“YOU'VE got mail” may not be a welcome message for a safety director when the letter comes from a Department of Transportation (DOT) auditor announcing a visit. However, if a company has been following the regulations and properly documenting its operations, the message loses some of its threat.
Like many fears, concern about a DOT audit can be eased by understanding the process — and the officers that conduct it, according to presentations during the International Milk Haulers Association Spring Convention April 21-24 in Mesa, Arizona.
“Make yourself available to the auditors,” said Matt Meyerhoff of the Salt Institute, a consulting firm in Phoenix, Arizona. “Give them your cell phone number, your home phone number, your e-mail address. On the day of the inspection, take them to lunch, even though there will have to be separate checks because of government regulations. Running from the auditors just makes them think you are trying to hide something. Remember, their job is to identify what you, the drivers, or maintenance people are doing wrong. It is your job to show the enforcement agents what you are doing right.”
While being pleasant and considerate should be the order of the day, hospitality in this instance does not mean that the safety director can't schedule an audit date that will be convenient for the carrier. In addition, the company's offices should not be turned over to the inspectors when they arrive. Meyerhoff suggested that the auditors be given a tour of the facilities by the safety director and then placed at a desk, or in a conference room, away from where drivers are moving about.
Before the auditors arrive, employees should be advised that DOT auditors will be on site and that the employees should conduct themselves accordingly.
When the agents are settled, the records they ask for can be brought to them. “Only give them files that are asked for,” he said. “And don't give them permission to go through your files.”
A list of drivers and equipment should be presented voluntarily to show cooperation. The list will have to be provided anyway, he added. Certain records relative to the requirements of the regulations will be inspected. On occasion, supporting documentation will have to be provided. Auditors will ask for the location of all records and probably will ask who is in charge of the records.
“Stay with the auditors, if possible. If not, check on them regularly,” Meyerhoff said.
The auditors will bring with them computers and scanners that they will use to enter information and copy company documents. Because of the capabilities of the electronic equipment, a report will be provided before the auditors leave.
For the audit to be positive, a company must “have its ducks in a row,” Meyerhoff said. That means that files must be up-to-date, particularly driver qualifications, driver logs, maintenance files, and daily condition reports.
“In addition, be sure to have your insurance certificate readily available, along with your accident register,” Meyerhoff said. “Hang the insurance certificate on your wall and have a copy of the Federal Motor Carriers Safety Administration regulations in sight.”
Typically, agents begin the review with the insurance certificate and accident register. “Thereafter, they usually go for the driver qualification files and then the driver logs, which leads them to the maintenance records,” he said. “They will check the driver logs against the driver daily condition reports, making certain your drivers prepared the daily condition reports on the equipment they operated.
“Thereafter, the agents will normally review equipment files and identify if they have been set up and maintained correctly. They will ask for your system of systematic, lubrication, inspection, and maintenance.”
Companies may be shown certain violations that have been discovered as the audit progresses. The agent may ask questions about how drivers are controlled. Company employees also may be questioned on numerous subjects, including the overall safety and compliance program.
When the audit is completed, the auditors will hold a conference with the safety manager, and in all probability, a vice-president or the president.
“During the conference, they will present the report of findings and recommendations, along with computer generated reports,” Meyerhoff said. “They will ask that officials of the company acknowledge receipt of the report by their signatures. Signing the report is not an admission of guilt, but merely receipt of the report.”
After the auditors are gone, the report should be examined closely, along with the recommendations. Necessary actions must be taken to restructure any areas of the safety and compliance program to eliminate the violations that have been identified.
“If you have received a less than acceptable report, you should prepare a Report of Corrections signed by the vice-president and/or the president,” he said. “Address it to the auditor's office and clearly set forth what corrective action you have taken to eliminate the violations discovered by the auditor. This may or may not stop punitive action relative to the discovered violations. It certainly cannot do further harm to your organization, unless you fail to take the actions you have indicated.”