It’s inevitable that you’ll be audited in one way, shape or form. From an annual audit by your accounting firm, to a safety audit by state or federal DOT, one thing is critical for any successful audit and that is correct, accurate data.
To be best prepared for an audit, we recommend that you do a few things:
- Analyze your data collection methods
- Understand what an auditor is looking for
- Put your data to the test
Analyze your data collection methods
All interstate transportation using heavy trucks is required to have an electronic logging device (ELD) or an automatic onboard recording device (AOBRD). The latter of which is only valid for use until December 16, 2019, when all AOBRDs must be replaced with ELDs.
With these electronic devices in every tractor cab, a host of data is automatically recorded, including location, hours of service, and much more.
Your ELD solution should include the ability to access your data in multiple ways– on the in-cab device itself, as well as online though a back-office administrative portal. For instance, the in-cab device must record and retain data for at very least the required time – current and last seven days – to pass any roadside inspection. If your ELD isn’t retaining the right amount of data, you’re likely to find out quickly at your next inspection.
Back-office systems should be robust and give you a wide variety of options to view and export your data. You will get a wealth of data from comprehensive systems that you can utilize both for audits, as well as optimizing your fleet. This includes:
- Driver hours of service (HOS)
- Daily vehicle routes
- Taxable mileage
- Off highway mileage
- Safety incidents
- Fuel efficiency
- Maintenance needs and status
- And much, much more
If you’re not gaining access to this type of data, contact your provider, or consider exploring alternative solutions.
In addition to ELD data, to pass a DOT audit, you should ensure that you are also keeping accurate records of the following:
- All DOT recordable accidents and relevant information, including accident date, location, driver’s name, number of injuries & fatalities, and any hazardous material spilled.
- All driver qualification (DQ) files including commercial driver’s licenses, drug and alcohol testing and medical cards.
- Inspection and maintenance records (DVIR) from the past 90 days for all vehicles.
Understand your auditor’s needs
Gone are the days of printing out and getting your paper files organized for a safety audit.
Now you will be asked to provide a wide variety of data, including the record of duty status (RODS) for your drivers electronically. For the driver’s RODS information, the auditor will expect to view your records on the FMCSA’s online eRODS application.
The RODS data should be exportable from your ELD provider’s back-office system. The FMCSA requires you to keep the most recent six months of driver log book data.
When exporting any data for the auditor, only export the very tight range of data that they request. Otherwise there the auditor will have to work through all the information to get to the data they need to evaluate or you’re exposing yourself to giving them more data to evaluate. Data exports should contain relevant notes that explain any device malfunctions and unidentified trips but should under no circumstances include any violation warnings. The auditor will use the eRODS application to determine any potential violations based on the raw driver RODS data transferred.
In terms of vehicle-related audits, all mechanical defects for vehicles must be accurately recorded on your driver’s DVIR. And, most importantly, if a driver is cited for a violation, there should be an associated DVIR and an associated repair record. FMCSA auditors are keenly aware of these issues and won’t hesitate to call these out and potentially fine you for them.
For all DOT recordable accidents in the past three years, have your records on hand in case they are requested. Optimally, at the time of an accident make a copy of all records at the time of the incident. This includes the Driver’s DQ file, disciplinary file, HOS records, vehicle maintenance records, DVIR, and police record of the incident. This ensures that you will be protected in the case that this accident is audited or in any legal cases. Be sure to talk to your legal representation for any further accident process recommendations.
Put your data to the test
Now that you have explored what your ELD provider can offer in their back-office system, you will better understand what you can provide to the auditor.
The most basic HOS file required by the auditor will be the record of duty status (RODS) data. Your solution should be able to easily export a RODS file for enforcement at roadside, as well as for auditors. If your solution makes this difficult, or doesn’t appear to offer exported file support, this may be a cause of pain down the line. Be proactive in finding out what the ELD back-office system can provide you.
The FMCSA has publicly made available the same tool used by the safety officials that can help you check out your own data. To use the eRODS tool:
- Open https://eld.fmcsa.dot.gov/eRODS
- Click the Browse button
- Navigate to your exported ELD file
- Click View ELD File
The online system shows you what your auditor will see. It should include an accurate HOS as well as any notes on unidentified trips. It should not include any violation information as the auditor will need to calculate any potential violations on their own.
Watch the Webinar
To help you get a better understanding of the process, watch our webinar where EROAD’s Director of Regulatory Compliance, Soona Lee, reviews:
- What auditors are looking for during an ELD audit
- How to access web eRODS to view the ELD data ahead of time
- Tips to ensure a successful ELD data transfer
- How ELD data transfer works from the EROAD back-office