Internal Compliance Review
When we start working with new companies one of the first things that we do is come in and conduct and Internal Compliance Review to determine your compliance standing in the eyes of the Federal Motor Carrier Safety Administration (FMCSA). Not only do we do this when starting with new companies, but we also perform our Internal Compliance Reviews when out current clients want us to start doing more for them.
During the Internal Compliance Review, we come in and look at the same documents and files an auditor would look at. By doing this, we get a better idea of the standing of your company, where your company could use our assistance and how your company would do in an actual federal audit. During this initial assessment, we give your company a safety rating and recommendations on how to fix the issues found.
We look at nine different categories to assess each motor carrier's safety, most of these categories are associated with a specific Federal Motor Carrier Safety Regulation (FMCSR). These categories are Carrier Operations, Accidents, Driver Qualification, Drug and Alcohol Testing, Hours of Service, Vehicle Maintenance, Safety Analysis, Training, and Hazmat Compliance (if applicable).
This category is relatively straight forward. We look at the overall operations of your company to include number of commercial motor vehicles, number of drivers and their CDL class, internal policies, inter/intrastate operations, as well as required forms and documents. This gives us an idea of the rules and regulations your company is required to follow, as well as what your company might not be doing correctly.
In this category, we focus on accident prevention, investigation, and reporting in regards to 49 CFR 390. This includes number of accidents, internal investigation reports, external investigation reports, written statements, training, and post accident testing.
The driver qualification category of our internal audit is the largest, and the category where we find the most violations. The driver qualification (DQ) file will be completed upon initial hire, but should be updated with each driver's specific information throughout their time as an employee for your company. In the DQ File, you are required to have their application for employment, previous employment, initial and annual MVRs, road test examination, medical certificate, previous drug and alcohol testing, and many more.
Drug and Alcohol Testing
All CDL drivers are required to be enrolled in a drug and alcohol testing program. We look for a DOT and Non-DOT, random, and pre-employment programs. There are also certain percentages of each fleet that must be tested for drugs and alcohol that carriers are required to meet.
Hours of Service
In this category, we look at driver's record of duty status, violation of the 14 and 11 hour rules, certain hours of service exceptions, and electronic logging devices.
Vehicle Maintenance Programs need to be compliant with 49 CFR 393, 396 and Appendix A. We look for a general maintenance program, periodic inspections, pre/post trip inspections, Driver Vehicle Inspection Reports (DVIRs), and roadside inspection reports. We also look for proper file management for all vehicle maintenance.
The safety analysis is geared towards the FMCSA's Safety Measurement System (SMS) data. The SMS is broken up into BASICs, and violations in these basics could trigger a compliance intervention. We come in and look at your BASICs, the frequency of data review, and completed FMCSA DataQs.
Training is required among all FMCSA regulated companies. We look for onboarding training and what it consists of, safety meeting topics, if drivers have a copy of the FMCSRs and if the carrier has an up-to-date copy of the FMCSR. One of our specialities is training, and we provide all our clients with training recommendations to help ensure their drivers are properly trained and refreshed.
If a carrier is hauling hazardous materials we look at shipping papers, how materials are transported, states permitted in, placards, records of training and the security plan. If the carrier doesn't haul hazardous materials, this category is skipped.
This has just been an overall glance at our internal compliance review, and more information is looked at than disclosed in this post.
After looking through all of these categories and assessing your company's standings and address the number of acute and critical violations, letting companies know where their standing would be if this was an actual audit. By doing this, we can also estimate the potential fines the company would face. From here we are able to list out our recommendations to eliminate your company's violations and allow for you to be in a better compliance standing.
Our team at Front Range Compliance is made up of audit experts, and we are here to help you. We have programs in place to assist all motor carriers in every area of our internal compliance review, and specialist ready to work with you. If you have an impending audit or just would like some help with your compliance, contact us and we will help you!
Our internal compliance review will be complimentary if the carrier sign a service agreement with Front Range Compliance.
Make sure to check out our online DOT Training platform, DOT University! We currently are offering Reasonable Suspicion for Supervisors, Cargo Securement, Defensive Driving, and Pre/Post Trip Inspection. In the coming months, we plan on releasing Designated Employer Representative and Appendix A.
Until then, check out our other blogs or follow us on Facebook, Twitter, and Instagram to be the first to know when new classes are made available or for other updates like this! You can also opt-in to our newsletter for exclusive offers, regulation changes, and industry news!
Stay Off The Radar!