • Tire size
  • Owner name (if not owned by the carrier)

Maintenance records, annual inspections, periodic inspections, roadside inspections, and post-trip inspection reports should all be part of your records. Our mock auditors will also ensure that your retention policy is compliant and that you have the necessary number of months or years of records. In addition, we will conduct a sample audit of roadside inspection forms to ensure that your company made any necessary repairs discovered during the inspection.

Factor 5: Hazardous materials

During Factor 5 mock audits, our safety experts ensure that you are able to meet FMCSA requirements for the safe transport of hazardous materials. The DOT requires that all carriers who transport hazardous materials obtain a hazmat security permit. Carriers must also maintain accurate shipping records for the transportation of all hazardous materials. Carriers must provide additional training to drivers who will transport hazardous materials.

Factor 5 mock audits focus on ensuring that your drivers have received adequate training on the safe transportation of hazardous materials, understand how to react and report in an emergency, and that you have all proper documentation in place.

Factor 6: Accidents

The DOT and FMCSA understand that accidents are inevitable when operating a large fleet, but a large portion of their efforts go into reducing the number of accidents that fleet vehicles are involved in each year.

Factor 6 mock audits focus on ensuring that you are providing adequate and qualified training to all of your drivers. Additionally, our experts work with you to calculate the rate of accidents your drivers are involved in per million miles as compared to the industry average, and ensure that you have an accident preventability program in place to reduce the frequency and severity of accidents that affect your fleet. If your accident preventability program isn’t adequate, our experts can even help improve your program to help reduce the number of accidents your fleet is involved in.

Reporting back

After Sheakley has finished the mock audit, a complete report of findings will be prepared and reviewed with you. If deficiencies are found in your program, Sheakley will recommend solutions to bring your company back into compliance and keep it there. If the DOT has already issued a “Less than Satisfactory” rating, Sheakley can prepare a Safety Management Plan (SMP) for submission to the DOT. The SMP will outline and document the solutions put in place to ensure compliance with the regulations.

Your partner in safety

Upon the completion of your compliance review, Sheakley can structure a program to help remedy problem areas, and help maintain a level of compliance for the future. Sheakley will work with your carrier officials or can work independently to construct a Safety Management Program to meet your company’s needs. Keeping your workforce safe is priority one for your company. Sheakley can help you develop better policies and provide assistance with developing safety programs to help you achieve your safety goals. Our experts are here to keep your employees and your business safe. Sheakley’s Workforce Management Services experts provide complete safety resources for your company.

Get your free safety consultation today with an expert from Sheakley. Stay up-to-date on all things Sheakley by subscribing to our blog and following us on social media. Join in the discussion by commenting below.

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