What the DOT Won't Tell You About Compliance Audits

Passing a DOT compliance audit starts with keeping your risk profile low.

A DOT compliance audit isn’t random, and it isn’t just about paperwork, either. It’s the FMCSA’s way of evaluating whether your company has the safety management controls required to operate responsibly. 

Understanding what triggers a compliance review — and how your safety rating is determined — is the first step toward reducing audit risk and protecting your operations.

What Triggers a DOT Compliance Audit? 

DOT compliance audits (sometimes referred to as DOT compliance reviews)  can occur at any point while a company is regulated by the FMCSA. But certain events may trigger the FMCSA to review your company’s DOT operations sooner rather than later. Common  triggers include:

• Accidents: One accident can alert the FMCSA to conduct a compliance review. How much notice the FMCSA provides depends on the severity of the accident. Accidents that result in a fatality or serious injury will prompt the FMCSA to conduct a review quickly, often with little notice.

• Roadside inspections resulting in “out-of-service” violations: The more roadside inspections that occur with violations – such as mechanical, hours of service, or moving violations — the more likely the FMCSA will want to conduct a compliance review.

• Failure of a New Entrant Safety Audit (NESA): The New Entrant Safety Audit sets the tone for how regulators view your operation. Companies that struggle during this initial review often face increased monitoring.. Learn more about the New Entrant Safety Audit here.

Understanding the Outcomes of a DOT Compliance Review

Unlike the New Entrant Safety Audit, a compliance review may result in substantial financial penalties depending on the amount and severity of the violations found. In addition, the FMCSA will assign a safety rating designation following a compliance review.

• Satisfactory – This is the most desired designation. It means the FMCSA has determined the company has adequate safety management controls in place and is doing its best to comply with federal requirements.

• Unsatisfactory – This is the most dreaded designation because it means the FMCSA has found serious violations and/or non-compliance with federal requirements that may cause safety hazards. In addition to the financial penalties incurred, the company must prove corrective action by submitting a safety management plan(SMP) deemed acceptable by the FMCSA within 60 days for property carriers or 45 days for passenger/hazmat carriers. If they fail to do this, they risk being placed out of service.

• Conditional –A conditional safety rating designation means that although the FMCSA found at least one violation and/or non-compliance with federal requirements, the company does not necessarily pose an imminent safety hazard. Keep in mind that even though the company won't face an out-of-service order, it will incur financial penalties and its DOT operations may be negatively impacted due to contractors and insurance companies being reluctant to work with the carrier. To remove a conditional safety rating designation, the company must prove corrective action by submitting a safety management plan deemed acceptable by the FMCSA.

• Un-ratable — Sometimes the FMCSA conducts a “focused” compliance review that only deals with one aspect of federal requirements, and therefore a safety rating designation will not be assigned. However, violations found may result in financial penalties.

Critical DOT Violations That Can Impact Your Safety Rating

All of the following are considered critical or acute in the eyes of the FMCSA and will cause an immediate unsatisfactory or conditional safety rating designation. They can also lead to substantial fines.

These DOT violations include, but are not limited to:

• Any type of drug and alcohol testing violation (provided drug and alcohol testing is required).

• Using a driver without a valid license.

• Using a driver who has been deemed medically unqualified.

• Operating a CMV without the required level of insurance.

• Failing to maintain hours-of-service records.

• Operating a vehicle declared out-of-service during a roadside inspection before the required repairs are made.

• Operating a CMV that has not undergone an annual/periodic DOT inspection.

• Falsification of records.

The Best Way to Prepare for a DOT Compliance Audit

The most effective way to pass a DOT compliance audit isn’t scrambling when one is scheduled — it’s maintaining consistent compliance long before the review begins.

Manually managing the many different requirements, like driver qualification files, drug and alcohol testing programs, hours-of-service records, and insurance documentation, leaves room for missed deadlines and incomplete records. And during an audit, even small gaps can create larger concerns.

A robust digital compliance platform can help eliminate those gaps by centralizing documentation, automating alerts, and providing real-time visibility into your safety and compliance status.

Dash, Foley's all-in-one DOT compliance platform, is designed to support carriers across the full compliance lifecycle, from onboarding and driver file management to ongoing monitoring and audit preparation. 

By keeping critical requirements organized and up to date, Dash helps carriers stay audit-ready every day, not just when the FMCSA calls. Request a demo of Dash today and discover how easy it is to shore up your DOT compliance.