At some point in time, while operating your trucking company, you will be the active recipient of an on-site focused investigation performed by the Federal Motor Carrier Safety Administration (FMCSA). Rather than react to this news after seeing the letter, it is much better to be proactive knowing it will eventually happen. This article will prepare you for what you need to know and what is going to happen during the inspection.
Proactive Measures for a Successful FMCSA Compliance Review
Prior to arriving the FMCSA officer will generally request a copy of your driver list, vehicle list, and copy of your current MCS-90. At the time of the onsite visit, they will review the following documents:
Proof of financial responsibility
Driver Qualification Files
Drug and alcohol testing records
Records of duty status and supporting documents
Driver vehicle inspection reports and maintenance records
FMCSA accident register
Hazardous materials records (if applicable)
The audit is normally one or two days long. Because of the amount of information that will be reviewed, having this material ready upon arrival and organized is essential. This shows that your company is dedicated to compliance and safety. While you should have all the information ready and organized, provide only the information to the investigator as they request it.
The paperwork will be audited, but the auditor will be requesting more explanation of your programs, processes, and policies. Rather than just having a driver hiring process on paper, they want you to be able to explain it, how it works on a daily basis, and real world situations. Having everything documented is essential, but the investigator will need to know that it is actually understood and implemented to offer satisfactory scores.
Auditing Beyond Paperwork: Programs, Processes, and Policies
The single most important area of review is for hours-of-service. This is frequently where carriers are downgraded with civil penalties assessed and even shutdowns occur. Any time a high-profile accident occurs, this is the first category discussed. Investigators want to see a meaningful program in place. If electronic logs are not currently in place, it is a necessity to have a documented system where punishments or incentives are meaningful for specific behavior in logs.
Offering multiple written warnings will no longer be deemed an effective management strategy.
Being proactive on the following activities should make the receipt on notice of inspection a non-event.
From the beginning, hire safe and qualified drivers. Use a Pre-employment Screening Program (PSP) and document the guidelines.
Document safety policies.
Require monthly driver meetings.
Use your PIN number on CSA to track all roadside inspections by driver. Utilize Data Q.
Create driver reward programs and set discipline for those outside standards.
Review all crashes and have responses to each.
Conduct internal audits to make sure everyone on the team is completing the required processes.
If you focus on the 6 categories at the beginning of this article (7 if you’re a hazmat carrier), and have solid processes to back up the paperwork, these investigations should go very smoothly.
Resources
May 2014 Webinar, “What to Expect during your FMCSA Compliance Review,” Transportation Safety Webinar Series