Regulatory Consultant Keith Johnson Regulatory Consultant Keith has been in the transportation industry since 1988. specializing in Safety & Compliance Management since 1992. He maintains multiple industry certifications. Director of Safety (CDS) (University of Central Fla / NATMI) Defensive Driving Instructor (CSI) (Smith-System, Lancer & Hartford Insurance) Driver Improvement Instructor (CDI) (VA Dept. of Motor Vehicles / AAA) 1st Aid, CPR, AED Instructor (National Safety Council) He is a member of American Bus Association, United Motorcoach Association, Virginia & Maryland Motorcoach Associations and the Virginia Limousine Association.

FEDERAL MOTOR CARRIER SAFETY AUDIT BASICS Behavior Analysis and Safety Improvement Categories

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§390.5 Definitions – Commercial Motor Vehicle Commercial motor vehicle means any self-propelled or towed motor vehicle used on a highway in interstate commerce to transport passengers or property when the vehicle— (1) Has a gross vehicle weight rating or gross combination weight rating, or gross vehicle weight or gross combination weight, of 4,536 kg (10,001 pounds) or more, whichever is greater; or (2) Is designed or used to transport more than 8 passengers (including the driver) for compensation; or (3) Is designed or used to transport more than 15 passengers, including the driver, and is not used to transport passengers for compensation; or

§390.5 Definitions – Interstate Commerce Interstate commerce means trade, traffic, or transportation in the United States— (1) Between a place in a State and a place outside of such State (including a place outside of the United States);or (2) Between two places in a State through another State or a place outside of the United States; or (3) Between two places in a State as part of trade, traffic, or transportation originating or terminating outside the State or the United States.

What prompts a FMCSA Audit? Fatality Complaint CSA scores Statutory (every 3 years) New entrant Request

Safety Management Controls 1. Policies and Procedures 2. Roles and Responsibilities 3. Qualifications and Hiring 4. Training and Communication 5. Monitoring and Tracking 6. Meaningful Action

OPERATING AUTHORITY #1

§387.31 – MINIMUM LEVELS OF FINANCIAL RESPONSIBILITY #2

§390.19 – MCS 150 - MOTOR CARRIER ID #3

Part 390.19 – MOTOR CARRIER ID REPORT Every 24 months, according to the following schedule: USDOT number ending in Must file be last day of 1 January 2 February 3 March 4 April 5 May 6 June 7 July 8 August 9 September October

§366.2 – BOC-3 FORM OF DESIGNATION #4

#5 VEHICLE INVENTORY List by Co. #/Yr./Make/Model/Vin #/GVWR Registrations for all vehicles List should reflect seating capacity #5

#6 LIST OF DRIVERS List all drivers used in the last 12 months Include Name, DOH, DOB, License # & State Identify single-employer and multiple-employer as defined §390.5 #6

COPY OF LETTER OR FIELD REPORT RESULTING FROM LAST DOT COMPLIANCE REVIEW #7

VEHICLE LEASE AGREEMENTS (If applicable) #8

POLICIES AND PROCEDURES THAT CONTRIBUTE TO SAFETY MANAGEMENT CONTROLS #9

§390.15 – ACCIDENT REGISTER AND SUPPORTING FILES #10

#11 §391.51 – DQ FILE Application Employment verification Road test MVR (current & updates) Annual review Driver data sheet Medical Examiner Certificate Verification of NRCME #11

§382 – RECORD OF DUTY STATUS #12 *Must retain records for 6 months

§382 – DRUG & ALCOHOL PROGRAM §301 Pre-employment §303 Post-accident §305 Random §307 Reasonable Suspicion §309 Return to duty §311 Follow-up #13

§40.111 – SUMMARY OF DRUG AND ALCOHOL TESTING #14

§396 – VEHICLE MAINTENANCE FILES On file label § 396.3 (b)(1): Company # Year Make Model VIN # Tire size Inside: Driver Vehicle Inspection Reports §396.11 * Preventative Maintenance reports §396.3(a) Emergency exit inspections §396.3(a)(2) Annual /State inspection §396.17 Emissions Tests (if applicable) *Retain for 90 days #9

ANNUAL INSPECTIONS § 396.17 OR #15c

§ 396.23 Jurisdictions with inspection programs that satisfy the United States Federal periodic inspection requirements United States Mandatory (22) • Alabama • California • Connecticut • Hawaii • Louisiana • Maine • Maryland • Michigan • Minnesota • New Hampshire • New Jersey • New York • Ohio • Pennsylvania • Rhode Island • Texas • Utah • Vermont • Virginia • West Virginia • Wisconsin • District of Columbia Voluntary (3) • Arkansas • Illinois • Oklahoma Canada • All Canadian Provinces (10) • Yukon Territory #15d

CERTIFICATES OF QUALIFICATIONS OF INDIVIDUALS RESPONSIBLE FOR INSPECTIONS #16

DOCUMENTATION OF ROADSIDE INSPECTIONS PERFORMED DURING THE PAST 12 MONTHS #17

PAYROLL RECORDS FOR THE LAST 12 MONTHS FOR DRIVERS REQUESTED IN #12 #18

LOSS RUN REPORT #19

With the Implementation of Electronic Logging Devices (ELDs), FMCSA Agents will be asking for four (4) additional lists. Log Violation Report (FMCSR §395.8) Edit report of Logs (FMCSR §395.11) Speed Alerts (FMCSR §383.51) Unassigned Mileage Report #20-23

Be Prepared Be Honest Be Polite

THANK YOU Keith Johnson CDS, CSI, CDI Regulatory Consultant BUS Advisors keith@busadvisors.org (980) 999-8484