Since 1966, the U.S. Department of Transportation (DOT) has ensured our nation has the safest, most efficient and modern transportation system in the world. To protect everyone on the roads, the DOT developed a rigorous set of regulations to guarantee that drivers are qualified and companies are safely transporting goods on U.S. highways.
But it can be difficult for companies to effectively monitor changing DOT regulations to remain compliant. Here are common challenges companies face and how Noble Diagnostics can help.
Common DOT compliance issues
Background check violations
DOT background checks are often conducted as part of a job applicant’s pre-employment screening process. Companies are required to reach out to a driver’s previous employers for the last 10 years to review past accidents, the driver’s safety history and drug and alcohol testing history. These background checks are enforced by the Federal Motor Carrier Safety Administration (FMCSA).
However, many companies don’t conduct proper background checks – or don’t do them at all.
In January 2020, the FMCSA established the Drug and Alcohol Clearinghouse, a secure online database that houses real-time information about commercial driver’s license (CDL) holders’ drug and alcohol program violations. The Clearinghouse contains records of violations of drug and alcohol prohibitions, including positive drug or alcohol test results and test refusals.
Before hiring a new driver, companies must run a full query in the clearinghouse, which acts as another layer in a high-quality background check. The DOT also requires companies to run a limited query once a year for every driver in the fleet.
Incorrect use of drug and alcohol testing pools
The DOT requires companies to test 50% of their drivers for drugs and 10% of them for alcohol in random testing pools. Companies can choose to test pools monthly or quarterly; the DOT allows companies to finalize all testing by December 31st of each year.
Some companies wait until the end of the year to conduct all testing, which can cause a logistical challenge and a backlog of tests. This can delay testing and force the driver pool – and the company – out of DOT compliance.
Other companies misunderstand the regulations altogether. For example, one business drug tested only 12.5% of its driver pool every quarter for a total of 50% of the pool every year. This violated the regulation to drug test 50% of their drivers every quarter. As a result, they were out of compliance and, if audited, would be subject to DOT fines.
The average FMCSA fine for drug and alcohol violations is $3,000 per non-compliant driver, making the company potentially vulnerable to tens of thousands of dollars in unnecessary fines.
Incomplete or out-of-date DQ files
Driver qualification (DQ) requirements mandate that every CDL driver has a DQ file easily accessible by an auditor. This file must contain multiple pieces of information, including:
REQUIRED per 49 CFR, Part 391.51
- Medical examiner’s certificate,
- Driver’s application for employment,
- Inquiry to previous employers for safety performance history (previous three years),
- Inquiry to state agencies for driver’s motor vehicle record and carrier’s annual review of record,
- Annual driver’s certification of violations,
- Driver’s road test and completion certificate or equivalent,
- Inquiry about drug and alcohol tests (FMCSA Clearinghouse),
- In addition to the above required documents, Noble Diagnostics DQ management program also includes and houses the following driver data:
- Background screening report,
- Pre-employment drug and alcohol test,
- Statement of on-duty hours,
- A copy of the driver’s license and license information, and
- Certification/audit for compliance.
It’s estimated that 60% of federal medical certificates are incorrectly filled out or signed by an ineligible physician. Only physicians on the federal registry – who have completed specialized training that allows them to perform DOT physicals – can sign a federal medical certificate.
If any other physician signs the medical certificate, it’s considered invalid by the DOT. This not only makes the driver non-compliant but also affects your entire company’s SMS scores – which can lead to audits and substantial fines.
How can you stay DOT compliant?
Partnering with a company that has the expertise and history of successful DOT compliance is the best way to stay current with DOT regulations and guidelines. Here’s what to look for in a partner.
Full FMCSA clearinghouse services and comprehensive background checks
You need a company that has FMCSA Clearinghouse services and provides comprehensive background checks. Noble Diagnostics has proven success offering full FMCSA Clearinghouse services, which can reduce the burden on your company.
Our Medical Review Officers (MROs) can directly access the database to review violations of drug and alcohol prohibitions and run both full and limited queries for every driver in your fleet.
We also conduct comprehensive background checks to review past accidents, the driver’s safety history, and drug and alcohol testing history to ensure full compliance with DOT regulations.
Comprehensive drug and alcohol testing
Drug and alcohol testing capabilities are the cornerstone of an effective DOT compliance program. Noble Diagnostics can help you efficiently conduct drug and alcohol testing of new and existing employees. We can help you with:
- DOT drug testing
- DOT alcohol testing
- Lab-based urine drug testing and breath alcohol testing
- Random drug and alcohol test management and reporting
- Drug and alcohol testing policy development
Centralized DOT compliance software
When you need to manage forms for multiple drivers and vehicles, paper files just don’t cut it. Noble Diagnostics has a centralized DOT compliance software system to track all your company’s fleet and driver data in one convenient location. Our proprietary software tracks everything from driver qualification file documents, driver drug testing results, physical exams and MVRs to custom compliance scores and vehicle maintenance data.
Noble Diagnostics tracks your data in real-time to ensure that it is kept up-to-date and accurate. It acts as a valuable information dashboard, flagging any items that are out of compliance or soon to expire, so you can take action to correct them. This cloud-based system includes:
- Driver qualification file tracking,
- Vehicle records and maintenance tracking,
- An email alert notification system, and
- An at-a-glance compliance and safety score for each driver and location.
This system helps to ensure both driver and fleet compliance. It can filter your data by branch and location so your safety director can review the compliance of each driver as well as the compliance of that location.
The risks to your company for non-compliance can be significant: It’s not uncommon for companies to get tens of thousands of dollars in fines during a DOT audit.
Our Noble Electronic Driver Qualification File Management System acts as an accountability tool to ensure managers are enforcing compliance regulations and avoiding fines that can run into the thousands of dollars per violation.
Our comprehensive system can help you make strategic business decisions, including how to issue safety performance bonuses to drivers and to managers while ensuring your company is DOT compliant throughout the year.
This system also allows you to manage your truck fleet as well to track annual inspections, and International Registration Program (IRP) and International Fuel Tax Agreement (IFTA) data. In addition, it can house your fleet’s regular maintenance log – all in one place.
Make sure your company stays DOT compliant. Contact Noble Diagnostics to discuss your needs today.