Facility Audits: Proof is Proof

by Everybody Loves Alain

There are only two words that count when it comes to a facility audit: ‘Show me’!

You might have the best policies and practices in place, but if you don’t document everything, then you might as well not have them at all. Let’s explore some key best practices to ensure a successful audit.

Maintenance Policy:

Having a written maintenance statement is great, but remember that you will be held accountable to that policy during an audit.

If you tell an auditor that you perform a full equipment service and PM inspection every 30 days on your tractors and quarterly on your trailers, then your maintenance files better back that up. If you exceed your own stated PM intervals, you will lose points because you are not in compliance with your own policy.

Therefore, you should build some flexibility into your maintenance statement. For example, instead of stating a 30-day PM interval for a tractor, modify it to every 30 to 40 days. Have your staff work within the 30-day interval; but if they don’t complete a PM within that interval, you have wiggle room.

Drivers and HOS:

During an audit, don’t be surprised when the DOT officer spends hours dissecting individual driver logs.

While you should be inspecting those logs yourself, in reality many carriers only give their driver logs a peripheral review. If this sounds familiar, sit up and take some notes.

The auditor will start by picking a month and entering all the duty hours for each day into a software program, which will then crunch the numbers to uncover cycle violations. If your review doesn’t check for cycle violations, don’t be surprised when the auditor finds one.

You can reduce cycle violations by levelling the playing field. Use log-auditing software yourself or use the services of a quality log-auditing firm.

If you do catch violations, address the issue with drivers, especially with repeat offenders. This is where a progressive discipline policy is useful.

Make sure your drivers understand your discipline policy, specifically by having each driver sign off on it as ‘understood’. Therefore, if you have a repeat offender, you have the legal means to take disciplinary action.

In addition, be sure to search for evidence of ‘mile compression’ or ‘pattern logging’.

Match log entries against bridge- and border-crossing receipts. If a driver has been through a scale, the log entry should show the proper time and date of the inspection. The DOT will bring time-stamped records to the audit to conduct comparisons against your logs.

Miles-driven and hours-driven entries should never suggest that a driver was speeding. For example, many logs document that a driver drove 800 kilometers while working for 7 1/4 hours. That the driver is either speeding or falsifying his log.

Let’s do a reality check. When a driver’s log averages 90 km/h or more, alarm bells should be ringing. No truck is ever going to average more than 90, given time spent getting up to speed, delays in traffic, and stops required for breaks and fueling. Any truck recording an average speed over 90 km/h should be targeted for a closer review.

Also, a DOT officer may enter city-to-city information into a mileage calculator based on approved mapping software programs like Milemaker. This is where the auditor may catch a driver shortening the hours required to do a trip leg — and bingo, you have an HOS violation with no effective way to fight it.

Bonus points:

Bonus points are available under most Canadian and U.S. audit processes. These are credited to fleets that can show that they provide regular safety training on such topics as load securement, handling/transporting of dangerous goods, and pre-trip inspection. You can also earn bonus points for exceeding minimum standards. For example, the regulations require you to pull driver abstracts once a year; if you pull them twice a year, you get bonus points.

However, be sure you know which measures will earn bonus points if exceeded — if you recall, more frequent PM inspections that don’t match your policies can work against you.

Got the Proof?

Since paper documentation can help you pass or fail a facility audit, ensure your paperwork is in order before an audit takes place. After all, talk is cheap. The bottom line is that during an audit, your company is only as good as its processes, and you need documented proof that you’re running a compliant business.

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