DOT and FMCSA Compliance Checklist for Truck Drivers
If the DOT requires a compliance audit tomorrow, are you ready? Do you know what documents you'll be required to produce, much less where these documents are located? Are your records complete?
What are you missing?
What Is DOT and FMSCA Compliance?
Truck drivers and commercial fleets are required to comply with all DOT rules and regulations, as well as those of the FMCSA.
The government loves its acronyms, so let's start there. What does DOT stand for? It's the acronym for the U.S. Department of Transportation, which is the division under the executive branch (the presidency) that regulates and enforces federal laws related to any mode of transportation. The DOT has multiple subdivisions that specialize in a particular type of transportation, including the Federal Motor Carrier Safety Administration (FMSCA), which regulates the trucking industry.
Truck driver compliance is a huge public safety issue, given the sheer size and number of vehicles involved. And that's before you consider any of the potentially dangerous materials some trucks carry.
As a result, there are a lot of DOT regulations covering just about every aspect of trucking. And it's up to you to keep track of the proof that you comply with every last one.
What Is a DOT Audit and When Does It Happen?
A huge federal agency like the DOT can't keep track of every compliance action that transportation companies take in real-time, so they periodically check your compliance through a DOT audit.
DOT audits can happen with very little warning. In fact, DOT audits have been on the rise since the FMSCA put in a digital Safety Measurement System (SMS), which creates a compliance score based on roadside inspection and weigh station data.
There are four types of DOT audits and they are triggered by different circumstances.
The most common types are compliance reviews and new entrant audits. New carriers are subject to a new entrant audit, usually within the first 6 months of operations. Compliance reviews happen when there's an indicator of poor performance. These are also called targeted DOT audits, since they only happen to carriers that meet certain requirements. Common triggers include a poor SMS score, a high crash rate, a high-profile accident, and citizen complaints, but the FMSCA also performs random compliance reviews.
There are also security audits (specific to a company's safety training and security plan) and hazardous materials audits (specific to HAZMAT training, labeling, and shipping documentation).
Since DOT regulations are so complex and audits can happen on such short notice, it's best practice for a carrier to periodically go through a DOT compliance checklist and make sure they can locate all the required documentation and make sure nothing is missing.
What Is Included on the FMSCA Compliance Checklist?
In the case of trucking carriers, a DOT audit will actually be carried out by the FMSCA, which is why a DOT checklist for trucks is sometimes referred to as an FMSCA compliance checklist.
When trying to compile a thorough DOT compliance checklist, it helps to break things down into major categories of DOT safety regulations. Please note, the lists below are not comprehensive – they're just meant to get you started.
You're responsible for thoroughly vetting new hires and keeping an updated Driver Qualification File (DQF) to ensure they meet all DOT rules and regulations. You have to keep a DQF for three years, regardless of whether the driver still works for you.
A DQF should include records like:
- Proof of current CDL licensing with the appropriate endorsements
- Their current Medical Examiner's Certificate (or a copy)
- Proof of valid insurance
- Three years' worth of Motor Vehicle Records (MVRs)
- Employment application
- Pre-employment and other drug test records (and current status if there were positive results)
- Proof of mandatory entry-level training
- Any records required by specific CDL endorsements
Hours of Service (HOS) Compliance
DOT safety regulations include restrictions on how long drivers can spend in service before they have to take a break (whether it's a short one or a long one). The exact time periods vary a little by situation, so make sure your drivers are following the appropriate HOS rules and spending their break time in the appropriate way.
HOS regulations used to be difficult to track and worked on the honor system, but Congress has now mandated an approved electronic logging device (ELDs) to be installed in every applicable commercial vehicle.
You'll need records that prove all drivers are operating within HOS limits, and you need to keep all ELD data and backups for at least six months.
Vehicle Inspections and Maintenance
For all operating CMV equipment, you need to show:
- Annual inspection records going back at least 14 months
- Pre- and post-trip Driver Vehicle Inspection Records (DVIRs)
- Post-trip inspection reports with flagged problems going back at least 90 days
Drug and Alcohol Screening
You need proof of compliance with DOT/FMSCA drug and alcohol testing requirements, including:
- Documentation of the company's testing programs and policies
- Reports covering all testing performed in the past calendar year (pre-employment screening, random screening, reasonable suspicion testing, and follow-up testing)
- Proof of reasonable suspicion training for all supervisors
Keep in mind, it's not just drivers that are subject to mandatory testing. It applies to any "safety-sensitive employee," which includes dispatchers, mechanics, warehouse workers, and replacement drivers.
Hazardous Materials Regulations (HMR) Compliance
If you transport materials that fall under the HMR, then you need to follow and show proof of compliance.
Unfortunately, DOT rules and regulations for HAZMAT are a complex set of requirements. In fact, DOT HAZMAT audits are one of the most in-depth, detail-oriented DOT audits you can go through.
Licenses and Permits
A carrier's required licenses and permits vary by state, but there are a few common requirements, including:
- US DOT carrier number
- Motor Carrier (MC) number
- Commercial Driver's Licenses (CDLs) for each driver
- Unified Carrier Registration (UCR)
- Standard Carrier Alpha Code (SCAC)
The above categories don't include everything, unfortunately. You'll also need to provide things like:
- Proof that each driver has been provided with a copy of the current FMSCA regulations and agreed to comply
- Your current MCS-90 form for the fleet's liability coverage
- Your current DOT security plan
- International Registration Plans (IRPs) for each qualifying vehicle
- Consistent quarterly fuel tax records based on the International Fuel Tax Agreement (IFTA)
- A copy of the FMSCA rules in your office
Meet DOT Training Compliance with Online Training
One aspect of DOT/FMSCA compliance that's often overlooked is the training requirements.
There are a few types of mandatory training for DOT compliance, including HAZMAT training within 90 days of starting HAZMAT duties like driving hazardous materials in commerce. Refreshers are required every 3 years.
Additionally, the FMSCA requires trucking supervisors to take "reasonable suspicion" training as part of their drug and alcohol testing program. This training is only legally required once, but most carriers require periodic refreshers to ensure they remember and adhere to the testing regulations.
Tracking compliance with this training is more difficult than it sounds. You need to provide proof of training for every employee that requires it, showing that they meet the requirements. HAZMAT training consists of multiple parts, tailored to an employee's role.
Finally, the DOT doesn't review or certify training programs. It's on the employer to choose an appropriate training program that covers all required topics.
We've been a trusted provider of safety compliance training for over 20 years. Our courses are online and self-paced, and businesses can get access to a learning management system that helps them assign, track completion for, and organize proof of mandatory training.
We carry both DOT supervisor alcohol and drug training and multiple categories of HAZMAT training suited to truck drivers. Check out our transportation safety training catalog today and get started!