July 2009, Work Truck - Feature
How to Prepare for a DOT Audit
The DOT has just informed you that your transportation operation will be audited. Are you prepared? Do you know what records will be reviewed? Do you comply with the regulations?
By Steve Frisch
Factor 4: Vehicle
The inspection and maintenance issues reviewed in Factor 4 are found in Part 396 of the FMCSR. The DOT expects the carrier to demonstrate any CMV under its control for 30 consecutive days or more is enrolled in a program of systematic inspection, repair, and maintenance.
Each vehicle subject to Part 396 should have a vehicle maintenance file. In addition to containing records of all repairs, inspections, or maintenance performed on that vehicle, the file should clearly detail the following:
- Company number (or license plate number)
- Model and year
- Vehicle identification number (VIN) or serial number
- Tire size
- Owner (if not the motor carrier)
Except for annual inspections, maintenance records are required to be kept in the file for 12 months before the information can be purged. Fourteen months of annual or periodic inspections must be maintained by the carrier. Proof of periodic inspection must also be stored in the vehicle in the form of a copy of current inspections or, in some states, an approved sticker with inspection information clearly legible.
The DOT verifies that annual/periodic inspections are performed by certified inspectors. Certification is also required for anyone performing CMV brake system work and may be requested during a review.
The motor carrier should maintain records of roadside inspections for at least one year. The DOT examines inspection forms to determine if the carrier has performed required repairs discovered on a vehicle during a roadside inspection and that a signed inspection form was returned to the issuing agency within 15 days of the repair completion.
An issue of note is the requirement a carrier maintain for 90 days the post-trip inspection reports completed by drivers at the end of each workday. This report must be in writing and completed by the driver. The report must indicate:
- What vehicle was inspected
- Date of inspection
- What was inspected
- Any deficiencies present on the vehicle
- Signature of inspecting driver
For inspections during which a defect is noted, the signature of the mechanic who corrected the defect, the signature of the next driver to conduct a pre-trip inspection, and the individual who accepted the vehicle back into service must also be detailed in the report.
At A Glance
A DOT audit reviews six categories of concern:
■ General - insurance, accident, etc., documentation
■ Drivers
■ Operational
■ Vehicles
■ Hazardous materials
■ Accidents