DOT compliance, explained.

DOT compliance software for small fleets

Standfirst: "No regulation requires a carrier to buy compliance software. Hours of service is the exception — 49 CFR 395.8(a)(1)(i) requires an ELD unless the driver fits a narrow exception." FAQ: open with "Not for the record sets in this article. Hours of service is the exception: 49 CFR 395.8(a)(1)(i) requires an ELD unless an exception at 395.8(a)(1)(ii) or an exemption in 395.1 applies. For everything else, 49 CFR 390.32(b) permits electronic methods but does not require them, and 390.31 allows legible copies in place of originals." At 20 to 100 trucks the real question is whether one person can keep five separate record sets current by hand, each running on its own clock.

What goes in a driver qualification file?

A driver qualification file must hold the eight items listed in 49 CFR 391.51(b): the employment application, the pre-employment motor vehicle record, the road test certificate or an accepted equivalent, the annual MVR, a note on the annual review of the driving record, the medical examiner's certificate, any FMCSA medical variance, and a National Registry verification note for non-CDL drivers. Keep the file for as long as the driver is employed and for three years after.

How CSA scores work, and what moves them

A CSA score is a percentile, not a grade. FMCSA's Safety Measurement System turns your roadside inspections, violations and crashes from the past 24 months into a measure in each of seven BASICs, then ranks you against carriers with a similar number of safety events on a 0-to-100 scale where higher is worse.

How do you challenge an inspection or violation with DataQs?

You file a Request for Data Review (RDR) in FMCSA's DataQs system against the specific inspection report, violation or crash record. A state agency adjudicates most requests, not FMCSA, and the burden of proof rests entirely with you.

What does the FMCSA Drug and Alcohol Clearinghouse require?

"The Clearinghouse requires every employer of CDL and CLP drivers subject to Part 382 testing to register", run a full query before a driver performs a safety-sensitive function, query at least once a year for every current driver, and report violations by the close of the third business day. "A driver whose record shows an unresolved violation is prohibited from safety-sensitive functions until the driver completes the SAP evaluation, referral and education or treatment process and passes a return-to-duty test." In the "Prohibited status" section, add: "A driver who has completed the SAP process and a negative return-to-duty test but not the whole follow-up testing plan may return, provided the employer takes on responsibility for managing the remaining follow-up tests (382.701(d)(2))."