New entrant safety audit checklist

When you get a new USDOT number, FMCSA places your company in the New Entrant Safety Assurance Program. That means 18 months of monitoring under 49 CFR Part 385, Subpart D, and a safety audit during that time. FMCSA’s goal is to complete the audit within the first 12 months, though trucking groups say many carriers wait longer than that.

The audit is not a road test. It checks that you have basic safety management controls in place. If you pass, your registration becomes permanent. If you fail and don’t fix the problem in the time FMCSA allows, your registration can be revoked.

Automatic failures

FMCSA lists 16 requirements in Appendix A to Subpart D. Violating any one of them fails the audit. The list includes:

• Operating without a drug and alcohol testing program.
• Using a driver who is disqualified or does not hold a valid CDL.
• Operating without the required insurance coverage (proof of financial responsibility).

Read the full list in the appendix to the subpart, linked above, and treat each item as a must-have before your first dispatch.

What the audit looks at

1. Drug and alcohol program (49 CFR Part 382)

• A written policy, given to each driver.
• Enrollment in a random testing pool, through a consortium or a third-party administrator.
• Pre-employment drug test result and Clearinghouse query on file before a driver’s first safety-sensitive task.
• Supervisor training records.

2. Driver qualification (49 CFR Part 391)

• A complete DQ file for every driver. See the DQ file checklist.
• A valid CDL and a current medical certificate for each driver.

3. Hours of service (49 CFR Part 395)

• Records of duty status for each driver, kept for six months.

4. Vehicle maintenance (49 CFR Part 396)

• A current annual inspection on every vehicle.
• Maintenance and repair records.
• DVIRs, where required. See the DVIR guide.

5. Accident register (49 CFR 390.15)

• A register of accidents, kept for three years, even if it is blank.

6. Insurance and registration

• Proof of insurance on file with FMCSA at the required minimum.
• Your USDOT number displayed on each power unit.

A 14-day preparation plan

1. Days 1 to 2: confirm you are enrolled in a random testing pool and that every driver has a signed policy acknowledgement.
2. Days 3 to 5: run a pre-employment Clearinghouse query on every driver and file the results with their consent.
3. Days 6 to 9: build or repair every DQ file. Fill the biggest gaps first: motor vehicle record, medical certificate, application.
4. Days 10 to 11: gather annual inspection reports, repair records and DVIRs for every truck.
5. Day 12: create the accident register.
6. Days 13 to 14: check insurance filings and USDOT markings, then have someone who didn’t do the work review every file.

If you fail

You may get a corrective action notice that states what to fix and by when. Respond quickly and keep proof of every fix. Failing to correct the problems can lead to revocation of your registration.

One more thing

An audit finding about missing paperwork is usually a record-keeping problem, not a safety problem. A tracker that shows what is missing, as it becomes missing, is the cheapest protection you can buy.