An Audit Avalanche

Jim Luff
Posted on March 27, 2013

First an insurance audit. Now a federal audit!
Recently I wrote about being inspected by our insurance company. No one really likes to be under the microscope. However, since our “cargo” involves transporting humans, I understand the need for oversight and compliance.

When the insurance company told me they were sending someone to inspect us, I had some trepidation. But I figured the worst thing an insurance inspector could do is tell the insurance company that we were high-risk and we would get cancelled. That wouldn’t be the end of the world. It would just make us shop for a new carrier. I was delighted when I received a letter from Zurich Insurance following my inspection. It was an obvious form letter that had an area to specify what improvements we could make to be safer. The letter said, “We have no recommendations for you.” How perfect is that?
Shortly after that, I received a letter from the U.S. Department of Transportation notifying us that they were coming for a full inspection of our company and we could plan on them being in our office for two full days. I have been given a list of 16 areas they want to review. This includes insurance, production of permits to operate, articles of incorporation, revenue, annual miles of each vehicle, accident records, driver records, drug and alcohol testing records, driver log books, trip tickets, maintenance records, daily vehicle inspection reports, and even fuel receipts for an entire year.

Talk about shaking in my boots! We run a tight ship but I sometimes feel such inspectors don’t come looking to see if you are running a tight ship but rather where they can find a single violation to write you up for and give you a citation. I know that Steve Levin with Sterling Rose Transportation near San Diego went through this several years ago and got in trouble for something as minor as not having a lock on the filing cabinet where he stores is driver records. There are so many laws and regulations that it is possible to miss something. That's the part that is scary.

The laws are also ever changing. For instance, starting this year, a chauffeur standing by at an amusement park is now considered “Off-duty.” So, in the past, a chauffeur could only be on-duty for a total of 15 hours in a day. Of those 15 hours, only 10 of them could be spent driving. That 15-hour period could only begin after the driver had eight consecutive hours off-duty. Under the new Hours of Service (HOS) rules, a driver that arrived at Disneyland at 10 a.m. and didn’t depart until 7 p.m. would be considered off-duty and available to drive 10 more hours in the next 15-hour period. That doesn’t really seem safe to me but I was told this directly by a DOT representative. 
Well, wish me luck. This audit will give me fodder for a whole series of blog posts. Stay tuned for what I hope will be minimal drama.

— Jim Luff, LCT contributing editor

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