The FEDs Are Coming!

Jim Luff
Posted on April 10, 2013

Part 1 of 4: Preparing for a Department of Transportation Review
 
If you’re a regular reader, you know that I was recently audited by our insurance carrier for safety. We cruised through that microscopic look at our operations without so much as a suggestion offered for improvement. We all still have worries when examined by anyone. With so many laws, rules, regulations and compliance issues, I always wonder if there is something I am missing.

When you get a phone call from someone that identifies themselves as a “Special Agent for the U.S. Department of Transportation,” it tends to get your attention. The email you were about to write disappears in your head. The bills you were about to pay don’t seem so important. As a matter of fact, the whole world stops spinning during that call. Your heart races as you wonder, “Why would a special agent be calling ME?” 
 
I didn’t have to wait long for the answer. The special agent informed me that we had been randomly selected to be audited in a safety compliance examination. Yikes! The word, examination, is so scary. Now, don’t think for a minute that I don’t run one of the tightest ships in the nation. I truly believe that. But, even so, I wondered what would be examined: How long would it take? How deep would it go? How far back in time? My stomach was in knots. It was Feb. 19. The examination would take place in 15 days. I timidly asked, “Is there anything I need to do to prepare?” “Yes, I will fax you a list of what I will be examining” was the answer.” Oh, goodie!
 
I received a fax that told me to have the following information available at that time:
 
• Insurance  Form MCS-90B
• Interstate Operating Authority Permit
• Articles of Incorporation
• Gross Revenue for the last fiscal and calendar year
• Federal TAX ID number (proof of)
• List of all terminal locations, addresses and phone numbers
• Total miles of all units used in the past year from today
• Accident Log for the past year
• Accident files for the past year by accident
• List of all drivers, their hire date and the first day they drove
• All records relating to Controlled Substance/Alcohol testing
• Pre-employment, post-accident and random test results for the last year
• All educational materials and supervisor training certificates relating to above
• List of all vehicles, company ID, license plate number, make, model and year
• All driver files
• All maintenance records for each vehicle operated in the past year
• All Daily Vehicle Inspection reports in the past 90-days
• All payroll time cards for the past six month
• All Daily Driver log reports completed
• Supporting documents such as trip packets, dispatch records, invoices and fuel receipts for the past six months.
 
Oh my goodness! This is a lot of data. Not that it wasn’t all readily available without any effort at all, but I was concerned about the condition. Was everything in order? Would he like it in chronological order to make it easy? 
 
There was no doubt in my mind that nothing would be amiss with driver files. We follow a meticulous routine each time someone is hired and they can’t start training until we have their pre-employment drug screen results. But, things such as oil change receipts tend to just get thrown in the file in no logical order. I wanted to be nice and neat in appearance and hope that I could get the guy in and out in a few hours. Surely he would not go through the entire year.
 
Boy, I was so wrong! A few hours? Yeah, right! This agent took up residence in my office and literally arrived with a suitcase. Come back to this blog next week, as my adventure is just getting started.

— Jim Luff, LCT contributing editor

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Jim Luff Contributing Editor
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