Common Missteps That Lead to FMCSA Audits
FMCSA will conduct an audit that reviews documents such as driver qualification files, hours-of-service records and vehicle maintenance logs as part of its evaluation of basic safety management controls implemented by carriers.
Failing the New Entrant Safety Audit will prompt a Compliance Review; other indicators include roadside inspections showing out-of-service violations or increased CSA activity.
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What triggers an audit?
FMCSA audits can be initiated for many reasons, including serious accidents, failed roadside inspections and high CSA scores. Accidents that cause fatality or serious injury usually trigger one right away while roadside inspections which result in numerous mechanical or hours of Service violations can also prompt audits without much warning.
At any point in time, companies may be chosen for a safety audit by FMCSA-certified auditors. An auditor will typically visit their place of business or they may submit paperwork directly online.
Undergoing an audit is always stressful for carriers who abide by all FMCSA regulations, even those who follow them strictly. Therefore, it’s essential that your paperwork and records be in order so you’ll be ready when an auditor arrives to inspect your vehicles.
FMCSA compliance experts can assist with keeping up with regulations, and preparing documents so you’ll be ready when an auditor visits. Safety Audit Prep services can also help avoid fines and penalties associated with failed audits.
The FMCSA is a small agency and cannot afford to audit every one of the millions of regulated carriers it oversees. Instead, they rely on their CSA program and Safety Measurement System to prioritize which carriers should undergo audit. Understanding this selection process can help prevent being taken by surprise when an audit notice arrives in your inbox.
FMCSA Safety Audits can be expensive for trucking companies, with even one violation leading to suspension of operating authority and fines rapidly increasing. With penalties mounting rapidly it’s essential that businesses devise a plan in advance in order to stay compliant and avoid audits altogether.
Safety Audit Prep is an invaluable tool that helps trucking companies remain compliant and avoid fines or penalties. By sending automatic alerts and reminders, this cloud-based software keeps your company compliant with DOT and FMCSA regulations and ensures all OSHA paperwork expires timely as well as drivers adhere to safety protocols; its invaluable features make this solution indispensable to any trucking operation.
Rules governing the audit
Motor carriers know there are numerous rules and regulations they must abide by to maintain safety on the highways, prevent crashes, injuries and deaths and maintain compliance. The Federal Motor Carrier Safety Administration (FMCSA) is charged with creating and enforcing these regulations.
To this end, companies often undergo what’s known as a safety audit or compliance review to evaluate whether their company meets FMCSRs and HMRs as well as related record-keeping requirements. A safety audit may take place either at your place of business or offsite and an auditor will usually notify you prior to scheduling it.
FMCSA offsite reviews had already seen a dramatic surge before the COVID-19 pandemic struck, increasing 400% over just one year. These audits differ from on-site audits as they usually only require you to submit a smaller sample of records; with offsite audits, one month of ELD records for one driver can be sent directly to FMCSA with their unique code provided by their auditor.
As part of your application, you will also need to submit any supporting documents available, such as driver logs, training certificates and vehicle inspection reports. Additional paperwork may be needed if your record-keeping system has changed significantly or there is evidence of possible data errors submitted in your submissions.
Keep in mind that these reviews do not guarantee you will pass. Even with all the appropriate systems in place, FMCSA remains a relatively small agency and can’t physically visit every trucking company – that is why they use an algorithm called CSA to prioritize certain carriers for enforcement based on factors like roadside inspection history and other considerations.
Avoid an unsatisfactory rating and associated financial penalties by taking steps to rectify issues identified during an audit. Doing this within 60 days for property carriers or 45 days for passenger and hazmat carriers will see their unsatisfactory rating lifted automatically.
Preparing for the audit
The trucking industry is one of the most heavily regulated in America, and the Federal Motor Carrier Safety Administration oversees an array of safety regulations related to it. Their Compliance Safety Accountability program can identify safety issues within an industry while creating programs to help truckers improve their overall safety performance.
FMCSA lacks the resources to audit every trucking company annually; so, to maximize efficiency it has established systems to prioritize carriers for on-site reviews based on their CSA scores and roadside inspection history. In addition, they have experimented with off-site audits that allow inspectors to review records without leaving their offices, saving travel time while simultaneously reviewing more documentation in one sitting.
Off-site audits may be more prevalent these days, but that doesn’t make them any less complex for fleets. Before FMCSA requests an audit, all compliance documents must be organized properly so they can be presented when asked for by auditors – including qualifying new drivers correctly, managing hours of service properly, and having all relevant records and logs ready to show to an FMCSA auditor.
Trucking companies must maintain an exceptional level of accountability with regards to FMCSA regulations and internal policies and procedures, or risk failing their audit and potentially losing operating authority.
Once a carrier fails its audit, FMCSA will provide written documentation highlighting which violations caused its failure and request a corrective action plan be submitted within the time period specified in their failure notification. The plan must outline how they intend to address these violations in the future and ensure that they don’t repeat themselves; failing this could result in being removed from FMCSA registry altogether; so make sure your trucks, drivers and records stay compliant all year-round if you want to stay out of trouble!
The audit itself
FMCSA is an agency, but making physical audits of motor carriers each year can be challenging. To overcome this difficulty, the agency developed systems and processes to prioritize carriers for enforcement through its Compliance, Safety, Accountability (CSA) program as well as data-driven methods like roadside inspection performance reporting and crash reporting to identify carriers who might receive less-than-satisfactory safety ratings.
At one time, most DOT inspections took place onsite and required trucking companies to produce huge volumes of paperwork – often filling entire rooms full of driver qualification files and hours-of-service logs. Since COVID-19 pandemic began sweeping through, however, onsite inspections have decreased dramatically while off-site audits continue to grow dramatically; off-site reviews increased last year alone and are on target to double within 2 years.
FMCSA audits require carriers to upload documents through their Safety Measurement System account, which can be an inconvenience for companies that rely on paper records and have yet to fully transition to electronic recordkeeping. The process could take hours and may require scanning or imaging software in order to convert paper documents into an accessible format for investigators – especially large fleets where driver qualification files require scanning or imaging software conversion.
Audits that conclude in failure provide carriers with notices describing violations identified and an order to develop a corrective action plan (CAP) within an acceptable timeline in order to address them; otherwise they risk losing registration with FMCSA.
Preparing for an audit can be time-consuming and heavy, yet essential in ensuring compliance with DOT regulations. By adhering to FMCSRs and company policies while keeping all documents readily available for auditors, a carrier can reduce its impact during an off-site audit or compliance review and avoid being given less-than-satisfactory ratings that might imperil its operating authority.