In this episode of the CSA Basics podcast, host Samuel Tucker, CPCU, CRM (CEO of Carrier Risk Solutions) explains the five primary factors that can prompt a Department of Transportation (DOT) compliance review or safety audit of a trucking carrier. He begins by debunking common myths and then details each trigger: (1) a fatality crash – any crash resulting in a death, regardless of fault, automatically raises DOT concern; (2) being classified as a high‑risk carrier – defined as having two or more CSA BASIC scores above the 90 % threshold for more than two consecutive months; (3) a high crash rate – measured as more than 1.5 crashes per million vehicle‑miles traveled or a high CSA crash BASIC score, with emphasis on keeping MCS‑150 census data accurate to calculate the rate; (4) a driver‑related complaint – any formal complaint filed by a current or former driver can trigger an audit, underscoring the need for good driver relations and proper dispatch practices; (5) a history of red‑flag violations – a list of twelve serious infractions (drug/alcohol, fatigue, operating out‑of‑service vehicles, and driver‑qualification issues such as invalid or disqualified CDL or medical certificate problems). Tucker highlights the importance of timely driver medical‑certificate self‑certification, 15‑day MVR verification, and overall compliance monitoring, mentioning his My Safety Manager service as a resource. The episode closes with a call to action to subscribe, visit CSA resources, and reach out with questions.
Welcome to CSA Basics.
CSA Basics.
The podcast where we talk about all things related to safety, compliance, and insurance for the trucking industry. We're here to help you save money, save time, and save lives. Now, here's your host, CEO of Carrier Risk Solutions, Sam Tucker.
All right, welcome back to the show. Today we're gonna be talking about what triggers a DOT audit. So most trucking companies out there are fearful, or rightfully so, at least have a healthy respect and fear of a DOT audit or compliance review, whatever you want to call it. And there's a lot of myths that circulate out there about what causes a DOT audit and what, you know, what doesn't cause a DOT audit. So I want to go through the 5 primary causes or triggers for a DOT audit and kind of walk through each of those for you and help you understand what your exposure to a DOT audit would be. So the first one is a fatality crash. So if your driver is is involved in a fatal or crash that has a fatality, whether or not they were the fatality, unfortunately, or whether or not somebody else passed away at the scene, regardless of fault, it could trigger a DOT audit for your company. So it's always just one of the ways that the FMCSA tries to protect the general public. And if they see such a thing with a fatality accident, that's one thing that automatically raises a number of concerns with them. So having a fatality crash is the number one, or is one of the things that could potentially trigger a DOT audit. All right, the second one, and absolutely most common one, is being what's considered a high-risk carrier. So what's a high-risk carrier? So if you have 2 or more CSA BASIC scores that are above the 90% threshold for more than 2 months in a row, Then you're considered in the FMCSA's eyes a high-risk carrier. So what that means is every month or every quarter when the FMCSA field offices are going through their lists of carriers who are potentially up for investigation that quarter or that month, they go through and they rank everybody, whoever is ending up on the list. And as a high-risk carrier, that's the number one way that you could be targeted for a CSA, or not CSA, but a DOT investigation.
Okay.
compliance review or safety audit. So again, it's high-risk carrier if you have 2 or more CSA Basic scores above the 90% threshold for longer than 2 months in a row. The third one, and this has become a lot more common over the last year especially, is having a high crash rate. And what we mean by high crash rate is if you have more than 1.5 crashes per million miles traveled, then you have what's considered to be a high crash rate. Or also, if you have a high CSA crash basic score too, that could also put you in that high crash category too. So as time has gone over the last year or so, the DOT has really started cracking down or trying to crack down on carriers who have crashes or high crash rates or high crash alerts. And with that, they're getting a lot of pushback from the Biden administration and others about the increase in road fatalities. So we're up about 10% year over year with, with the situation with more road fatalities. So the FMCSA has been pushed on by the Department of Transportation saying, well, what are we doing as an enforcement agency to prevent these crashes from happening and these deaths from happening on the roadways? And so that's one thing that a lot of carriers or a lot of carriers are being targeted with those high crash rates. So one primary way you can help fix that is making sure that your MCS-150 data is updated. So your MCS-150 is essentially your census data that the FMCSA has on you. So if they have a big book with your information in it, the FMCSA MCS-150 document is what records all your census information. So things like your location, the number of drivers you have, the number of trucks you have, and more importantly for our concern today is How many vehicle miles traveled your fleet has over the last 12 months. So having an accurate vehicle miles traveled number in your MCS-150 data is critical here because that number is absolutely a large part of determining your crash rate. So make sure you have that updated. The 4th one is having a complaint filed against you. So if a current driver or a former driver Takes issue with something that you or a dispatcher or one of your operations folks or somebody at your carrier did, then that's one thing that could also trigger a potential alert or a potential DOT audit as well. So you want to make sure that you try to keep drivers happy. Don't have your dispatchers do anything questionable, I guess is a good way to put it, with how they're dispatching the drivers and how, how they're addressing hours of service and things like that. So having a complaint filed against you It's another really good way to have a DOT audit in your very near future. The 5th one is having a history of red flag violations. Now, a red flag violation, you can Google it and see the list. There's really 12 different violations on this list, and they basically break down into one of 3 categories. Either it's a drug and alcohol violation found on the roadside, so a driver is using or in possession of drugs. Or they're using or under the influence of alcohol. So those are 2 of the 12. The other 2 are fatigue driving. If you're driving after being declared out of service for hours of service, then that's a red flag violation. Or also if you're caught operating an out-of-service vehicle. So if you have a vehicle that's been declared out of service and it moves before you have a chance to repair the defect that was determined at the roadside, that's also a red flag violation. So those, That's 4 of the 12 right there. And the rest of them are really driver fitness related to mostly driver CDL status, driving a commercial motor vehicle while disqualified, operating without a valid CDL, operating with more than one driver's license, or having an improper CDL group, having a generally unqualified driver, or driver, you know, being disqualified from operating a CMV. And more likely, and this is, one that's come up, especially since COVID hit in 2020 and over the last few years, driving a CMV or commercial motor vehicle while disqualified. It's a 391.15 violation. And essentially what that is, is, or what's happened over the last 2 years, like I said, with COVID is as drivers go through and get their medical certificates upgraded or renewed, rather, they're supposed to go through a self-certification process with each state. So as you know, the states have been kind of lackluster in being able to execute on that over the last couple of years. And that's caused a lot of backup problems down the road, not to mention the, you know, just many, many different levels of exemptions and things that the FMCSA and different states have gone through over the years too, in terms of when the medical certificate could be renewed, when it's not, when it's self-certified, when it's not, those kind of things too. So my point is many, many drivers have been You know, not just, yeah, they've been disqualified. I mean, technically from operating a commercial motor vehicle over the last few years because their medical certificate status. So definitely wanna make sure all your drivers have a valid medical certificate. One of the key regulations a lot of people ignore, but it's really critical, is having, once you, once your driver renews their, their CDL, or sorry, renews their medical certificate, you have the ability to go back and do that self-certification process. That gives you 15 days as soon as you have a new medical certificate. And within that 15 days, you actually have to, as a carrier, go through and pull a new MVR to verify that self-certification went through properly. So if you're not doing that, you should absolutely do that. If you aren't currently doing that and you need somebody to help you with that, we help with that all the time. So that's one of the things that, uh, one of the key driver qualification services that we provide under our My Safety Manager program. So. The blatant disregard for FMCSA regulations, or those 12 red flag violations is what they're called. So if you have a history of those, even a couple of them over the last 24 months, that's also a large trigger for a DOT audit. So in a nutshell, we hit fatality crash, having a high or being considered a high-risk carrier, having a high crash rate, having a complaint filed against your carrier or your FMCSA authority. Or having a red flag violation. So any one of those 5 different categories could cause or trigger a DOT audit in your near future. So if you have any other questions, don't hesitate to reach out to us. I hope you have a great day.
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