Preparing for an FMCSA Compliance Review

Navigating motor carrier compliance can be daunting, particularly when faced with an audit or intervention from the Federal Motor Carrier Safety Administration (FMCSA). Such communication often indicates rising Compliance, Safety, and Accountability (CSA) scores that could significantly impact operations. In this blog post, we'll dive into the key aspects of FMCSA audits, including their reasons, notification processes, and what to expect during a compliance review. Whether you're a seasoned carrier or just starting out, being well-informed can make all the difference in effectively handling these regulatory challenges.

In this issue:

• Nebraska State Trooper Killed by Snowplow.
• Daylight Savings Time Begins Sunday March 9th!
• International Road-check 2025 is May 13-15
• Registration is now open online for the 2025 Idealease/NPTC Spring Safety Seminar!

Suppose a motor carrier receives communication from the Federal Motor Carrier Safety Administration (FMCSA) or their state motor carrier enforcement division regarding an audit or intervention. In that case, it often indicates that their Compliance, Safety, and Accountability (CSA) scores have reached a level that has brought the carrier to the attention of the FMCSA. While audits may take place for various reasons, the CSA score is typically the main factor. Because of the limited number of FMCSA enforcement officers, the agency may partner with state carrier enforcement officers to carry out these audits and interventions.

Other Reasons for an Audit or Intervention:

• A carrier is new to the industry (New Entrant).
• The FMCSA is following up after a conditional or unsatisfactory review.
• A carrier has had a high-profile fatal accident or a hazardous materials spill involving an accident.
• A carrier requests an audit.
• Someone has filed a written complaint with the FMCSA regarding non-compliance with motor carrier regulations.

How Much Notification Do Carriers Receive Before a Compliance Review?

Carriers usually receive a written notification from the FMCSA with a two-week advance notice before a review. However, if the FMCSA finds serious non-compliance issues or violations, they may decide to conduct a surprise review instead.

Before the Compliance Review

When enforcement officers arrive at your business, one of your first steps—if they don’t provide it right away—is to ask for their identification. It’s appropriate to make this request, as all federal and state employees must carry identification showing their status. This way, you can confirm that they are indeed authorized representatives.

Be courteous, as they are there to perform their duties. Arrange them to work in a conference or meeting room away from busy areas to help minimize distractions. You can offer them coffee, water, or soda while they’re there, but avoid offering to buy lunch or providing any tips. Also, ensure that the room temperature is comfortable for them.

Take the opportunity to provide them with your preferred method of communication during the audit, whether via text or phone. You will serve as their primary point of contact as the individual responsible for regulatory compliance. It’s advisable to deliver all requested documents personally.

After the audit, there will be a final review with the owner or president of the company, who will need to provide a handwritten signature on the audit findings. During this meeting, you can address any violations they have identified. If you disagree with any of the violations, please let the officer explain how they reached their conclusions. They might have missed a piece of documentation that could alter their assessment. Furthermore, since regulations can sometimes be subject to different interpretations, feel free to share your perspective and discuss any inconsistencies.

What Must Carriers Provide for a Compliance Review?

Before the audit, the officer will gather information about the carrier and collect documentation related to driver and vehicle details from the CSA program. They will have access to data concerning drivers and vehicles involved in violations, accidents, and out-of-service incidents and will likely ask for supporting documentation.

When supplying the requested documents, only provide what has been specifically requested—nothing additional. For instance, if the officer asks for hours-of-service records for a driver covering five specific days, do not submit the records for the entire month. If the request lacks clarity, seek to confirm the exact days they need.

Typically requested records during a compliance review include:

• Proof of financial responsibility (MSC-90 for carriers with for-hire authority only).
• Driver qualification and training files.
• Drug and alcohol testing policies and records (for CDL drivers only).
• Records of duty status (logs) and supporting documents.
• Inspection and maintenance files (including certification for brake repair technicians and annual inspections).
• Hazardous materials records (if applicable).
• Accident registers and copies of accident reports.
• Medical certifications of drivers.

By regulation, a motor carrier has two business days (48 hours) to produce records upon request.

What Can a Carrier Expect During a Review?

The officer typically starts with a short interview and requests a facility tour. During the interview, they will ask basic questions regarding the carrier’s operations, safety measures, and driver training programs.

After the interview, the officer will focus on reviewing documentation. Carriers should provide a table or desk for the investigator to work at and ensure that they have easy access to the necessary files and records. If any records are stored electronically, be ready to display or print them as needed.

Suppose you are an Idealease customer and receive a notification about a review. In that case, it’s important to contact your Idealease representative immediately to ensure maintenance files are prepared for the officer’s review.

What Should Carriers Do During the Process?

The most critical advice for carriers undergoing an audit is to remain calm and cooperative. It’s essential for carrier representatives to respond promptly to all inquiries and to be honest with the investigator. While audits can be daunting, losing composure will only complicate the process. Carriers with effective management and safety protocols are well-prepared to navigate the audit successfully.

Top Audit Violations

The Top Five Acute Violations

Acute violations are considered severe and require immediate corrective action.

The Top Five Critical Violations

Critical violations indicate a breakdown in a carrier's management controls. A pattern of noncompliance (more than one violation) can negatively impact a carrier's safety rating.

When multiple documents are reviewed, a pattern of noncompliance is defined as violations occurring in at least 10% of the examined records.

Frost Laws in 16 States and 9 Provinces!

Spring weather can present unique challenges for drivers. The shift in ground temperatures often leads to road damage, resulting in uneven surfaces and a “roller coaster” driving experience. As a result, motor carriers need to stay informed about the various state and provincial weight restrictions that come into play during this season to avoid harming the roads or their vehicles.

Be prepared to take a different route. Many states introduce seasonal weight limits as early as late February, and these restrictions can extend into May. Drivers should pay attention to posted signs that specify allowable weight limits and may also indicate reduced speed limits. When planning routes, it’s wise to check state websites for information on highway accessibility for your vehicles. If a driver encounters a weight restriction, it may be necessary to find an alternative route, which could involve reaching out to dispatch for help.

Failing to heed posted restrictions can lead to consequences beyond fines; it can damage roads, vehicles, and cargo while increasing the risk of accidents due to challenging driving conditions. For detailed regulations in various states and provinces.

Daylight Savings Time Begins Sunday March 9th!

Daylight Saving Time will begin for 2025 on Sunday, March 10, at 2 a.m. local time, when clocks will move forward one hour. This twice-annual time change affects millions of Americans, though not all states and territories observe it.

• Start now to ensure all drivers are aware of the upcoming time change in two weeks. Route drivers should be especially cautious, as the amount of daylight will shift at their stops.
• Remember to change the batteries in smoke alarms and carbon monoxide detectors as well.

Most sleep experts recommend a minimum of seven hours of sleep per night. Many people lose an average of 40 minutes of sleep on Sunday night, March 9, after Daylight Saving Time returns. To avoid excessive drowsiness, plan ahead—sleep in on Sunday morning and consider taking a nap in the afternoon.

Not all states observe Daylight Saving Time. Hawaii and most of Arizona (except the Navajo Nation) do not participate, nor do the U.S. territories of American Samoa, Guam, the Northern Mariana Islands, Puerto Rico, and the U.S. Virgin Islands.

International Roadcheck 2025 May 13-15

International Roadcheck is a three-day annual event where CVSA-certified inspectors focus on compliance, enforcement, and educational initiatives related to motor carrier, vehicle, and driver safety. This event is the largest targeted enforcement program for commercial motor vehicles globally, with nearly 15 trucks and motorcoaches inspected every minute throughout North America during the 72-hour timeframe.

Since its start in 1988, over 1.8 million roadside inspections have been conducted during International Roadcheck. Besides enforcement activities, this event also serves as an opportunity to educate industry professionals and the public about the importance of safe operations for commercial motor vehicles and the roadside inspection program.

The Commercial Vehicle Safety Alliance (CVSA) sponsors International Roadcheck, with participation from various organizations, including the Federal Motor Carrier Safety Administration (FMCSA), Pipeline and Hazardous Materials Safety Administration (PHMSA), Canadian Council of Motor Transport Administrators (CCMTA), Transport Canada, and Mexico’s Ministry of Infrastructure, Communications, and Transportation.

Registration is now open online for the 2025 Idealease/NPTC Spring Safety Seminars!

Idealease and the National Private Truck Council NPTC will again be hosting safety seminars in the spring and fall of 2025. The one-day seminar this year will focus on basic safety and compliance, regulation changes and CSA. The seminars and will be provided to all Idealease customers, potential customers and NPTC members at no charge. The seminar provides important information applicable for both the novice and experienced transportation professionals.

Spring Seminars 2025

• 4/16/2025 – Dallas, TX
• 4/21/2025 – Hudsonville, MI
• 4/23/2025 – Brookfield, WI
• 4/29/2025 – San Leandro, CA
• 5/1/2025 – Portland, OR
• TBD – Harrisburg, PA
• TBD – Columbia, SC
• TBD – Miami, FL
• 5/15/2025 – Tampa, FL

To register for an upcoming spring seminar in 2025, click on the following link:
Safety Seminar Registration

Note: Fall seminars will be announced in a later bulletin.

*The Idealease Safety Bulletin is provided for Idealease locations and their customers and is not to be construed as a complete or exhaustive source of compliance or safety information. The Idealease Safety Bulletin is advisory in nature and does not warrant, guarantee, or otherwise certify compliance with laws, regulations, requirements, or guidelines of any local, state, or Federal agency and/or governing body, or industry standards.