What Happens During a DOT Audit (And How to Prepare)
If you run a trucking company, getting notice of a DOT audit can be stressful. But an FMCSA audit is generally about determining whether your company has effective safety management controls in place and whether your records match what is actually happening in your operation.
The best way to prepare for a DOT audit is to stay organized long before the notice arrives.
Why Would a Trucking Company Get Audited?
There are several reasons FMCSA or a state enforcement agency may take a closer look at a motor carrier, including:
- Being a new motor carrier in the New Entrant Program
- Poor safety performance or concerning CSA trends
- Serious crashes or repeated roadside violations
- Complaints or other safety concerns
- FMCSA or state enforcement selection
For new trucking companies, the audit is especially predictable.
A motor carrier is generally considered a New Entrant for its first 18 months of operation, and FMCSA conducts a New Entrant Safety Audit within the first 12 months.
The Main Types of DOT Audits and Investigations
New Entrant Safety Audit
A New Entrant Safety Audit checks whether a new motor carrier has basic safety management systems in place.
FMCSA may conduct the audit at your place of business or remotely by requesting records electronically.
Auditors may review areas such as:
- Driver qualification
- Hours of service
- Drug and alcohol testing
- Vehicle inspection and maintenance
- Accident records
- Insurance and financial responsibility
FMCSA Investigation or Compliance Review
Established trucking companies can also face more detailed investigations when FMCSA identifies potential safety or compliance concerns.
Depending on the situation, an investigation may be:
- Offsite
- Onsite and focused on specific compliance areas
- Onsite and comprehensive
A comprehensive investigation can examine multiple areas of your operation and may affect your company’s safety rating.
What Will a DOT Auditor Look At?
The exact documents requested depend on your operation, but common areas include:
Driver Qualification Files
Your driver files may include:
- Driver application
- Proper driver’s license or CDL
- Motor vehicle records
- Medical qualification information
- Road test certificate or acceptable equivalent
- Required driver history and qualification records
The important thing is that your files are complete, current, and consistent.
Hours of Service
Auditors may review:
- ELD records
- Records of duty status
- Supporting documents
- Hours-of-service violations
- Your procedures for monitoring driver compliance
They are not only looking for logs. They may compare records to determine whether the information is consistent.
Drug and Alcohol Testing
For carriers operating vehicles that require a CDL, FMCSA may review your drug and alcohol testing program.
That can include:
- Pre-employment testing
- Random testing
- Post-accident testing when required
- Testing records
- Your random testing pool or consortium
- Procedures following positive tests or refusals
Simply being enrolled in a consortium does not eliminate the carrier’s responsibility to make sure the program is being handled correctly.
Vehicle Maintenance
Expect to produce records showing that your trucks and trailers are being properly inspected, repaired, and maintained.
That can include:
- Annual inspections
- Maintenance records
- Repair records
- Driver vehicle inspection reports when applicable
- Documentation showing out-of-service defects were repaired
Accident Register
Motor carriers must maintain an accident register for qualifying FMCSA-reportable crashes occurring during the previous three years.
Keep the register accurate and make sure the required information is available.
Insurance and Financial Responsibility
FMCSA may also verify that your company maintains the required level of financial responsibility for the type of operation you run.
How to Prepare for a DOT Audit Before It Happens
The easiest DOT audit is the one you have been preparing for all year.
Keep Your Driver Files Current
Don’t wait until an audit notice arrives.
When something changes, update the file:
- New medical qualification
- New MVR
- New driver’s license
- Driver status changes
- Required testing records
Consider performing an internal review of your driver files several times per year.
Monitor Your Safety Data
Regularly review your company’s FMCSA safety information and roadside inspection history.
If one area is developing a pattern of violations, address it before it becomes a larger problem.
Review Your Drug and Alcohol Program
If your operation is subject to CDL drug and alcohol testing requirements, make sure:
- Drivers are properly enrolled
- Pre-employment tests are completed before required driving
- Random selections are properly administered
- Testing records are retained
- Your consortium or third-party administrator is doing what you expect them to do
Keep Maintenance Records Organized
Every truck and trailer should have an organized maintenance history.
A repair may have been completed correctly, but if you cannot document it, you may have difficulty proving compliance during an audit.
Store Records Where You Can Actually Find Them
Whether you use a dedicated compliance platform, cloud storage, or another filing system, organize your records so requested documents can be produced quickly.
Digital records can make this much easier as long as they are complete and properly maintained.
What Should You Do If You Receive a DOT Audit Notice?
First, read the notice carefully and identify exactly what records are being requested.
Then:
- Gather the requested files. Organize everything by driver, vehicle, and compliance category.
- Review the records before submitting them. Look for missing, incomplete, or expired information.
- Correct legitimate problems immediately. If something can properly be corrected, fix it and document the corrective action. Never backdate, alter, or create records simply to make a file appear compliant.
- Make sure your records agree with each other. ELD records, maintenance records, driver information, and other supporting documents should accurately reflect your operation.
- Respond by the deadline. Missing an FMCSA deadline can turn a manageable issue into a much bigger problem.
- Understand any violations identified. If you don’t understand a finding, ask what regulation applies and what corrective action is required.
For serious compliance issues, it may also make sense to involve an experienced DOT compliance professional or transportation attorney.
How Insurance Fits Into DOT Compliance
Insurance does not replace a good DOT compliance program, but your insurance agency can still be an important part of your overall risk management process.
A transportation-focused insurance agency may help you identify issues involving:
- Vehicle and driver schedules
- Coverage limits
- Safety programs
- Loss trends
- Claims
- Risk-management resources available through your insurance carrier
Your insurance records should also accurately reflect your actual trucking operation.
The Bottom Line
A DOT audit becomes much easier when compliance is part of your normal operation instead of something you think about only after receiving a notice.
Keep your driver files current. Maintain your equipment. Review your safety data. Keep your drug and alcohol program organized when applicable. And make sure you can quickly produce documentation showing what your company is doing.
Good compliance isn’t about creating paperwork for an auditor.
It’s about building a system that can prove your trucking operation is being managed safely and consistently.
Have questions about whether your trucking insurance and risk-management program matches the way your company actually operates? Nelson Insurance Agency works with trucking companies to identify coverage gaps and build insurance programs around their real-world operations.
