Jul 20, 2023

Be Prepared for Safety Compliance With Mock Audits

Conducting mock audits is a pivotal instrument that motor carriers must utilize to gain a profound comprehension of their operational performance during a Federal Motor Carrier Safety Administration (FMCSA) safety compliance review.

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Typically, this requires the engagement of a seasoned third-party consultant, well-versed in Federal Motor Carrier Safety Regulations (FMCSRs), to scrutinize a company's safety compliance standards exhaustively. Through this meticulous examination, areas that could potentially lead to an unfavorable safety fitness rating during an auditor's assessment are identified. Let's dig deep into these compliance programs.

Insight From a Regulatory Compliance Director

According to Mark Barlar, a Department of Transportation regulatory compliance director at an insurance agency that provides safety consulting, the majority of safety managers have not conducted an FMCSA actual audit or successful audit. This can be attributed to the complexities involved in the safety rating process, which may not be fully understood unless one is responsible for its enforcement.

An unsatisfactory or conditional safety rating signifies a deficiency in the safety management controls, leading to a restriction on the operation of commercial motor vehicles by the concerned business. Given that a carrier's safety rating is made available to the public, it can potentially impact the business's reputation with shippers and customers.

Insights From FMSCRs

Barlar, an expert in Federal Motor Carrier Safety Regulations (FMCSRs), underscores the significance of complying with all the regulations, particularly those in Appendix B to Part 385. These acute and critical regulations contribute significantly to maintaining a good safety rating.

Failure to abide by other regulations may not directly affect the safety rating, but it could still result in penalties and warnings during an audit.

The regulations outlined in Appendix B are of utmost importance as they pertain to numerous domains, including but not limited to general, driver, operational, vehicle, hazardous materials, and accidents, where the need for acute and critical measures is paramount. Barlar recommends conducting a mock compliance review in the order of these sections to ensure compliance with all necessary regulations.

The assessment of safety ratings takes into account the occurrence of accidents and the frequency of out-of-service incidents. In the event that the frequency of accidents in your transportation operation exceeds 1.5 crashes per million miles (or 1.7 crashes per million miles for urban carriers), or if the out-of-service rate during qualifying inspections exceeds 34%, an unfavorable safety rating shall be assigned. It is important to note that these factors are crucial in determining the overall safety of your operations.

Are You Prepared for a Safety Compliance Mock Audit? Here's Why You Should Be and Avoid any Further Corrective Action

Being selected for a compliance review can evoke a sense of unease among safety professionals who are ill-prepared for the process. However, conducting regular mock inspections and audits and gaining insight into the reasons why a business may be targeted can bolster the chances of success during an actual review. This is beyond the expected annual inspections to make sure compliance requirements and costly fines are executed.

According to Barlar, there are several key factors that may contribute to a company's selection for an FMCSA audit process with thorough audit reports. This is beyond their established safety rating. Notably, the seven Compliance, Safety, Accountability (CSA) Behavior Analysis and Safety Improvement Categories (BASICs) play a pivotal role in this determination.

The aforementioned classifications consist of perilous driving practices, collision markers, adherence to service hours, upkeep of vehicles, regulation of controlled substances and alcoholic beverages, compliance with company policy with hazardous materials, and driver physical preparedness.

Data that bears significance is procured from examinations conducted at roadside inspections, evaluations of accidents, and outcomes of thorough investigations.

Barlar elucidated that maintaining an "alert" status for any of the seven Compliance, Safety, and Accountability (CSA) categories increases the likelihood of being subjected to an audit

Furthermore, a higher number of alerts in one's CSA profile amplifies the probability of an audit. In addition to this, if an individual lodges a complaint against a business to the Federal Motor Carrier Safety Administration (FMCSA), it is mandatory for the agency to investigate it. Although such complaints may not always lead to an audit, it is contingent on the nature and severity of the complaint.

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Best Mock Audit Practices

To adhere to best practices during a genuine audit, it is recommended to maintain segregated files to mitigate the risk of disclosing superfluous information, as advised by Barlar. In order to maintain optimal organization and compliance, it is recommended that vehicle maintenance records, driver qualification files, and crash records be separated, and that driver qualification documentation be kept separate from drug and alcohol files.

Furthermore, Barlar suggests preparing a sample file for each driver and vehicle that contains all requisite information. This approach enables a company to train safety personnel effectively and obtain the necessary documentation.

Lastly, Barlar recommends conducting mock audits on a regular basis. 

Via the inspection process, checking detailed records of driver files, training records, medical records, vehicle maintenance files, past compliance audit reports, and current policy or compliance regulations will help re-surface any underlying issues (or even obvious issues) that are taken for granted.  

Industry standards should be strictly followed and must be considered by business owners as a business priority.

It is recommended to conduct FMCSA audits at regular intervals, preferably every few years, to ensure that the safety personnel in your department are well-equipped to handle them. This practice can also be adopted whenever there is a change in the safety personnel. Monitoring standards and safety standards really matter.

According to Barlar, this approach can prove to be beneficial in imparting knowledge and skills to the safety department staff regarding the successful navigation of FMCSA audits.

To aid motor carriers in preparing for such audits, there are companies that offer the services of their FMCSA regulation experts who can conduct both on and off-site mock audits.

For more information on availing of these services, connect with us at Labworks USA as we have a network of Trucking industry companies to support you.

Moreover, if you need support with DOT and FMCSA compliance, feel free to contact us today.

If you are looking for more information about drug and alcohol testing as a truck driver, visit LabWorks USA. Our DOT Consortium's friendly team will be more than happy to discuss any concerns you may have and work with you to ensure you are always fully compliant specially with random DOT drug and alcohol testing pre-employment testing. Moreover, if you need help with FMCSA Clearinghouse registration, we can further support you.