DOT Audits Are Increasing

What they’re looking for

There is a definite increase in the number of DOT audits in recent months. DOT is still doing a large number of security reviews, but I have been hearing about more full-blown audits than in past years.

The security audits come completely without prior notice. DOT just shows up at your doorstep. They will look for the four elements of the DOT security plan: Vulnerability Assessment, Written Security Plan, In-Depth Security Training, and Security Awareness Training.

The Vulnerability Assessment must be in writing and specific to the risks for your location. The Written Plan must address the identified location risks of vulnerabilities along with three main topics: Personnel Security, Unauthorized Access and En Route Security. The In-Depth Security Training must cover five elements of your written plan: company security objectives, specific security procedures, employee responsibilities, actions to take in the event of a security breach, and the organizational security structure. Security Awareness Training must be conducted every three years.

The In-Depth and Security Awareness Training must be documented with five pieces of information: The hazmat employee’s name; the most recent completion date of the hazmat employee’s training; a description, copy or the location of the training materials used to meet the requirements; the name and address of the person providing the training; and certification that the hazmat employee has been trained and tested.

Once DOT has shown up on your doorstep to do a security audit, they may look at other areas while they are there. They typically review your shipping papers/manifest, hazmat training, driver files and maintenance records. They may also look at your MCS-90 (the DOT liability insurance form) and your Hazmat Registration.

The Compressed Gas Association (CGA) recently updated and published four guidelines on security. They are P-50, Site Security Standards; P-51, Transportation Security Guidelines for the Compressed Gas Industry; P-52, Security Guidelines for Qualifying Customers Purchasing Compressed Gases; and P-53, Security Code Top Screen. You should review these for ideas on updating your security program.

I have written many Traffic Bulletins on the security programs and training requirements. There are also many Bulletins that will help you with the DOT audits. Be sure and check the Commonly Used Forms link in the GAWDA DOT Consultant Web page as well.

Another item I recently put together is a Suggested Filing System Help Page. It will give you a suggested hanging file and manila folder filing system that will help you organize your DOT records to help you stay in compliance and look very organized when DOT arrives. If you would like a copy of this help page, just ask and I’ll be glad to send it to you.

Call me whenever you are having or are about to have a DOT audit. I can help you with the items they ask about. I can also help you with any response letters you are required to send them outlining corrections they might require. The more you cooperate, the faster you make the corrections, and the more quickly you submit the correction action plan, the more it helps to reduce the potential penalties. The call I hate to get is when a member has received their penalty notice and this is the first I have heard about the audit. This is a little late to really help in reducing the penalty. It works a lot better to be proactive from the very beginning.

Gases and Welding Distributors Association
Meet the Author
GAWDA DOT & 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.