Over the last decade, the likelihood of receiving a Department of Transportation (DOT) audit has increased. But just because they’re more common doesn’t make them any less of a hassle. Audits typically come with no notice, which can leave busy fleet managers scrambling to complete all necessary documentation — and no matter the audit type, that required documentation will be extensive.
Whether you’re preparing for the new entrant audit, have received notice of a Compliance Review or simply want to plan ahead in case an audit does come your way, Onward can help. Read on for a quick overview of the most common DOT audits and our team’s streamlined audit preparation process.
Which vehicles have to comply with DOT regulations?
DOT regulations apply to every commercial vehicle that operates in the U.S. In addition to commercial vehicles owned by a company, this category can also apply to a vehicle that:
- Transports 16 or more passengers (including the driver), without compensation
- Transports 9 or more passengers (including the driver), for compensation
- Weighs 10,001 pounds or more
- Transports hazardous materials in quantities that require a hazardous materials placard
DOT regulations are wide-ranging and can include everything from hours of services to random drug and alcohol testing. Although it’s critical to stay continually up-to-date with DOT regulations, your fleet’s compliance comes under special scrutiny during a DOT audit.
What are the main types of DOT audits?
There are four types of DOT audits: the New Entrant Safety Assurance (NESA) Audit, Compliance Review, Security Audit and Hazardous Material Audit. The NESA Audit and Compliance Review are by far the most common for commercial fleets, but it’s helpful to have an overall understanding of the audit landscape as you operate and grow your business.
- NESA Audit: The DOT audits new fleets to ensure they’re in compliance with all safety regulations. The “new entrant” period spans 18 months, but this audit typically comes during your first year of operation. The DOT issues automatic fails for violations related to alcohol and drugs, driver qualifications, repairs and inspections, and a failed NESA Audit can increase your likelihood of an in-depth Compliance Review.
- Compliance Review: The DOT can require a Compliance Review any time that Federal Motor Carrier Safety Administration (FMCSA) data indicates an issue. The triggers for a Compliance Review can include poor CSA BASIC scores, “out of service” violations during roadside inspections, a failed NESA Audit, a complaint investigation and/or a major accident. The Compliance Review evaluates how well you’re following FMCSA guidelines and assesses your fleet’s overall safety track record. Depending on your fleet and auditor, this review can require incredibly extensive documentation spanning all major aspects of your fleet’s operations, including your drivers, safety record and finances.
During a Security Audit, the DOT evaluates your security measures, safety plan and driver training. When carriers receive notice of a Security Audit, a Hazardous Material Audit typically follows suit. That audit reviews shipping documentation, container labeling, training and other procedures related to the transport of hazardous materials. These materials can include marine pollutants, hazardous wastes, hazardous substances and others outlined by the DOT.
How should you prepare for a NESA Audit or Compliance Review?
For the purpose of this article, we’ll focus mostly on the NESA Audit and Compliance Reviews, as these are the most common audits for commercial fleets. In both cases, a tremendous amount of time goes into gathering and presenting the data required to demonstrate compliance. Crossing every “t” and dotting every “i” is critical to passing an audit.
To pass a new entrant audit, fleets must submit substantial paperwork, including but not limited to driver logs, time cards, inspection forms and medical exams for all drivers across all units. You’ll need to establish online submission access and upload all required documents correctly to ensure your auditor has what they need to properly assess your fleet’s compliance. This process could also require phone calls with the auditor to ensure they receive all documents the way they want them. In some cases, the NESA Audit can be performed online; other times, it could require an in-person meeting at your place of business.
When preparing your NESA Audit paperwork, pay special attention to the “automatic fail” categories, which include:
- Alcohol and drug violations such as lacking a testing program, lacking random testing protocol or using a driver who refuses a required drug or alcohol test.
- Driver violations including using drivers without a valid CDL, disqualified drivers and/or medically unqualified drivers.
- Operations violations such as operating a vehicle without the required insurance or failing to require hours-of-service records from your drivers.
- Repairs and inspections violations like operating a vehicle declared “out of service” before repairs are made, not performing “out of service” repairs reported in your DVIRS or operating a vehicle that’s not inspected periodically.
A Compliance Review is typically intensive and comprehensive, covering everything from your driver qualification and financial responsibility to operations reviews, maintenance records and DOT accident register. As with the NESA Audit, you’ll want to communicate with your auditor to ensure that you’ve prepared all documentation before the audit, which is typically conducted in-person at your principal place of business.
Whether you’re completing a NESA Audit or a Compliance Review, your auditor will be a certified U.S. federal safety investigator, state or provincial enforcement officer. In-person meetings could require the attendance of your managers, drivers, mechanics and/or other staff, depending on your auditor’s requirements. If your audit includes an in-person interview, it’s critical to have all paperwork readily available so that you’re prepared for any questions that arise.
How Onward can help
Our team has a track record for helping commercial fleets navigate DOT audits and pass with flying colors. Whether you’re preparing for your NESA Audit or have received notice of a Compliance Review, trust our team to handle every aspect:
- Preparing all documentation required for your audit
- Communicating on your behalf with auditors to ensure they receive all documentation in their preferred format
- Setting up your online submission access and uploading all documents
- Managing all deadlines to ensure timely submission
- Providing expert advice if your audit requires an in-person interview
- Identifying any gaps in program compliance that arise as we compile the data required for your fleet’s DOT review
Whether your audit can be completed 100% online or requires an in-person review, our experts understand exactly what is required and have a proven process ready to go. That includes helping fleets operating in multiple states and those that have received a Compliance Review notice due to issues like poor CSA BASIC scores. With Onward handling the in-depth audit process, your team is free to focus on other critical tasks.
Does your commercial fleet need a trusted partner to help you pass your DOT audit? Contact us now to discover how our proven process can save you time and frustration.