DOT mock audits: find gaps before the investigator does
A mock audit is a practice run. We ask for the same records an FMCSA investigator would, check them against the regulations, and give you a written list of what's missing while there's still time to fix it.
Why a practice run is worth it
Every new carrier faces a New Entrant Safety Audit within its first 12 months. Established carriers can be pulled into an investigation after a crash, a complaint or a string of bad inspections. Either way, the investigator is not asking whether you work hard. They are asking whether your records show that you control your drivers and your equipment.
Records requests come with short deadlines. If you keep records at a regional office or terminal, FMCSA can require them at your principal place of business within 48 hours, not counting weekends and federal holidays (49 CFR 390.29). That is not the time to find out a medical card expired in March.
What an investigator looks at
A mock audit covers the same six areas.
Driver qualification files
Application, motor vehicle records, road test, annual review, medical certification and the rest of 49 CFR 391.51.
Hours of service and ELD records
Records of duty status, ELD data and the supporting documents that let an investigator check the logs against fuel, toll and dispatch records.
Drug and alcohol program
Written policy, pre-employment and random testing, Clearinghouse queries and proof of supervisor training.
Vehicle maintenance files
A file for each vehicle you control for 30 consecutive days, inspection reports and annual inspections under Part 396.
Insurance
Coverage at or above the federal minimum, which is $750,000 for general freight in interstate commerce (49 CFR 387.9).
Accident register
Every recordable accident from the last three years, with the details and report copies required by 49 CFR 390.15.
The violations that fail a new entrant automatically
49 CFR 385.321 lists 16 violations that fail a new entrant safety audit on their own. In plain words, they are:
- No drug and alcohol testing program, or no random testing program.
- Using a driver who tested positive, refused a test, or had an alcohol concentration of 0.04 or higher.
- Using a driver without a valid CDL, or a driver who is disqualified.
- Using a driver who is not medically qualified.
- Operating without the required insurance.
- Not requiring drivers to keep records of duty status (failure threshold: 51% or more of the records examined).
- Operating a vehicle placed out of service before it is repaired, or not fixing out-of-service defects a driver reported.
- Using vehicles without a periodic (annual) inspection (failure threshold: 51% or more of the records examined).
Some of these items are record gaps that a regular file review catches early. Others, like letting a disqualified driver drive or running a vehicle placed out of service, are unsafe practices that paperwork alone does not fix.
How LFS runs a mock audit
Intake
We talk about your operation and pull your public inspection and violation history from the SMS website.
Document request
You get a written list of what to send, built on the same areas FMCSA reviews. Most carriers send scans or give us read access to their files.
Review
We check every driver file, a sample of logs and supporting documents, every vehicle file, your drug and alcohol records, insurance and accident register.
Conversation
We talk with you and whoever handles safety and dispatch, because an investigator will ask how things actually work, not only what is written down.
Written gap list
You get a report listing each gap, the regulation behind it, how serious it is, and the fix, in the order you should do them.
Follow-up check
When you've made corrections, we look again so you know the gaps are closed.
A team behind your audit
Your mock audit has education behind it: a team with up-to-date information on the newest FMCSA rules, making sure the work is done the right and correct way.
Good times to schedule one
- You have a new authority and haven't had your safety audit yet
- You received a warning letter or had several inspections with violations
- You had a crash and expect questions
- You are hiring your first employee driver
- Your insurance renewal is coming up
A gap list is not a judgment
Almost every small carrier we review has something missing. The point is to find it now, on your schedule, instead of during an audit on someone else's. If files are the main problem, our driver qualification file service can rebuild them.
Questions and answers
Is an LFS mock audit the same as an FMCSA audit?
No. We are not FMCSA, and our review does not change your safety rating or your record. It is a private review that shows you what an investigator is likely to find.
If I fix everything on the gap list, will I pass?
We can't promise that. An investigator may sample different records or find something that happened after our review. A clean file set gives you the best footing you can have.
Do you come to my office?
Our mock audits are done remotely by default. If you need someone on-site, ask, and we'll tell you what we can arrange.
How long does it take?
It depends on how many drivers and trucks you run and how organized your records are. We'll give you a timeline after intake.
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Request a DOT mock audit
Tell us your fleet size, how long you've had authority, and whether you have an audit date. We'll send the document request list.
Prefer the phone? Call 901-205-9679.
Sources
- FMCSA — New Entrant Safety Audits
- 49 CFR 385.321 — Safety audit: Failure
- 49 CFR 390.29 — Location of records or documents
- 49 CFR 391.51 — General requirements for driver qualification files
- 49 CFR 395.11 — Supporting documents
- 49 CFR Part 382, Subpart G — Drug and Alcohol Clearinghouse
- 49 CFR Part 396 — Inspection, repair, and maintenance
- 49 CFR 387.9 — Financial responsibility, minimum levels
- 49 CFR 390.15 — Assistance in investigations and special studies (accident register)
- FMCSA Safety Measurement System (SMS)