The Ultimate DOT Compliance Checklist for 2022
The Department of Transportation (DOT) is tasked with ensuring a fast, safe, efficient, and accessible transportation system across the US. To that end, the DOT has established a series of compliance rules that regulate commercial driving operations, such as freight fleets.
Freight carriers must abide by DOT regulations to legally operate. Failure to do so could result in significant penalties, including fines, fees, and business shutdowns.
But what regulations do you need to follow to pass a DOT compliance audit?
Our team has compiled a DOT compliance checklist you can use to verify that your business is operating legally.
How to Pass DOT a Compliance Check
If you have a DOT compliance check coming up, it’s important to first understand who carries out these checks, and why. While the Department of Transportation creates the rules and regulations that govern shipping operations, they do not carry them out. Instead, enforcement is left to the Federal Motor Carrier Safety Administration (FMCSA).
FMCSA is a subsidiary of the DOT and is primarily tasked with regulating trucking operations within the country. Their stated purpose is to increase road safety and help provide fleet safety solutions by reducing crashes, injuries, and fatalities caused by or involving large commercial motor carriers. 1
Now, let’s take a look at a DOT checklist and explore what being DOT compliant entails:
#1 Obtain a USDOT Number
Regardless of whether you operate and oversee shipping vs delivery logistics, commercial freight or trucking companies that transport cargo or people in interstate commerce are required to be registered with the FMCSA 2. Specifically, they must register for a USDOT number.
Your USDOT number is like a social security number. It’s a unique identifier that a carrier will be required to show in the case of a crash, audit, vehicle inspection, or investigation.
How do you know if you need a USDOT number?
The FMCSA requires you to obtain one if you own and operate a commercial vehicle that satisfies any of the following criteria 3:
- Has a gross vehicle weight of 4,536 kg (10,001 pounds) or more.
- Made to transport more than 8 passengers, including the driver (for commerce).
- Made to transport more than 15 passengers, including the driver (not for commerce).
- Used to transport hazardous materials that require a safety permit in intrastate commerce.
Obtaining a DOT number is just the initial step for compliance. You must also follow all relevant Federal Motor Carrier Safety Regulations 4.
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#2 Abide By Driver Qualifications
Before you can ever allow an employee to get behind the wheel, you must first rigorously verify that they are qualified for the job. As a result, every aspiring driver must pass a pre-employment background check.
To that end, your screening needs to cover the following basic eligibility requirements 5:
- Licensing – To operate a commercial vehicle, most drivers will be required to obtain a commercial driver’s license (CDL) from their home state, which includes both skills and knowledge tests. The CDL should be non-expired and scanned on both sides.
- Education – A driver must possess a high school diploma or GED.
- Medical physical examination – Driver candidates must be considered physically fit enough to safely operate a commercial vehicle. The certified medical examiner must be in the National Registry and completely fill out and then sign a Medical Examiner’s Certificate.
- Motor vehicle records (for the past three years) – The CDL driver should have a clean driving record with little to no accidents or driving violations.
- Age – A driver must be at least 18 years of age to drive within the state and must be 21 to operate interstate.
- Previous employment – If the driver has engaged in safety-sensitive work over the past three years, the employer must put in a “good faith” effort to reach out to the previous employers for an employee review. DOT defines safety-sensitive workers as 6: “Someone who holds a job that can impact both their own safety and the safety of the public.” Examples may include working on a flight crew, operating a train, or working on pipelines.
- Substance abuse records – The driver shouldn’t have any alcohol or drug violations, especially if they were in a safety-sensitive position.
- Pre-employment drug test – The driver must pass a 5-panel drug test for the following:
- Marijuana (THC)
- Cocaine Metabolites
- Amphetamines (including Methamphetamine & MDMA)
- Opiates (including Codeine, Heroin, Morphine)
- Phencyclidine (PCP)
- Show relevant documents – Depending on the state, the driver may also be asked to show proof of insurance, proof of state residency, and their social security card.
- Criminal background check – The driver must pass a 10-year background check.
Conducting a rigorous background check and interview process ensures that only trustworthy drivers may represent your company. Failure to properly screen candidates could expose a freight carrier to legal liability, especially if that unqualified driver caused an accident or violated the law.
#3 Maintain a Driver Qualification File
After a driver has been hired, commercial vehicle carriers are expected to maintain a driver qualification file (DQF) which should include the following:
- A completed and signed driver’s employment application
- The driver’s road test certificate
- Proof of insurance
- Hours of service
- Record of inquiry to state agencies for a 3-year driving record
- Pre-employment drug and alcohol documents
You must also maintain a record of inquiry to previous employers regarding the driver’s safety performance history records over the previous three years. If the driver corrected or rebutted the incident, records of that should be kept as well.
According to FMCSA, carriers must also update the files regularly by completing the following tasks 7:
- Annually – Contact your state agency for an updated copy of each driver’s motor vehicle record (MVR).
- Annually – Collect and review each driver’s MVR to confirm that they still meet the minimum requirements.
- Annually – Collect and review each driver’s convicted violations of motor vehicle traffic laws and ordinances and compare it to their MVR.
- Once every 24 months – Drivers must pass a physical exam and provide a copy of the certificate.
#4 Follow Hours of Service (HOS)
Over the past decade, there have been several new commercial motor transportation rules passed by the DOT. The most important of those was the hours of service (HOS) rules, which were safety compliance measures meant to ensure that professional drivers are rested, awake, and alert at the wheel.
These DOT rules include the following for property-carrying drivers 8:
- 11-hour driving limits – A driver is allowed to drive a maximum of 11 hours after 10 consecutive hours off duty.
- 14-hour limit – An exception was made for short-haul drivers that allow a driver to work a shift that lasts up to 14 hours max if they operate within 150 air-mile radii of their normal work reporting location.
- 30-minute driving break – Drivers are legally required to take a 30-minute break after having driven for a period of 8 cumulative hours without interruption. This break can be some combination of:
- On-duty not driving
- Off-duty
- Sleeper berth
- 60/70-hour limit – A driver can’t drive after 60/70 hours on duty in 7/8 consecutive days. Before they can drive again, they must take 34 or more consecutive hours off duty.
- Sleeper berth provisions – A driver can split their stipulated 10-hour-off duty period between sleeper berth and outside. However, they must spend at least 7 consecutive hours in the sleeper berth.
- Adverse driving conditions – A driver can extend the maximum driving limit and window by up to 2 hours if there are adverse driving conditions, such as a weather event.
#5 Install an ELD
In the past, driver hours of service (HOS) went by the honor system. Drivers either logged these events manually or used an automatic onboard recording device.
But incidents, where drivers fell asleep at the wheel or complained of overwork, compelled Congress to take further action. Now, electronic logging devices (ELDs) are congressionally mandated in every commercial vehicle required to maintain records of duty status (RODS) 9.
On the surface, these electronic solutions enable professional drivers to track HOS compliance by automatically tracking and logging operating data. They connect to the truck’s engine to maintain an accurate and comprehensive record of driver and vehicle activity. This allows for easier, more accurate HOS recordkeeping while ensuring that drivers take the breaks they need to stay alert.
In addition to installation, motor carriers are also expected to maintain ELD RODS data and backup data for at least six months.
#6 Inform Driver of FMCSA Rules
Carriers are required to keep educating and training their drivers. As a part of that continued training, carriers must provide each driver with a copy of the FMCSA regulation list. Additionally, the driver must sign a receipt for the document whereby they agree to follow the regulations therein.
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What Triggers a DOT Audit?
The vast majority of commercial carriers will be audited at some point in time. A DOT audit could be random or triggered by something by driver actions, such as:
- Vehicle crash
- Poor vehicle inspection reviews
- High CSA scores
- Road-side out-of service violations
- Complaints
- Failing a new entrant audit
If you are audited, you need to have all of the relevant documents prepared. According to IRP, only 7% of carriers undergo an audit without a single violation. The vast majority are hit with at least one civil penalty, which would result in hefty fines for the following offenses:
- Operating a CMV that was placed out of service – $19,277
- Recordkeeping errors – $12,919
- Knowingly falsifying records – $12,919
- CDL violations – $5,833
- Operating a CMV after being declared unfit – $27,813
AtoB Partnering with Carriers for Safer Roads
Whether you’re an owner operator of a single truck or run a large fleet, to run a successful business, you must abide by the state and federal motor carrier laws and DOT regulations.
At AtoB, one of our goals is to support our partners within the freight industry. In addition to offering one of the top smart fuel cards on the market, we also provide educational materials that you can leverage to stay compliant with the various rules and regulations. Our fuel cards can even help you automate IFTA compliance. Learn more about IFTA requirements.
Visit AtoB to learn more about our secured gas card and how to save on truck-related expenses. Start your AtoB fuel card application today.
Sources:
1 FMCSA. FMCSA Strategic Plan. https://www.fmcsa.dot.gov/sites/fmcsa.dot.gov/files/docs/FMCSA_FY2015_FY2018_Strategic_Plan_082618.pdf
2 FMCSA. Do I Need a USDOT Number? https://www.fmcsa.dot.gov/registration/do-i-need-usdot-number
3 FMCSA. Do I Need a USDOT Number? https://www.fmcsa.dot.gov/registration/do-i-need-usdot-number
4 ECFR. Code of Federal Regulations. https://www.ecfr.gov/current/title-49/subtitle-B/chapter-III/subchapter-B/part-390
5 America Truck Driving. Requirements to Become a Truck Driver in California. https://www.americatruckdriving.com/requirements-to-become-a-truck-driver-in-california/
6 Vector Solutions. Understanding DOT Drug and Alcohol Testing Regulations. https://www.vectorsolutions.com/resources/blogs/understanding-dot-drug-and-alcohol-testing-regulations/#:~:text=The%20DOT%20defines%20a%20safety,crew%2C%20or%20fixing%20an%20airplane.
7 CSA.FMCSA. Driver Qualification File Checklist. https://csa.fmcsa.dot.gov/safetyplanner/documents/Forms/Driver%20Qualification%20Checklist_508.pdf
8 FMCSA. Hours of Service (HOS). https://www.fmcsa.dot.gov/regulations/hours-of-service
9 FMCSA. ELD Rule. https://www.fmcsa.dot.gov/hours-service/elds/general-information-about-eld-rule
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Vedant Khamesra is the driving force behind product management at AtoB. Specializing in strategic partnerships, SMB solutions, and new product development, Vedant seamlessly navigates P&L responsibilities while leading product execution and strategy. He is fueled by AtoB's mission to empower truckers and fleets with intelligent financial tools and services, making their lives easier and more rewarding.
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