Mock DOT and OSHA Audits: Helping Carriers Stay in the Clear

By Scott Fouts

Motor carriers may dread compliance audits from Department of Transportation (DOT) and the Occupational Safety and Health Administration (OSHA), and for good reason: These audits comprise difficult processes, and when failing an audit, getting it overturned to reduce negative consequences can be just as hard.

The rule of the road is simple: The higher a compliance safety and accountability (CSA) score, the more likely a carrier will get a visit from a DOT compliance officer. And since the onset of the pandemic, OSHA audits have increased to enforce COVID-19 compliance.

But these audits shouldn’t blindside motor carriers. Instead, it’s incumbent upon the carrier owners and operators to be prepared when audits take place — even with little or no advance notice.

A “mock” audit identifies areas where safety and health hazards or potential violations exist within your operations, helping provide what to expect and which records you will need. A mock audit prepares your operations to ensure critical programs and procedures are in place long before any actual audit.

The ingredients of an annual DOT or OSHA mock audit

The benefits of having good Compliance, Safety, Accountability (CSA) scores include lower annual insurance premiums and easier driver recruitment efforts based on your reputation. It can mean fewer DOT audits and roadside inspections as well.

A mock audit will give a detailed CSA analysis and help make sense of CSA inspection data and ratings. If you are a motor carrier with a conditional rating, a mock audit can help navigate any deficiencies and also support the official appeals process.

To prepare for mock audit, these are other steps you can take in advance to ensure your operations are ready:

• Outline policies and procedures. Printed guidelines will emphasize safety, keep employees informed and minimize claims. A review and update of policies should be ongoing to deal with emerging risks that will affect business operations. Maintaining detailed records consistently year round will help any OSHA audit progress smoothly. A system to keep your business compliant at all times is key to passing a DOT audit.
• Ensure training and protocols are provided to employees. Both DOT and OSHA have specific training requirements for drivers and employees to address specific regulatory requirements. Training shows a commitment to safety, giving employers a workplace that follows safe practices. It is imperative that all employees go through required training that includes executives, managers and frontline employees.
• Develop an incident response plan. An incident response plan gives clear direction in the event of an incident. If there’s an accident on a roadway, drivers, office employees and dispatchers should know what to do without having ask. Each employee will have his or her own job in the aftermath of an incident. Commit the plan to paper so everyone knows the proper response in each scenario and provide training to those affected employees. Response plans should also be addressed with facility employees to ensure they are aware of the protocols in the event of an emergency.
• Continuously evaluate your safety programs. In today’s environment, regulatory requirements are changing to ensure the health and safety of employees. Whether it is OSHA, DOT, the Equal Employment Opportunity Commission (EEOC) or the U.S. Department of Labor (DOL), your company’s operations will be dependent on staying current with regulatory guidelines and making sure your employees are aware of company operational changes.
• Mock audits help prevent negative impacts to your safety ratings. While it is possible to overturn a deficient rating (with proof of risk management as outlined above), it’s best to prevent a poor rating in the first place through providing a mock audit. A mock audit will ultimately relieve your business the hassle, headache, and increased premiums that come with a failed audit. The proper training, policies and procedures — which a mock audit will you effectively identify risk — and ultimately, help you protect your people, property, and profitability.

Contact HUB Risk Services expert for more information on conducting a mock DOT or OSHA audit & learn more about DOT Audits with this webinar from HUB!