August 2026
- David Humphrey
- Aug 3, 2021
- 6 min read

DOT Safety Compliance Audits
Failure to comply with DOT regulations identified during a safety compliance audit is considered an acute violation, necessitating that the carrier provide a corrective action plan to address the issues. These violations can also lead to fines for the carrier, alterations in safety ratings, and potential shutdown of the carrier.
Acute Violations (requiring immediate corrective action):
Operating without a valid Commercial Driver's License (CDL).
Failing to implement and/or randomly conduct drug/alcohol testing.
Using a driver with a suspended or revoked CDL.
Using a driver who has tested positive for drugs.
DOT annual inspection reports must include checks of the Antilock Brake System and the Rear Impact Guard. The auditors are looking for these items on the reports.
Critical Violations:
Speeding.
Falsifying Hours of Service (HOS) records.
Not using an Electronic Logging Device (ELD) when required.
Missing driver qualification files.
Using a driver before receiving a negative pre-employment drug test result.
Roadside Violations - Drivers:
Speeding (6-10 mph over the limit).
Failing to obey traffic control devices.
Falsifying HOS records.
Failing to wear a seat belt.
Operating a Commercial Motor Vehicle (CMV) without a CDL.
Roadside Violations - Vehicles:
Vehicle roadside violations frequently involve issues with:
The required lamps are inoperable.
Operating without proof of periodic inspection.
The brakes are out of adjustment.
Problems with fire extinguishers.
Roadside OOS Violations - Vehicles:
Vehicles can be placed Out-of-Service at the roadside for:
Flat tires or audible air leaks.
Defective brakes.
Inoperative turn signals.
Lack of proper breakaway or emergency braking.
Inoperable required lamps.
These lists highlight some of the most common violations, but they are not exhaustive. Compliance with all DOT regulations, including proper vehicle maintenance, adherence to HOS rules, and accurate record-keeping, is essential for truckers and companies to avoid violations and maintain a good safety rating.
The mechanic performing the inspection is required to fill out all of the Annual Inspection Forms. Ensure that the company and vehicle details are accurate.
During all safety and compliance audits, the auditor examines Drug and Alcohol Clearinghouse compliance. This includes the pre-employment full query, driver consent form, the annual limited query, and, if necessary, the yearly full query for each driver.
The Crash Preventability Determination Program (CPDP) is where we can contest recordable accidents that occurred on or after August 1, 2019. A Request for Data Review (RDR) with the required police accident report and other supporting documents, photos, or videos must be submitted to prove the non-preventable accident. If the request is approved, the accident will be moved to "Reviewed - Not Preventable Crash Activity" and will not count in the CSA scores.
The following crash types are eligible for participation in the program:
Struck in the Rear type of crash when the CMV was struck:
in the rear; or
on the side at the rear.
Wrong Direction or Illegal Turns type of crash when the CMV was struck:
by a motorist driving in the wrong direction; or
by another motorist in a crash when a driver was operating in the wrong direction, or by a vehicle that was making a U-turn or illegal turn.
Parked or Legally Stopped type of crash when the CMV was struck:
while legally stopped at a traffic control device (e.g., stop sign, red light, or yield); or while parked, including while the vehicle was unattended.
Failure of the other vehicle to stop type of crash when the CMV was struck:
by a vehicle that did not stop or slow in traffic; or
by a vehicle that failed to stop at a traffic control device.
Under the Influence type of crash when the CMV was struck:
by an individual under the influence (or related violation, such as operating while intoxicated), according to the legal standard of the jurisdiction where the crash occurred; or
by another motorist in a crash where an individual was under the influence (or related violation such as operating while intoxicated), according to the legal standard of the jurisdiction where the crash occurred.
Medical Issues, Falling Asleep, or Distracted Driving type of crash when the CMV was struck:
by a driver who experienced a medical issue that contributed to the crash; or
by a driver who admitted falling asleep or admitted distracted driving (e.g., cell phone, GPS, passengers, or other).
Cargo/Equipment/Debris or Infrastructure Failure type of crash when the CMV:
was struck by cargo, equipment, or debris (e.g., fallen rock, fallen trees, unidentifiable items in the road); or the crash was a result of an infrastructure failure.
Animal Strike is a type of crash when the CMV:
struck an animal
Suicide type of crash when the CMV:
struck an individual committing or attempting to commit suicide
Rare or Unusual type of crash when the CMV:
Was involved in a crash type that seldom occurs and does not meet another eligible crash type (e.g., being struck by an airplane or skydiver or being struck by a deceased driver).
Drug and Alcohol Testing
The return-to-duty (RTD) process allows Commercial Driver's License (CDL) drivers to regain eligibility to operate commercial motor vehicles (CMVs) after violating DOT drug and alcohol regulations. This process, mandated by 49 CFR Part 40, Subpart O, requires drivers to undergo evaluation, education/treatment, and testing by a DOT-qualified Substance Abuse Professional (SAP). Once the RTD process is completed, the driver's status in the FMCSA Drug and Alcohol Clearinghouse will be updated to "not prohibited".
Key Steps in the Return-to-Duty Process:
1. SAP Evaluation:
The driver must be evaluated by a DOT-qualified Substance Abuse Professional (SAP).
2. Treatment and Education:
Based on the SAP's evaluation, the driver will undergo a treatment and education program.
3. Second SAP Evaluation:
The SAP will conduct a second evaluation to determine if the driver has successfully completed the prescribed program.
4. Return-to-Duty Test:
The driver must pass a return-to-duty drug and/or alcohol test administered by the employer or a C/TPA.
5. Clearinghouse Update:
The employer or C/TPA reports the negative return-to-duty test result to the FMCSA Drug and Alcohol Clearinghouse.
6. Follow-up Testing:
The SAP will prescribe a follow-up testing plan, typically involving unannounced and observed tests for a period of 1 to 5 years.
Important Considerations:
Employer Responsibilities:
Employers are responsible for providing a list of DOT-qualified SAPs, ensuring the driver completes the RTD process, and reporting the negative return-to-duty test result in the Clearinghouse, according to the Drug & Alcohol Clearinghouse.
SAP Responsibilities:
The SAP evaluates the driver, prescribes the treatment and education plan, and determines when the driver is eligible for the return-to-duty test.
C/TPA Role:
If the driver is an owner-operator, their designated consortium/third-party administrator (C/TPA) will handle certain aspects of the process, including administering the return-to-duty test and reporting to the Clearinghouse.
Clearinghouse Updates:
The Clearinghouse is updated throughout the process, reflecting the driver's status as prohibited, then not prohibited after successful completion of the RTD process.
Follow-up Testing:
The SAP's follow-up testing plan is crucial for ongoing monitoring and ensuring the driver maintains compliance with drug and alcohol regulations.
IRS - 2290
Internal Revenue Service Heavy Vehicle Use Tax (IRS Form 2290) must be filed by the end of August. The taxable year runs from July 1st to June 30th. Any vehicle that has a GVW of 55,000 pounds or more is subject to the tax. The maximum tax remains at $550.00. The Schedule I paid receipt listing vehicle serial numbers is required to purchase license plates. The tax is prorated monthly for vehicles placed in service after July. When a vehicle is sold, the new owner must pay the tax under their name. The carrier selling the vehicle may apply for a credit for the unused part of the tax and apply it to a new vehicle or file for a refund.
Carriers operating vehicles across international borders should have a copy of the stamped Schedule I receipt in the cab of the vehicle being used in the United States. Customs officials will be checking vehicles that cross the border from Canada and Mexico to ensure compliance.
The return must be filed electronically. Any carrier that would like us to file the tax return must make a check payable to the U.S. Department of the Treasury for the amount of the tax due, and we must receive it by August 20.
UNIFORM CARRIER REGISTRATION SYSTEM - UCR
Every company with an interstate USDOT number is required to file under the UCR. Many states now require even intrastate companies and farmers that operate vehicles over 10,000 GVW or combination vehicles over 10,000 pounds to obtain a DOT number, even if they do not cross a state line. Each state can determine if it will require solely intrastate private and for-hire carriers to register under the UCR. States have begun enforcement of the UCR filings. Each state has established its fines for non-filing.
Several UCR filings did not reach the FMCSA website, which is the official location for enforcement. We have verified all of the UCR filings we completed and can verify any others when requested.
UCR fees for 2027 will be increasing by about 20 percent.
During DOT safety audits, auditors are looking at the operation of vehicles before the payment of the UCR fee for the new year. Make sure that the UCR fee is paid before the end of each year to avoid any fines.
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