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Are you DOT Compliant?
Did you know...
One of the most problematic areas of DOT compliance, next to hours of service and drug and alcohol testing, are driver applications (Part 391.21). Driver applications may be audited by state and federal agencies and surveyed by insurance companies. Missing information, missing pages, or blank lines can lead to DOT write-ups, fines, and a request (more like an order) from the DOT to fix the mess. Here are some common DOT “application for employment” error areas to avoid.
Driver Application— Common Error Checklist
• Has the applicant listed his/her address for at least the last three years?
• Does it show an out-of-state address? If yes— then this means that the carrier needs to get the out-of-state Motor Vehicle Record (MVR), for each state listed.
• Has the applicant listed at least 3 years of past employment, if new to driving as a job, or if the driver has obtained a recent CDL?
• Has the applicant listed at least 10 years of employment if he or she had a CDL over 3 years ago?
Has the applicant explained any gaps in employment in excess of one month?
• Has the applicant answered YES or NO to each question for every job:
» Was this job subject to Federal Motor Carrier Safety Regulations?
» Were you subject to drug and alcohol testing under DOT rules?
Note: These questions apply to both interstate and intrastate drivers.
(It may help to ask the applicant if they even understand and know what these questions mean. In many instances the applicant does not know if they were subject to DOT regulations in their previous job(s) and will check off they were, when in reality were not or were DOT exempt.)
• Has the applicant listed a date of birth?
• Has the applicant answered BOTH of the following questions:
» Have you ever been denied a license, permit or privilege to operate a motor vehicle?
» Has any license, permit or privilege ever been suspended or revoked?
If the answer to either of the above questions is yes, has the applicant given details?
The applicant needs to fully answer each section:
• DRIVING EXPERIENCE
• ACCIDENT RECORD
• TRAFFIC VIOLATION RECORD
• Are there any “blank” answers?. If an answer is “none,” then the applicant must write “NONE.” (Not leave it blank or NA)
Has the applicant SIGNED and DATED the application?
Was the application completed by the applicant? The applicant, not a friend or family member, must fill out the application— in his own handwriting.
Are the Organization’s/Company’s Name and Address on the application??
The DOT driver application is an important document that forms the basis of the background investigation of the driver. Check your driver applications for these common errors. Don’t accept improperly filled out applications.
Applicants should be aware that improperly filled out applications potentially can lead to federal charges.

Dot information of the day-
The 2020 UCR registration is still not open, they are however giving you a 3 month grace period.

Carriers that transport passengers or cargo across state lines are generally required to obtain a USDOT number. This is processed through the FMCSA's Unified Registration System (URS). Once a carrier has received their DOT number, they are also required to update their registration bi-annually and whenever there are any changes to their registration information. In addition, 32 states require intrastate carriers to apply for and obtain a DOT number.

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DOT tip of the day:

What Does DOT Compliance Entail?

DOT compliance spans a lengthy set of rules and regulations, and companies are expected to know them all. In general, DOT compliance can be broken down into two categories: fleet compliance and driver compliance.

Fleet Compliance
Fleet compliance applies to every vehicle in your fleet that is registered with the DOT. It’s helpful to keep a compliance checklist on hand that makes it easier to review requirements at a glance and ensure nothing falls through the cracks.
A few general guidelines you might consider:
Keep a current copy of FMCSA rules at all times
Inspect all vehicles before and after each trip and document your findings. Start a routine vehicle maintenance program and document all activities. Make sure every vehicle is marked with its official DOT registration number. Keep a detailed record of any incidents that occur on the road

Driver Compliance
Driver compliance applies to every driver of DOT-registered vehicles. Just like with fleet compliance, it can be useful to keep a checklist for driver compliance requirements to ensure you’re hitting all points. Consider the following guidelines when pursuing driver compliance:
Make sure each driver has a copy of FMCSA rules
Collect a signed agreement from each driver that they have read and understood their responsibilities pertaining to FMCSA rules. Keep a record of driver qualifications and safety history. Record all hours of service (HOS) for each driver
Conduct pre-employment drug testing for each driver and retain documentation (if possible, include any record of previous drug or alcohol abuse). Conduct random drug testing of all drivers on a regular basis and record all results
Put all trainers and supervisors through drug and alcohol testing as per DOT regulations

Each of these checklists cover the basics of DOT compliance, but they shouldn’t be considered comprehensive. Companies should consider creating their own checklists that are more detailed and relevant to their operations.

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