Part 4 of 4: My company’s D.O.T. audit finally comes to a merciful end. I am all the wiser.
Part 3 of DOT Audit Series
As we left off last week, se concluded our late business day by inspecting the Driver Qualification files (a fancy term for your personnel files). I had honestly believed that since he was in the middle of that task at the end of the day, he would “sample” a handful. This was not the case. He checked every single file and some he seemed to take much more interest in than others. In one instance, one of my drivers had his license suspended, as indicated on his Pull Notice review contained in the file. The driver got a speeding ticket sometime in the past and didn’t take care of it. However, when we were notified by DMV of an impending suspension (via Pull Notice notification), I had initialed the form, called the driver to discuss, made a note of the call, put an entry into my Outlook calendar for follow-up, and encouraged the driver to take care of his business. He assured me he would.
He did not take care of it and his license did become suspended. This caused me to personally take the driver to the court house, be nearly strip searched to enter the building, pull a number and wait. I personally paid the fine, obtained the receipt along with a statement that indicated the driver’s license was reinstated effective immediately. Those documents were also in the file after court. However, Mr. Inspector took the extra effort to call the California DMV to ask as to exactly what time it was reinstated and then match it to a run time start. He was quite frank with me that I could have a violation here. In the end, I did not. However, I did get a strong warning that this should not have taken place on the day of suspension but rather handled the day the notice came in the mail. In hindsight, I agree.
Now, as I mentioned, it was time to get down on dirty in examining hundreds and hundreds of trips during the remainder of his visit. I always feel like the less information I offer up, the better. After all, I think a good “sampling” of data is a good indication of how we run our ship. Before his arrival, I had five staff members comb through every single trip-ticket in an effort to make sure everyone of them had proper documentation. This would include the trip-ticket, fuel receipts for the trip, a DVIR (Daily Vehicle Inspection Report) and any other information relative to a particular trip such as hotel receipts on overnight trips or Driver Daily Logs on over-state-line trips or trips over 100 miles. Because we file this information together anyway by month, it wasn’t a big deal. However, receipts become detached over the year or pulled out of order for review and just stuck back in the box.
I made it nice and neat by having all the tickets in order by date, followed by driver name, followed by chronological start and end time of the driver’s day. We filed three months at a time in banker’s boxes. Each box clearly marked with file dividers separating the three months. Seriously, I am going somewhere with this line of thought.
Upon completion of the driver files, the inspector stated that he wanted to review individual trip records for 2012. I said, “No problem. Let me go get them out of storage. They might be a little dusty.” I brought back one box. I selected 2Q 2012. I said, “I just grabbed 2Q for now. If you want to maybe just pick a month out of there I can pick a month out of the other three boxes.” He replied, “No, I’ll take them ALL.” Ugh!
For the next day and a half, he would pour through ticket after ticket after ticket performing calculations and a forensic review of any trip that crossed a state line or involved multiple days of travel or trips over 100 air-miles from our base. This would include his own mileage calculation based on MapQuest or something similar and then compare the driver’s mileage entries, compared to average mile per gallon of the vehicle and drilled down to fuel receipts that support the particular trip. I can tell you that some were looked at really hard.
One thing that is a plus for me is the fact that we have a policy that every vehicle is refueled after every trip concludes. I didn’t set this up 20 years ago to comply with any government agency. I set it up because I want to know EXACTLY how much money we make on every job. I have a spreadsheet I use to determine how much profit each vehicle produces by day or month. Even if we only do a local airport drop-off and pump in $7.23, I know that the trip cost $7.23. Because of this, we could easily substantiate every trip.
Apparently, some operators let their driver’s drive more in a day than legal. Of course, they have to buy fuel for the additional driver hours and the inspector can easily figure this out. He reviews the gas card assigned to that driver during that day. He next compares all fuel purchases made using that card in that day (days) against your fuel statement from your fuel vendor. Next, they review the driver’s stated ending mileage of the last trip-ticket of the day being examined. He then compares the starting mileage of the next driver of that vehicle from the DVIR and the trip-ticket. So, if you’re thinking of just throwing away or “hiding” a ticket that may have gone over, you’re going to get caught. In case you were wondering, I did not get any violations but it was pointed out that I came dangerously close in several cases to Hours of Service (HOS) violations.
These changed as of 2013 so you might want to bone up on them. The HOS rules that apply to our industry are more stringent than truck drivers hauling cargo. I was summoned to the inspector’s desk about once an hour to “explain” something. I am proud to say that not one violation was discovered in an examination of 4,981 trips performed.
As quickly as he arrived and set up his “office” the inspector packed his bags, came to my office and asked, “Would you like to discuss your audit or shall we just mail you the results?” Of course I wanted to discuss them right now. I asked him if I was going to get a citation. He replied, "Why would you ask me that?" I told him that I knew many operators who went through this audit and almost all of them got a ticket of some kind ranging from $500 to $30,000. He replied comically, “You don’t get to join that club.” He presented me with some “recommendations,” had me sign a form and said it was nice meeting me. I left shortly behind him to my favorite watering hole, RJ’s Bar and Grill, where I promptly ordered one large draft beer and one small shot of Patron Tequila. The nightmare was over. I felt like I just woke up from a bad, bad dream.
PREVIEW: Tune in next week when I share my, “Buck Stops Here” story as I was forced, (due to a driver shortage) to drive a 55--passenger bus to Staple’s Center in Los Angeles last Saturday night and my harrowing experiences.
— Jim Luff, LCT contributing editor
It's not only the most wonderful time of the year, but also one of the most dangerous.