The New Entrant Safety Audit: Your First 18 Months

When a carrier receives a new USDOT number for interstate operation, it enters an eighteen-month new entrant period. During that time the Federal Motor Carrier Safety Administration or a state partner conducts a safety audit, generally within the first twelve months, to confirm the carrier has the basic safety management systems in place. It is not a roadside inspection and it is not a full compliance review. It is a check that the paperwork exists and the programs are real. Fail it, and the USDOT number can be revoked. Here is how to be ready.

How the audit arrives

You receive a notice, usually by mail or email, scheduling the audit and listing the documents to have ready. Many audits are now conducted offsite: you upload the documents to a secure portal by a deadline and answer questions by phone or email. Some are still done in person at your place of business. Either way, the notice gives you a window to prepare, and a carrier that has been keeping records since day one needs that window only to organize, not to create.

What the auditor reviews

• Proof of insurance at the required minimums, with the federal filing on record.
• Driver qualification files for every driver, including the owner if the owner drives.
• The drug and alcohol testing program: pre-employment tests, random pool enrollment, Clearinghouse registration and queries, and the written policy given to drivers.
• Hours-of-service records: logs or electronic logging device data, and supporting documents.
• Vehicle maintenance: inspection reports, repair records, annual inspections.
• Accident register, even if it is empty.
• Hazardous materials compliance, if you haul anything placarded.
• The MCS-150 and operating authority, current and accurate.

The automatic failures

Most findings in an audit are marked as violations to correct. A short list of them fail the audit outright, no matter how good the rest of the file looks:

1. 01No alcohol or drug testing program at all, or using a driver who tested positive or refused a test.
2. 02Operating without the required insurance.
3. 03Using a driver without a valid CDL, or with a disqualified, suspended or revoked license.
4. 04Using a driver who is medically unqualified.
5. 05Knowingly allowing a driver to exceed hours-of-service limits, or having no hours-of-service records at all.
6. 06Operating a vehicle that has been placed out of service before repairs were made.
7. 07Failing to implement a random testing program.

After the audit

A pass means you continue through the rest of the eighteen months, and if your roadside inspection record stays acceptable, you leave the new entrant program with a permanent registration. A fail comes with a corrective action plan: you have a set number of days to document how each violation was fixed and submit it. Carriers that submit an acceptable plan continue; carriers that do not have their registration revoked. The audit report also becomes part of your record, so the violations that were found and corrected are worth keeping fixed.

Frequently asked questions

Do not wait for the letter

The carriers who pass are set up in the first month. Call (432) 257-7547 or come by 700 C Andrews Hwy in Midland and we will build the programs with you. English and Spanish.