DOT Compliance, FMCSA
“One thing you may not be doing that can affect your DOT!”
Every year at renewal your insurance agency must file your new policies with the FMCSA and Motor Carrier Permit division. Failure to do this can result in your authority being revoked and your MCP to be inactive. Both permits are a foundational permit that can put your operations to a halt. Make sure you are communicating with your insurance agency to ensure they are filing your updated policies on time.
US DOT: https://www.fmcsa.dot.gov/registration/insurance-filing-requirements (link to insurance requirements)
Form BMC-91
Motor Carrier Permit: Form MC-65 M. This form can also be filed online at https://www.mcinfo.org/MCInfo/login.
**Both Liability Insurance and Workers’ Compensation must be filed if your company falls under Workers’ Compensation requirement per CA Insurance regulations.
DOT Audit, FMCSA
A motor carrier’s DOT safety rating indicates whether a company has adequate and functioning safety management controls to meet the Federal Motor Carrier Safety Administration’s (FMCSA) safety fitness standard based on the results of a compliance review (CR).
Safety Rating Levels
Safety rating are broken down into 3 basic levels and will be assigned to a carrier:
Satisfactory. Functioning and adequate safety management controls are in place to meet the safety fitness standard.
Conditional. Inadequate safety management controls are in place. You cannot ensure compliance with the safety fitness standard. You have deficient areas that FMCSA expects the carrier to resolve. However, you can continue to operate.
Unsatisfactory. Inadequate safety management controls are in place. You cannot ensure compliance with the safety fitness standard. Your safety program has too many deficiencies to allow your fleet to continue operating.
If your organization has never had a CR, your fleet will be unrated on the SAFER site.
Factors that Impact Ratings
The safety fitness standard is determined through the results of a CR. The areas of compliance for the standard are outlined in §385.5. They are based on previous audits and are updated monthly after reviewing accident data and violation status.
The key factors in ratings include:
- Hours of Service (HOS)
- Unsafe Driving
- Controlled Substances and Alcohol
- Driver Fitness
- Accident History
- Maintenance of Vehicles
- Hazardous Materials Compliance
Where Can I Find My DOT Safety Rating?
Your companies DOT safety rating is available to you — and the general public — at FMCSA’s SAFER website.
Since anyone can look at your safety record, a poor safety rating can affect your insurance rates and hurt your company’s reputation, hinder your driver recruiting efforts and result in a loss of customers.
To help avoid a less-than-favorable safety rating, you need to understand what the agency will examine during an audit.
How Can I Improve My Safety Rating?
If your company has received a conditional or unsatisfactory rating, you may request a rating change at any time. The FMCSA would expect to see a safety management plan to address the violations discovered during the CR. Based on the contents of the plan, the FMCSA may issue an improved safety rating.
Maintaining a solid DOT safety rating is critical to your reputation as a motor carrier and can save your company a lot of time and money!
VLC will be expanding our core features to include a safety tracking module to ensure good driver behavior and improve and encourage good CSA scores. Contact us to learn more.
DQMConnect™, Driver Qualification File Management, FMCSA
The FMCSA has been conducting offsite audits for over 3 years. Starting in 2019, they were largely focused on safety reviews. However, the number and types of offsite audits have been on the rise. The pandemic encouraged the transition while the ease and cost effectiveness of offsite audits are continuing the trend upward.
In 2020, nearly 5 times the number of offsite audits were conducted as compared with 2019. Last year, 2021 saw a rule change enabling the FMCSA to issue safety ratings after an offsite audit. More motor carriers are receiving a “conditional” safety rating than “satisfactory”, despite so many audits being done remotely. This is something the agency could never do before.
Given the trend of the past 3 years and the fact that offsite audits appear to be working, they will likely remain part of the agency’s approach for years to come.
Let’s examine the audit numbers for 2021.
6% increase in audits; 95% resulting in violations
30% increase in audits that uncovered severe violations
37% increase in audits with critical violations such as missing records
The rise in conditional safety ratings is an important consideration for any HR manager or Fleet Manager. Conditional safety ratings can have costly consequences, including lost customers, higher insurance rates, and increased liability in court.
The Transition to Offsite Audits
As we can see, the Federal Motor Carrier Safety Administration is relying more heavily on offsite audits. It is time for you to embrace a DQM File Management tool to help ensure your compliance and facilitate these offsite audits. DQMConnect has a truly unique approach to DQM File Management. You maintain control of your files and it presents you with your compliance status and prepares the necessary audit files right from the Dashboard. No waiting. No loss of control. The data is yours and is accessible 24×7. For you and for the auditor should you need it.
Let us show you why more carriers are moving to DQMConnect to stay in control, in compliance, and audit ready!
Electronic Logging, FMCSA
The Federal Motor Carrier Safety Administration (FMCSA) establishes minimum performance and design standards for hours-of-service (HOS) electronic logging devices (ELDs). On June 24, 2022, FMCSA removed the ArionT ELD from the list of registered ELDs due to the company’s failure to meet the minimum requirements established in 49 CFR part 395, subpart B, appendix A. Motor carriers and drivers using ArionT ELDs have 60 days to replace the revoked devices with compliant ELDs.
Here are the specifics of the affected ELD product, model #, and ELD identifier:
ELD Name: ArionT ELD
Model number: AT5000
ELD Identifier: AR1ONT
ELD Provider: Arion Tech Inc.
This device now appears on FMCSA’s Revoked Devices list.
Motor carriers and drivers who use the ArionT device must take the following actions:
- Discontinue using the revoked device(s) and revert to paper logs or other logging software to record required hours of service data.
- Replace the revoked device(s) with compliant ELD(s) from the Registered Devices list before August 24, 2022.
These required actions provide motor carriers with up to 60 days to replace their ArionT devices with compliant ELDs.
Motor carriers and drivers who continue to use the revoked ArionT device listed above on or after August 24, 2022, will be in violation and drives will be placed out-of-service in accordance with the Commercial Vehicle Safety Alliance (CVSA) OOS Criteria.
If Arion Tech Inc. corrects all identified deficiencies, the FMCSA will place the device back on the Registered Devices list and inform the industry and the field of the status change. However, FMCSA strongly encourages motor carriers to take the actions listed above now to avoid compliance issues should these deficiencies continue past the 60-day grace period.
Vehicle Licensing Consultants has a solution for you. Check out the benefits of a TripDawg solution for your electronic logging needs:
- The TripDawg ELD is based on Geotab, one of the highest rated ELDs available
- TripDawg ELDs are always kept up to date with the latest technology and software releases
- TripDawg ELDs offer amazing expansion capabilities including:
- Dash Cams
- Weigh Station Bypass
- Asset tracking
- Fleet Maintenance
- Dispatch solutions
- And more!
Vehicle Licensing Consultants
A Virtual Projects, LLC Company
Fleet & Driver Compliance…Fleet Tracking Software
FMCSA
Commercial drivers license holders might finally be able to stop giving their medical cards to the state. The FMCSA is proposing June 23, 2025, for the new deadline. That date will also affect when motor carriers will be able to stop verifying that their CDL drivers are seeing a certified medical examiner.
No changes for now, but once the delay is finalized, motor carriers and drivers will need to continue following current practices for the foreseeable future. This means:
- Motor carriers must continue to get a copy of each CMV driver’s medical card.
- Motor carriers must verify that their DOT medical examiners are actively listed on the National Registry for all CMV drivers.
- CDL/CLP drivers must submit their medical card to the state within about five days of each exam and then carry a copy for at least 15 days following the exam.
- Motor carriers must obtain an updated driving record (MVR) for each CDL/CLP driver within 15 days of each medical exam.
Changes that were scheduled to arrive to the medical certification and licensing processes on June 22, 2021, are being delayed yet again. If the delay is finalized, recordkeeping practices will not need to change until June 2025.
VLC is here to help with all fleet and driver compliance and licensing matters.
Vehicle Licensing Consultants
A Virtual Projects, LLC Company
Fleet & Driver Compliance…Fleet Tracking Software
530-384-3884
FMCSA
Due to the coronavirus, the FMCSA (Federal Motor Carrier Safety Administration) permitted a waiver for renewals of interstate and intrastate CDLs (commercial driver’s licenses), CLPs (commercial learner’s permits), and medical cards. The extension was granted to professional drivers whose CDLs, permits, or medical cards had expired or set to expire after March 1, 2020. Similar waivers were continued in June, Sept, and Dec of 2020. May 31, 2021 ends the extension… just around the corner.
This is a helpful reminder that if you were due for renewal on or after March 1, 2021 you now must renew and have your CDLs, CLPs, and medical cards in place by June 1, 2021.
We Are Here to Help
If you are taken off-guard by any of the regulations, extensions, permit dates, etc. it is time to take those worries off your plate. Give the job to a professional who knows the rules, stays abreast of changing regulations, and keeps you on-time and in compliance.
Contact Us
By phone 530.384.3884, by email info@im4trux.com, or fill out our contact form online. We help clients focus on their business, offloading the compliance and licensing issues, and providing excellent fleet data to help you focus on your strengths and efficiencies.
Providing Mobility to the Trucking Industry…
Vehicle Licensing Consultants
A Virtual Projects, LLC Company
Fleet & Driver Compliance…Fleet Tracking Software
530-384-3884
