These tips will keep you better prepared for FMCSA/DOT compliance reviews

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Now that summer travel is underway, it’s a good time to be sure your business is compliance- review ready. Mike McDonal, who is also Chair, Bus Repair and Maintenance Council and Past Chair Bus Industry Safety Council, recaps important “to do’s” including:

• Know when your review is due. Check out FMSA’s website to verify your last audit. Expect to be audited every three years, but keep your records up to date at all times, one bad day could lead to a very extensive investigation.
• Know how to proceed if you don’t have a safety director. Designate a specific staff member or an outside source, to be responsible for safety policies and compliance. This person will need to be knowledgeable about compliance, audits and able to enforce drug testing and maintain drug-testing census. Additionally, they’ll have to track and record driver and maintenance crews’ certifications while keeping orderly files on drivers’ commercial driver’s licenses (CDLs), medical cards (A DOT medical exam is valid up to 24 months) and pre-employment drug testing and other current records on file.
• Know what should be included in a driver’s binder onboard the buses. Information should include proof of vehicle insurance, registration and the ELD (Electronic Logging Device) information sheet to be carried on each trip. Also, don’t forget copies of paper logs if there is a malfunction of your ELD.
• Know how to prepare your drivers. Each driver should know what to expect if they are stopped for a roadside inspection, including how to properly operate emergency hatches and windows and the ADA complaint wheelchair lift. They should also be prepared to show all of their documentation form the bullet above as well as transfer their electronic logs if requested.
• Know to offer specific ELD training. Drivers should know all FMCSA-required ELD features and how to use the technology as intended. Check if your ELD vendor has training materials for drivers. Train with your payroll staff on paperwork verifying that hours-of-service information provided to FMCSA is correct.
• Know to keep your maintenance team’s training and certifications current. A safety inspector will often ask to see documentation your mechanics have showing they’ve been trained and tested to repair brakes and other key components on your coach.
• Know how to inspect your equipment. Using the following FMCSA criteria found here, and check emergency exits within the 90 -day required period.
• Know how to write your documentation. Make sure documentation is clear and needs no further explanation, when uploading to FMCSA’s site. Many investigations are being off site now. Your documentation will have to “speak for itself.” You may not have the opportunity to answer questions or explain a situation like you could in person in the past.

“The key elements in a review are drivers, vehicles, drug testing, qualifications of drivers and mechanics, hours of service, maintenance, accidents, and record-keeping systems. A compliance investigation will include the drivers and vehicles in use over the past 365 days and DOT reportable accidents during the past year,” said McDonal. “Be investigation-ready all the time. If the FMCSA gives two days or two weeks’ notice for a safety audit, you’ll be prepared.”

For more information, find FMCSA compliance manual here, or reach out to Mike McDonal with your questions at mmcdonal@saucontech.com or call: 410-245-5525.