Prepare For The Dreaded Call

DOT has been very active in the past few months with audits and our membership. I have lost count of the number of calls I have received from members regarding DOT audits. The typical call goes something like: “DOT called and is coming next Monday to do an audit. What do I do to prepare for this? I’m not ready for an audit.” Would you be in this situation if they were to call you? Waiting for them to call is too late to prepare for their visit. There are too many things to have ready, and many of them involve recordkeeping and history from a few months to three years or more, depending on the item. The typical penalties issued after a DOT visit range from a couple thousand dollars to as much as the latest one of $16,000.

As your GAWDA DOT & Security Consultant, I publish a Traffic Bulletin every month on some aspect of DOT requirements. These are kept on the GAWDA Web site under the DOT Consultant section, and currently there are about six years’ worth of valuable information available there to help you. Reading each of these and following the guidance given will really help you to be ready for that dreaded call. Another way to prepare is to schedule a mock DOT audit, which will take you through the possible scenarios.

There have been several new items from DOT that are now in effect. These are discussed in more detail in the October 2005 Traffic Bulletin.

Shipping Paper/Hazardous Materials Manifest Update
The new change is found in 49 CFR 172.202 (a)(2). If the material (other than combustible liquids) has a subsidiary hazard class shown in column 6 of the hazardous materials table found in 172.101, then it must be entered in parenthesis immediately following the primary hazard class or division number on the shipping paper, i.e., Oxygen, compressed, 2.2 (5.1), UN1072.

Cylinder Label Update
You must show the appropriate hazard class or division number in the lower corner of a primary hazard label and any subsidiary hazard labels.

Hours of Service
The Federal Motor Carrier Safety Administration (FMCSA) issued its new and long-awaited hours-of-service rule for drivers of property-carrying commercial motor vehicles, specifying how long these drivers can operate their trucks before having to take a break.

The new rule took effect October 1, 2005. For most of our GAWDA members, there are not any changes from the previous rule. The only major changes are for sleeper berth drivers and non-CDL drivers of commercial vehicles which do not affect most of our members. DOT has issued a Frequently Asked Questions document on the new rule and you can view it here:

Gases and Welding Distributors Association
Meet the Author
GAWDA DOT & Homeland Security Consultant Michael Dodd is president of MLD Safety Associates in Poplar Bluff, Missouri. Members can reach him at (573) 785-5111 and at