The first order of any business with a DOT number, should be improvement. Particularly in understanding what deficiencies, processes, or controls are missing from day-to-day operations. This requires a plan. Especially since regulatory enforcement activities are on the rise this year. We talk to people every day who are operating by the seat of their pants, scrambling to keep up with the too numerous and ever changing requirements of the FMCSA. But it doesn’t have to be that hard.
Are you prepared?
This year, FMCSA has expanded it’s “off-site” audits to all 50 states. Off-site audits take less time, cost less, and are more efficient. Because of this, the potential for many more carriers, those who have not been audited or been subjected to intervention, could be facing a CSA scrutiny.
If your CSA scores/Safety Measurement System (SMS) are high in one or more of the Compliance, Safety, Accountability categories or BASICs (Behavior Analysis and Safety Improvement Category) you are likely receive a warning letter or investigation.
Before we talk about what triggers an audit, let’s understand the methodology of the SMS, which is the program that holds motor carriers and drivers accountable for their role in safety:
FMCSA organizes the SMS data into seven Behavior Analysis and Safety Improvement Categories (BASIC) and is updated monthly:
- Unsafe Driving – Speeding, reckless driving, improper lane change, inattention, no seatbelts
- Crash Indicator – Histories of crash involvement
- Hours of Service Compliance – Noncompliance with HOS regulations, including logbooks
- Vehicle Maintenance – Brakes, lights, defects, failure to make required repairs
- Controlled Substances/Alcohol – Use/possession of controlled substances/alcohol
- Hazardous Materials Compliance – Leaking containers, improper packaging and/or placarding
- Driver Fitness – invalid license or medically unfit to operate a CMV
After an investigation, a motor carrier may be issued a safety rating. A safety rating reflects date of investigation and are as follows:
- Satisfactory – After an onsite Comprehensive Investigation was conducted, safety controls were found to be sufficient.
- Conditional – After an onsite Comprehensive or Focused Investigation was conducted, safety controls were found to be inadequate but have not yet resulted in violations.
- Unsatisfactory – After an onsite Comprehensive or Focused Investigation, safety controls were found to be inadequate which resulted in violations. A motor carrier with a final rating of Unsatisfactory is prohibited from operating a commercial motor vehicle in interstate commerce.
However, not all audits will change a rating. Focused audits will look at one or two areas and may not effect a rating unless the violations are too critical or acute. But are you willing to take that chance? Something benign could easily become malignant.
Scores are given to drivers and motor carriers.
What triggers an audit?
- High CSA scores
- Too many violations per driver
- Out of service violations
- Failure of a New Entrants safety audit
- Disgruntled employee files complaint
- Neglecting to fill out the MC150 correctly (falsify) and on-time
PUT A PLAN IN PLACE
Don’t be caught off guard. Contact us today to put a Safety Management Plan in place. Or if it’s too late and you’ve already been audited and are in jeopardy of being put OUT-OF-SERVICE, let us help you with a Safety Rating Remediation (SRR).
The first thing we will do is help you submit a request to the FMCSA to request a Satisfactory upgrade. Then we will help you take the corrective action identified as well as develop and implement a sustainable plan to bring you into compliance. We will also help you develop a comprehensive Safety Management Plan (SMP).
Not sure where you stand from a DOT Compliance perspective?
Contact us today for a proactive plan –before you get a call from an investigator!