Safety Audit Checklist

In an effort to ensure safety & regulatory compliance for new operations, the FMCSA will conduct a safety audit on all applicable motor carriers subject to the New Entrant Safety Program. Listed below is a breakdown of the points of information that may be reviewed at the time of an audit. This checklist was created by us at MCSA Compliance Consultants by compiling the requirements listed through various sources maintained by the FMCSA. Depending on your specific operation, more documentation may be required by your assigned officer at the time of an audit.

Many carriers do not make it past their first year in business, which is often due to receiving an unsatisfactory or conditional rating on their audit, affecting their ability to operate. We have assisted thousands of carriers through their safety audit to ensure continued operations. Should you have any questions or concerns about the items listed below, or want to discuss what you can do to be better prepared for any audits or inspections, please select an option below.

Driver Qualification

The FMCSA will look for documents related to your drivers to show they are authorized to operate the appropriate classes of vehicles and ensure they are deemed as a qualified driver.

Driver Qualification File

The Driver Qualification File is a document compiling all information necessary to meet the requirements of 49 CFR 391. During the Safety Audit, the file can be provided to an officer as it meets the record-keeping requirements as required by FMCSA. This file must be kept current and accurate and retained on-file for each applicable driver for up to 3 years after employment ends. The individual items listed below are key components of the Driver Qualification File.

Driver’s License

A copy of a valid driver’s license that meets the requirement of the vehicle they operate. Appropriate licenses are either an operator’s license issued by one State or jurisdiction, a commercial driver’s license (CDL) with the proper endorsements as required, a Canadian license, or a Licencias Federales de Conductor, issued by the Mexican Government.

Driver’s Motor Vehicle Record (MVR)

The driver’s motor vehicle record, commonly known as the “driving record”, must be pulled on an annual basis, reviewed, and kept with the driver’s other documents, usually in the Driver Qualification File. The MVR must be kept for 3 years after employment ends. The carrier must review the motor vehicle records of the drivers it employs to ensure the driver is not disqualified from operating a CMV.

Medical Certificate

All drivers are expected to be physically and mentally fit to operate a commercial motor vehicle. Drivers must be examined by a Certified Medical Examiner. The medical examiner will complete a Medical Examination Report (Long Form). Upon passing the physical examination, the driver will be given a copy of their Medical Certificate. The carrier must review the Medical Certificate and verify the Medical Examiner is registered with the National Registry of Certified Medical Examiners.

Application for Employment

The driver’s application for employment must be completed in full to show the driver’s basic information, driving history, accident/ticket history, and previous employment.

Investigation of Previous Employment

Upon reviewing the driver’s application, any previous employer which the driver held employment and operated a commercial motor vehicle for within the last three years must be contacted to complete an interview regarding the driver’s safety performance history.

Road Test & Certification

All drivers must complete a Road Test or show proof a Commercial Driver’s License or equivalent license. The Road Test must be completed to show an understanding and ability of operating the vehicle. The examiner will be anyone who holds an equal or greater class of license. Upon completion of the Road Test, the examiner will complete the appropriate road test form, sign it, and provide it to the carrier. If the driver currently holds a CDL, they may use the Road Test that they obtained when completing their CDL test.

Drug and Alcohol Testing

Motor carriers whose drivers are required to have CDLs to operate a CMV must have an appropriate Drug and Alcohol testing program in place, where once enrolled, drivers will be subject to random testing in order to maintain eligibility to operate.

Drug and Alcohol Testing Program

Carriers with drivers subject 49 CFR 382 must comply with this regulation by enrolling into a drug and alcohol testing program. Through this program, drivers will complete a pre-employment test prior to operations, be subject to random testing according to consortium requirements, and be monitored for any signs of substance abuse, which may result in reasonable suspicion testing. Proof of enrollment, testing policies, and test results will be provided to an officer during the time of an audit. The individual items listed below are key components of an acceptable testing program.

Proof of Enrollment into a Consortium

Otherwise known as a Consortium Agreement. This is an agreement between the company and the consortium which details the responsibilities of each party and includes the enrollment date and expiration date of the program. This also provides proof that the carrier has an active random testing program in place and that the requirements for the consortium are being met.

Workplace Policy

This is a policy given to the drivers to ensure they are aware of their enrollment into a Drug and Alcohol Testing program and provides the company with the proper permissions to send a driver in for testing. It also outlines the types of tests required to be administrated and the penalties should the driver fail or refuse a test. This must be signed and kept in the employee file with other testing-related documents.

Negative Pre-Employment Test and Chain of Custody Form

Before the driver is authorized to operate the vehicle, they must complete a pre-employment test and receive a negative result. The chain of custody form that was provided at the time of testing and any results should be kept on file at all times.

Supervisor Training Certificate

Should the carrier have any employed drivers who are enrolled into a testing program, the carrier is required to have a supervisor complete a certified Supervisor Training Course to train them to recognize signs and symptoms of substance abuse in employed drivers. Any certifications for these supervisors should be kept on file and readily available.

Additional Requirements

Listed below are additional documents, certificates, logs, and lists that must be maintained at all times.

Driver’s Records of Duty (ROD)

Every carrier must keep record of his/her duty status for each 24-hour period. All Hours-of-Service rules must be met and the Records of Duty will show proof of the safe driving. Supporting documents should also be included such as: toll receipts, fuel receipts, bills of lading, or trip reports. The record of the last 6 months must be available at all times.

Notes:

  • The last 6 months of RODs can be provided – but RODs older than this should also be kept
  • Policies should be in place regarding inspection of RODS to ensure driver compliance
  • Disciplinary policies should be in place for non-compliance with Hours-of-Service rules


Types of Record of Duty:

  • Electronic Logging Device (ELD)
  • Log Books
  • Time Records


Ensure that you are aware of the Record of Duty device that is appropriate for your company. Not utilizing the proper Record of Duty device can lead to severe penalties.

Proof of Insurance

All carriers must provide proof of adequate financial assurance that can potentially cover costs associated with bodily injury, property damage, and environmental restoration due to discharge of toxic or environmentally harmful materials caused by their company. If you are unsure of which document to provide, contact your insurance provider and ask them for the proof of financial assurance, they will provide you with the proper documentation.

Examples of Insurance documents:

  • MCS-90
  • BMC-91
  • MBC-91x

Driver List

The driver list should provide information for all of the drivers that have worked for the company in the last 365 days. For an example driver list, you can download one by clicking here.

The Driver List should include:

  • Driver’s first and last name
  • Date of birth
  • Date of hire
  • Driver’s license number & state
  • Termination date

Vehicle List

You are required to maintain a list of all vehicles owned, operated, or leased by the company. For an example vehicle list, you can download one by clicking here.

The Vehicle List must include at minimum:

  • Unit number
  • Vehicle identification number (VIN)
  • Plate number
  • Plate State

Annual Inspection Program

The vehicle must receive an annual inspection each year. The vehicle is not to be operated unless the vehicle has passed an inspection at least once during the preceding 12 months and documentation of this inspection is kept in the vehicle. Additionally, you need to maintain vehicle maintenance records, and 90 days of post-trip inspection reports, including supporting documents of any maintenance that was required.

This inspection form must include:

  • Date of inspection
  • Name of carrier
  • Primary business address
  • Certification that the vehicle or vehicle combination passed an inspection in accordance with 49 CFR 396.17

Hazardous Materials

Motor carriers transporting hazardous materials must have appropriate documentation. Shippers of hazardous materials must provide carriers with shipping papers and emergency response information which provide useful information in the case of an incident. A shipping paper provides a record of what is being transported and provides first responders with necessary information for emergency response. HM shipping papers must be within the driver’s reach with the seat belt on and visible to first responders entering the vehicle. Motor carriers must retain HM shipping papers for one year after acceptance of the shipment, or three years for hazardous wastes.

Information on the shipping papers must include:

  • The identification number, identified in the Hazardous Materials Table
  • The proper shipping name, identified in the Hazardous Materials Table
  • The hazard class
  • The packing group, identified in Roman numerals, when required
  • The total quantity of hazardous materials
  • The number and type of packages holding the hazardous contents
  • Any additional description requirements per 49 CFR 172.203

Automatic Failure Violations

During the audit process, if you are found to have any of the violations listed below, it is considered an automatic failure. Be keenly aware of any deficiencies you may have in the following topics to ensure you are not at risk of an automatic failure.

Driver Violations

  • Using a driver without a valid license for their operation level
  • Using a disqualified driver
  • Using a driver with a revoked, suspended, or cancelled driver’s license
  • Using a medically unqualified driver

Alcohol and Drug Violations

  • No drug and alcohol testing program in place – including no random testing
  • Using a driver who refused a required alcohol or drug test
  • Using a driver the company knows had a blood alcohol content of 0.04 or greater
  • Using a driver who failed to complete required follow-up procedures after testing positive and being sent for a substance abuse program

Operations Violations

  • Operating a motor vehicle without having the required level of valid insurance in place
  • Failing to require drivers to create and maintain hours-of-service records

Repairs and Inspection Violations

  • Operating a vehicle declared Out-of-Service for safety deficiencies before repairs are made
  • Not performing OOS repairs reported in driver/vehicle inspection reports
  • Operating a CMV that has not been periodically inspected

Failure of Safety Audit

If the audit is failed, the motor carrier must satisfactorily implement a Corrective Action Plan (CAP) to address violations, correct safety management practices, and implement procedures for avoiding the violations in the future. Failure to submit a satisfactory CAP by the deadline will result in your USDOT number being placed Out of Service, immediately halting all operations until the process is complete.

If you have already failed your audit and need immediate assistance with creating a CAP, we can help.