DOT Audit Gets Down N' Dirty

Jim Luff
Posted on April 24, 2013

Part 3 Of 4: Day One of my U.S. Department of Transportation review was turning into a very long day. We still had to get through the afternoon and evening.

Shortly after 1 p.m. the, the examiner left for a few hours to participate in a teleconference. By 3 p.m., he was back. I had hoped the conference call would be intense and take the rest of the day. No such luck.

It was time to get on to a review of our drivers’ files. These are called a Qualification File. To us, they are known as personnel files and D.O.T. wants these files to be in order. To them, they are, as the name implies, the proof that each driver in your company is qualified to drive and that you took reasonable efforts to make absolutely sure the driver was fully qualified before he ever drove for the first time. This is crucial. The inspector checked every file for the hire date of the employee and took special note of the day the driver was hired, drug and alcohol tested and the results were confirmed and acknowledged. 

Before I go too much further on the drug and alcohol results, let me warn you that your files must be kept in a locked cabinet and access to the files and their confidential materials must be safeguarded and accessed by only those people who have a legitimate need to access the file. Failing to secure these documents is violation of its own.

Continuing with the drug and alcohol testing process, as you know, a driver may not operate the vehicle without being tested in a pre-employment test for drug and alcohol abuse. Once the test results are returned, you must initial on the test results page the date you received and/or viewed this document before placing it in the qualification file. You also must keep a record of how many tests you performed each year by the type of test including pre-employment, random and suspicion of abuse tests and the results of each type of test. Tests can be alcohol only, drug and alcohol or just drugs for random tests.

The next thing the inspector dug into was making sure there was a copy of a Request to Previous Employer for drug and alcohol test result information. You can’t just say that you mailed it out and the previous employer never responded to you. You have to be able to prove everything you claim. Even if you forgot to mail it, having a copy (marked “copy”) in the file seems to legitimize your claim.

The next document reviewed in the evaluation was a copy of the driver’s Road Test. This document completed by our trainer shows that the driver was given a specific test that verified his/her driving skills including railroad crossings, highway and city driving, parking, use of lights/signals and the driver demonstrates the ability to perform a complete pre-trip inspection of a vehicle complying with D.O.T. code requirements.

Next up, it was on the Pull Notice Program enrollment of each driver. If the driver’s most recent copy of their driving record has been received, it should be in the file with your initials that you read it AND with the driver’s signature. I got a little verbal ding on this one as I have never shown the records to my drivers. When they arrive, I have simply initialed them and put them in the driver’s file. The law requires that each driver have access to their driving record, review it and sign that it is accurate. I guess this is to protect the driver from mistakes being on his license or give the opportunity to report that there was a violation or accident in the past year that doesn’t show up on the report yet.

Obviously with only two hours in the day, I figured that he would skim over the driver qualification files. Maybe he would just sample a handful. As 5 p.m. was approaching, I pointed out to him that it was almost 5 p.m. He told me that he would let me know when he was getting tired. It was a simple and effective way to let me know I would be working late. I almost offered to buy us a pizza but I didn’t want him getting to comfy and figured he had to eat dinner sooner or later. It was later! The driver qualifications would continue the next day and then came an examination of hundreds and hundreds of individual trips. That’s another story for Part 4.

— Jim Luff, LCT contributing editor

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