Operations

Avoiding DOT Recordkeeping Nightmares

Posted on September 16, 2014 by - Also by this author

Employers are tasked with keeping records that would make a librarian dizzy trying to remember where everything is stored. Transportation companies are tasked with keeping records of employees, accounting and fleet vehicles. This article emphasizes DOT recordkeeping issues that will ensure you are prepared for a Compliance Review.

Why You Need Organized Records
Carlos Blanco, a field inspector for the U.S. Department of Transportation, advises that organized records ready for inspection can smooth out the audit process. This demonstrates a commitment to safe operations and may influence the depth of the inspection. An average inspection or “review” as Blanco calls it will take two to three days. Having well-organized records can shorten the visit to a day and a half, Blanco says. Jason Followill, a motor carrier inspector for the California Highway Patrol, elaborates on Blanco’s advice: If you can’t find records or produce them for examination, it will raise red flags and doubts.

Business Records Folder
Photocopies of the items described below should be readily available in a single file. The copies must be valid for the current period of inspection. Here is a list of business records that must be produced upon request under DOT regulation code 49CFR 390.29:

Insurance Form MCS-90B
• Easily obtained upon request from your insurance agent.
• This document is similar to the insurance certificate you file with your state authority.

Interstate Operating Authority Permit
• Easily obtainable by visiting www.safer.fmcsa.dot.gov and printing the .pdf file.

Copy of your Operating Authority Permit from your state

Copy of your Articles of Incorporation

Gross amount of revenue for the last fiscal year (tax year) AND last ending calendar year.
• The easiest proof of revenue for your last tax period is to provide the front page of your tax return. Since you also are required to provide your tax ID number, this document will suffice for both requests.
• For the calendar year ending revenue statement, a simple Profit & Loss statement for the past calendar year will suffice.

List of all terminal locations by name, address and phone number.
• For most operations, there is only a single location. If you have more than one, you will need a list.

A master list of all vehicles operated in the past 365 days.
• Company vehicle ID
• Vehicle year
• Vehicle make
• License plate number
• VIN (Vehicle Identification Number)

A master list of all drivers who operated vehicles in the past 365 days.
• Driver’s legal name
• Date of hire

Vehicle Records Folders
Each vehicle should have its own folder containing the history of the vehicle from the date of purchase to the date of retirement. The file should include when and where you purchased the vehicle, the odometer reading when placed in service, and purchase documents. There are many other documents that will be placed in this file through the life of the vehicle as indicated below:

Total monthly miles from first day of each month to the last.
• You must show total miles of each vehicle in the past 365 days.
• This is not the past year but 365 days before the date of inspection.

Lubrication Records
• Lube, oil and filter service performed (LOF) with date/mileage
• Fittings/undercarriage lubrication
• Radiator flushes

Monthly or quarterly detailed vehicle inspections (Not DVRs)
• Brake system inspections (list who performed them)
• Emergency exit checks (must be done every 90 days and logged)
• Tire/wheel inspection
• Engine/driveline/axle/transmission inspection
*Note: You must provide proof that the person performing monthly or quarterly inspections is qualified to do so, such as having a training certificate on file.

Accident Register and Accident Files
In the event a vehicle operated under your authority is involved in a serious accident, you must record it on an accident register. You also must maintain an accident file with the details of the accident. A significant accident is one in which a passenger transportation vehicle has a GVWR (Gross Vehicle Weight Rating) of 10,001 lbs. or more, can carry 15 or more passengers (including the driver), and there is a fatality or injury requiring medical treatment away from the scene OR the vehicle must be towed from the scene. The information must be maintained for three years from the date of the incident. Even if you have no accidents, you must maintain a log for each calendar year and have it ready for inspection.

The following information must be entered into the accident register:

• Date and time and location of the accident
• Number of deaths
• Number of injuries (treated away from the scene)
• Driver’s name
• Insurance claim information
• Police report number and agency name completing the report
An accident file is a separate file containing information about a specific accident. While DOT publishes no specific guidelines about the required contents of the file, the CHP’s Followill recommends you keep the following documents in the file:
• Summary of the accident including date, time, location, vehicle ID and driver
• A brief description of the crash compiled by personal observation of the driver
• A brief description of the crash compiled by company officials on scene
• Photos of the accident scene
• Diagrams of the scene
• Law enforcement accident report
• Company accident report
• Towing receipts
• Repair estimates and invoices detailing parts repaired or replaced
• Post-accident drug/alcohol test results (place a copy in driver’s file as well
• All insurance claim information
While all of the above is not legally mandated, having such information can help refresh your memory and that of the driver if a lawsuit is filed as a result of the accident. It may be years after the accident before depositions and court hearings are held.

Controlled Substance/Alcohol Test Requirements
Although it may seem redundant, Inspector Blanco recommends you keep company records and statistics in a binder, which should be kept in a locked cabinet, and place copies of test results in the driver’s individual qualifications file. The following information should be kept in the binder:
• Pre-employment test results*
• Post-accident test results*
• Random test results*
• Statistical summary from the performing laboratory
• Annual testing summary for the prior year from the performing laboratory
• Inquiries sent to previous employers and results*
• Company drug/alcohol policy
• Educational materials
• Proof of supervisor reasonable suspicion training*

*Note: Copy in employee file

Driver Qualification Files
By far the most scrutinized part of the inspection, the people transporting the public are Followill’s biggest concern. Each commercial driver must be verified as adequately qualified to safely transport passengers in assigned vehicles. Blanco recommends you maintain every driver file in the same order of documents:
• Driver application (Must conform to 391.21 of DOT Code).
• Motor vehicle/license report (MVR) covering the past three years.
• Record of road test and certification including who performed it, when, and what driving functions were inspected and by whom.
• Three years of DOT physical certifications.
• Copy of driver’s license and valid medical certificate.
• Drug/alcohol testing results (pre-employment, random, reasonable suspicion, post-accident) using federal custody and control forms.
• Driver signed acknowledgement of the drug/alcohol policies of the company.
• Copy of requests sent to previous employers (for three-year period) for previous drug/alcohol test results. You also must have systems for tracking the following:
• License expiration date
• Medical card expiration date
• Endorsement expiration (ie school bus driver, para-transit etc.)

Operations Files
The final part of the examination is related to how you operate and document your daily operations. Trip information can be contained together by attaching the following documents to document a driver’s daily activity as it pertains to hours of service and safety:
• Trip ticket with date/pickup time/location and destination location
• Miles traveled
• Start and end time of each trip (hours of service)
• Driver’s daily vehicle inspection report (DVR or DVIR)
• Driver’s daily log (if more than 100 air-miles from terminal)
• Fuel receipts from the day or trip

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