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Up for a Facility Audit?

The first issue often raised by a carrier facing an audit, is "why me?" It is often assumed they are targeted for a particular reason. This may be the case, but in most cases audits are random, althou...

The first issue often raised by a carrier facing an audit, is “why me?” It is often assumed they are targeted for a particular reason. This may be the case, but in most cases audits are random, although they may be focused on those in the industry who have not been audited in the past or those who have not been audited for a long period of time. This approach is both understandable and fair.

But there are audits that are indeed initiated because of specific factors. These include, for example, carriers who have what is considered an unacceptable CVOR threshold. An overall compliance rate of 34% will initiate a warning letter, although not necessarily an audit. But where the overall rate continues to edge upwards, your chances of being audited, rise accordingly.

There are also those instances where an operator has been brought in for an interview and submitted an action plan for improved compliance. It is particularly important in these circumstances that the CVOR record improves accordingly. In other words, you don’t want a case where you have meticulously explained how you are going to reduce out-of-service vehicle inspections, only to have this rate remain the same, or worse, rise as the result of subsequent roadside inspections.

If you have a detached wheel event, you can almost bank on an audit, certainly if there was a personal injury or fatality involved. In these circumstances, and unfortunately there have been too many, I would recommend the following: Make certain that prior to an on-site visit, you have taken all steps to fully investigate the incident, and have it fully documented. Your overall maintenance program will come under the microscope, so you should ensure that a full review of inspection procedures and policies is part of the analysis.

Better yet, before any “detached wheel event” ever occurs, I strongly recommend that all carriers consider as part of their overall documented maintenance program the steps they take as a matter of routine to prevent such situations from ever occurring. There is a lot of good information available on this topic, and if an appropriate set of steps are taken, documented, and followed, your overall due diligence will be enhanced significantly. Put yourself in the position of an investigating officer who is apprised of your well-established and acceptable procedures that you have adhered to as opposed to one of, “I can’t believe this happened to us”. You know what side of the fence you would rather be on.

The other most common “target audit” is one where a complaint has been lodged. The complaint will generally come from a disgruntled employee, often a driver. It has been my experience that the nature of such complaints are split nearly 50-50 between personality clashes and specific complaints about excessive hours or shoddy maintenance practices. In almost all cases while the complaint is embellished, there is usually an element of truth to the claim. And an aggravating factor is that the complaint, as true as it may be, tends to take the shotgun approach. A particular driver may have been urged to run the load a few times by a particular dispatcher, putting him over hours, but the complaint is often couched in terms of “this is the way the company runs at large”.

Like the precautions that can be taken with any compliance aspect, steps should be taken to minimize complaints lodged by employees that can trigger audits. I have seen too many instances, particularly in larger companies, where a particular dispatcher is well respected for the job he or she does in moving freight but is generally disliked by the driver force. A situation like this can often be a filed complaint waiting to happen where the entire company comes under scrutiny. Conversely there are particular drivers, who may have great driving records and can move the freight, but seem to have that bit of attitude that at some point is directed to the company at large. We don’t live in a perfect world, but steps can be taken to recognize these types of problems early on, and take actions to prevent the unnecessary from occurring.

Nobody likes a compliance audit regardless of which branch of government is involved. But every audit is predictable. The key factors leading to a positive outcome are the same. Know the rules and regulations. In trucking, you know that hours of work (driver control) and vehicle maintenance compliance are the two big ones. Your knowledge of such must be buttressed by training of drivers and in-house personnel, periodic training as required, and full monitoring of compliance followed up with corrective action and/or discipline to address deficiencies.

Most important, you must be able to produce full documentation that will demonstrate how your particular policies, procedures, and actions result in an acceptable level of compliance. Get the jump on an audit. Do your own in-house. And for those who may not be aware, the Ontario Ministry of Transportation offers an excellent publication detailing the facility audit program, and how to conduct your own.

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