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October 29, 2018

Dot Compliance Tips: Record Keeping for Transport Companies

The Department of Transportation (DOT) sets strict guidelines for the way that transport companies operate. Among the requirements is accurate record keeping. Fleet owners and drivers are expected to comply with the rules and regulations imposed by the DOT, or face stiff fines and penalties. Rules and regulations are continually updated and revised and it's imperative that fleet owners keep up with the changes to ensure compliance.

Electronic Logging Devices

ELDs are meant to create safer conditions for drivers and to prevent fatigue related accidents and issues. When connected to the vehicle's engine, it automatically records information to make it easier and faster to track, manage and share records and helps drivers track their limits. According to the FMCSA, as of December 18, 2017, all most motor carriers and drivers are required to use an ELD or an automatic onboard recording device (AOBRD). By December 16, 2019, all motor carriers and drivers covered under the rule must implement the use ELDs only.

 

Data that is automatically recorded with these devices includes:

  • Date, time, and location
  • Number of engine hours
  • Number of miles the vehicle has traveled
  • The driver's identification
  • Vehicle information
  • Motor carrier details

Dispatch and Trip Records

In addition to the information collected and recorded by the ELD within each fleet vehicle, it is the responsibility of the transport company to maintain dispatch and trip records. These are considered supporting documents and must be retained by the carrier for no less than 6 months. The information contained in these records must coincide with the ELD data.

Bills of Lading and Manifests

All freight that is transported by a carrier must be accompanied by a bill of lading (BOL) this acts as a receipt for the freight services as well as providing details about the contents of the shipment. It is a legally binding contract that provides the driver and carrier with the details necessary to process the shipment and invoice the shipper properly. A manifest is also required which acts as a type of tally-sheet giving a detailed summary of all the bills of lading that are included in a specific trip. Information that is required includes:

  • The full names and addresses of the shipper and receiver.
  • Date of pickup.
  • Description and packaging details of items being shipped.  
  • NMFC freight class
  • Purchase orders or special reference numbers.
  • Special instructions.
  • DOT hazardous material designation, where applicable.

Fleet Management Communication Records

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Fleet Management Software (FMS) is often used by motor carriers to help simplify and streamline the tasks associated with fleet vehicle management. In addition to managing vehicles, it also provides driver management, and incident tracking and route optimization. It is a way for transportation companies to ensure their fleet vehicles and drivers remain compliant. The FMCSA requires transport companies to maintain records of every communication transmitted through a fleet management system.

Driver Expense Receipts

Carriers must maintain records of all costs that drivers incur during their on-duty/not driving periods. The driver is required to collect all receipts and turn them into the carrier who keeps them for a minimum of 6 months. The types of expenses generally covered by this rule include:

  • Lodging
  • Meals
  • Fuel
  • Any other related expenses

Payroll Records and Settlement Sheets

As an employer, it's vital that a transportation company, or carrier, maintains accurate records of all payments made to drivers. This includes regular payroll payments, settlement sheets, and any other related documentation. Not only does this documentation prove that the company has made the appropriate payments, it also provides information driver's and the company will need when tax time rolls around.

Driver Qualification & Performance Records

According to 49 CFR Part 391, a driver who operates a vehicle that weighs 10,001 pounds or more, transports 8 passengers including the driver, or who hauls any hazardous materials requiring a placard must have a file containing their qualification documents. These records show that the driver is healthy, safe, and qualified to operate a commercial vehicle. It applies to both employees and owner-operators who are considered both employers and employees. Documents that must be maintained include:

  • A DOT Compliant Employment Application.
  • Medical Certificate.
  • Commercial Driver's Licence or Road Test Certification.
  • Safety Performance Evaluation.
  • Motor Vehicle Driving Record and Any Violations Incurred
  • Annual Motor Vehicle Driving Record Review

Drug and Alcohol Test Records

The safety of drivers is imperative and any drug and alcohol use while on duty is strictly prohibited. Therefore, it's vital that drivers are periodically tested for these substances. Records of all drug and alcohol tests performed on drivers must be maintained in a secure location under lock and key away from regular personnel files. Access to these files must be strictly controlled and limited.

The Following Records Must Be Maintained for a Minimum of Five Years:

  • Alcohol tests that result in a BAC of 0.02 or greater
  • Positive controlled substances tests
  • Documentation of a driver refusing testing.
  • Substance Abuse Professional reports

The Following Records Must be Kept for at Least Two Years:

  • Random Test Subject Selections
  • Documentation of Reasonable Suspicion

These Records Must be Maintained for a Minimum of One Year:

  • Drug Test Results that are Negative or Canceled
  • Alcohol Tests Showing a BAC below 0.02

Records of Vehicle Maintenance

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Motor carriers are obligated to maintain vehicle maintenance records for any vehicle under their direct control for 30 days or more. This ensures that the maintenance and repair schedule is properly maintained and also provides authorities with vital information in case of an accident, or other incident. Records have to be kept in the location the vehicle is garaged for one year, and for six months after it has left the carrier's control. The following information must be included in these records:

  • Identifying Vehicle Information including the company's name, make of the vehicle, serial number, tire size, etc.
  • Inspection Schedule that includes the type of inspection and date it was completed.
  • Repair and Maintenance information the type of repairs needed, actions taken, and the date of repair.

Conclusion

It's not an easy feat to stay compliant with all of the DOT rules and regulations, especially when things are continually changing. Maintaining good records is imperative, however, and failing to comply with any aspect of the record keeping rules is not an option. Contact us at Whip Around for more information about DOT compliance, record keeping, vehicle inspection reports, or any other related topic. We'll be happy to answer any questions you have.

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