Security Plan Audits

DOT is still placing extra emphasis on security plan audits. Many of our members have been visited. If you do not have a security plan and all four elements (Risk Assessment, Written Plan, In-Depth Training on the Plan, and Security Awareness training), then please contact me for help. I can help you with a sample plan and simple instructions on how to get this program in place as soon as possible.

DOT Audit Tips
  1. Get a current MCS-90.
  2. Do an annual driver safety review.
  3. Check drivers’ previous employers.
  4. Keep a driver’s current license on file.
  5. Keep three years of Medical Examination Certificates on file.
  6. Keep track of important dates.
  7. Contact your GAWDA Consultants.

Several common items that I find during my mock DOT audits bring to mind the following questions:

  • Do you have a current MCS-90 from your insurance carrier? Most people need to show $1 million on the form. However, if you transport cargo tanks with more than 3,500 gallons of water capacity or transport Hazard Zone A inhalation hazard gases, you will need $5 million.
  • Are you doing the annual driver safety review? Remember that this is a three-step process. You have the drivers certify their violations for the past 12 months, you pull a state MVR, and then you certify the driver is OK. This must be done on or before the date from the previous year.
  • Are you doing the previous employer checks when hiring a new driver? This requires three checks:
    1)  Verification of employment dates,
    2)  DOT accidents for the past three years, and
    3)  Asking about drug and alcohol testing results for CDL drivers for the past three years.
    You must ask at least twice if you do not get answers from the previous employer.
  • Are you making sure that you keep a current driver license in the driver file? This is not required by DOT, but it is an excellent way for you to make sure the license is current and has the proper endorsements.
  • Are you keeping three years’ worth of Medical Examination Certificates in the driver file? This is from the date the doctor does the exam.
  • Do you have a method of keeping track of important dates such as driver’s license, the med card, hazmat training, the annual driver safety review and the annual DOT inspection for your vehicles? Having a system is one thing, but DOT will check the actual records to see if you are ever going past any of the dates.

Have you ever contacted your GAWDA consultants? I’m always amazed at the number of members who have never contacted me with questions or looking for help with their DOT program. I get an average of about 275 e-mails or calls a month from members. I love answering questions and helping people. If you have never or seldom contacted your consultants, please do. This is an extremely valuable service that comes as a part of your GAWDA membership. Take advantage of it.

Hopefully, you have made plans to attend the convention in Orlando this October. If you attend, please look me up or stop by the contact booth and say hello and bring your questions. See you there.

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 mldsafety@hotmail.com.