Papers, Please! Are You Ready to Face a Level III Driver/Credential DOT Inspection?
Approximately 4 million commercial motor vehicle inspections are conducted every year throughout North America to ensure the large trucks and buses driving on our roadways are operating safely.
While violations associated with vehicle inspections result in the majority of citations, it’s important to remember that the driver is as critical a component of the overall operation of the vehicle as the tires and brakes. It’s for that reason that an entire inspection level — Level III — is devoted to a comprehensive examination of the driver’s license; medical examiner’s certificate and Skill Performance Evaluation (SPE) certificate; driver’s record of duty status; hours of service; vehicle inspection report(s); and HM/DG requirements. They’ll even check out your seat belt to make sure it’s being used!
A violation or citation can affect your CSA score and negatively affect your reputation and ability to earn/retain business or obtain affordable insurance. An Out of Service violation can cost much more. Each day is an estimated loss of $264 in revenue when a driver is out-of-service. Don’t forget the fines — penalties for ELD violations can range from $1,000 to $10,000.
At Drivewyze, we are committed to improving road safety and efficiency for everyone. With that in mind, here are steps to make the Level III inspection process as easy and painless as possible while avoiding any major violations or delays.
Just as you do a pre-trip inspection to make sure your vehicle is in working order, it’s a good idea to check that your vehicle registration, permit documents, and other required documents are all valid and up-to-date. It’s in your best interest to find a problem before an inspector does, as the fines can be high, on top of you and your vehicle being put out of service.
It’s easy to let things fall through the cracks, so make a point to review documents at least every quarter to ensure everything is up to date. If you need a reminder, put alerts into your schedule to when permits, licenses and other time-sensitive materials are about to expire and need to be renewed.
Required documents include:
- Medical Certificate (remember, you are required to be examined every 24 months). As of June 22, 2018, commercial drivers no longer have to carry a Medical Examiner’s Certificate (MEC) with them or be responsible for submitting documentation to state agencies. Instead, the FMCSA’s electronic registry verifies the trucker’s current medical status.
- Driver’s License or CDL. Make sure your CDL is the sufficient class and has all the endorsements you need for the type of vehicle you’re driving and the load you’re hauling, and if there are any restrictions, make sure they’re current. For example, if you used to wear glasses, but got Lasik surgery, get your CDL updated, so an officer can’t write you up for not wearing corrective lenses when your license says you need them.
- Periodic vehicle inspection documents,
- Shipping papers/bills of lading,
- Proof of insurance,
- Other supporting documents such as receipts from the trip.
Not having documents with you, or at the ready, is no excuse. The inspector isn’t going to just take your word for it. Staying organized is the best way to stay on top of your paperwork requirements.
As a carrier, spend a few bucks and supply your drivers with binders in which they can keep all of their paperwork neatly organized. Check the documents at least every quarter to make sure everything is up to date.
Are you using an ELD or AOBRD to log your hours of service? If you’re shrugging your shoulders, you’d better figure it out fast. Electronic Logging Devices have been required since December 2017, and it’s critical that drivers understand their devices, get training if necessary, and know what to do if the device malfunctions. And if you’re exempt from the ELD mandate, you need to know why and be able to prove it.
There are so many systems out there (436 ELDs alone, as of this morning), and it’s impossible for the inspectors to know all of them. That’s why YOU have to be the expert. If you’re hunting for the instructions, you’re in trouble there too — it’s required that the manual be kept in the truck (whether the printed or electronic version).
Drivers still using AOBRDs need to follow the regulations laid out by the 1988 AOBRD Rule (49 CFR 395.15) and have:
- An AOBRD direction card in the cab that outlines how to use the device.
- At least seven days’ worth of blank paper logs with them in case the AOBRD isn’t working.
The Level III inspection is no joke. The inspector will be taking a serious look at your paperwork, so accuracy is important.
Log book requirements can be overwhelming at times. While it can be challenging to keep all the information straight, you still need to ensure that your log book is current and correct.
Keep your record of duty status (RODS) current to last duty status change (including accepting/rejecting any log edits or unidentified driving), and sign your logs at the end of every day. An officer can still take enforcement action against you even if the day has not been signed — and if the previous day hasn’t been signed by the end of the first stop on the following day, it constitutes a form and manner violation.
Believe it or not, the inspector is not the enemy. You and the officer are both doing your jobs. Be courteous and patient, and don’t be afraid to speak up if you have a question — safety is always the number one priority, and inspectors would like nothing better than to help carriers and drivers better understand and comply with regulations. Ultimately, everyone benefits.
Oh, and about that seat belt —- being caught with a missing or broken seat belt is something that CAN’T be improved by a clean inspection. The much maligned seatbelt ticket can land your fleet and driver 7 CSA points in the Unsafe Driving BASIC. To put it in perspective, a reckless driving ticket (15 mph over) is 10 points. Many carriers use neon seatbelts and seatbelt covers (less than $10 on Amazon) to draw attention to the proper use and avoid violations.
About the Author: Sara Steele
Sara is an expert in FMCSA compliance in the trucking industry. She has been involved in numerous compliance roles in several technology companies since 2009. During this time, she has traveled hundreds of miles on ride-alongs, attended numerous FMCSA rulemaking meetings, and advocated as a voice for drivers in Washington, D.C. She currently holds the Director of Compliance position at Drivewyze.