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2005 was another busy year for DOT. Here are highlights of the past year on issues that affected our members.
DOT Audits
This was a big item last year and I fully expect it to continue in 2006.
The audits were typically initiated as a security review and while they
were there, they reviewed other topics, such as shipping papers, driver
qualification files, alcohol and substance abuse programs, hours of service
records, vehicle files, and other DOT items as they wished. Some audits
were with one inspector and lasted from a few hours to as many as two
inspectors taking two long days. Based on what they found and how they
felt about the company, the penalties ranged from a few hundred dollars
to as high as $16,000 per company. Most averaged from $4,000 to $6,000
per audit.
Shipping Paper/Hazardous Materials Manifest
Update
The new change is found in 49 CFR 172.202(a)(2). If the material (other
than combustible liquids) has a subsidiary hazard class shown in column
6 of the hazardous materials table found in 172.101, then it must be entered
in parentheses immediately following the primary hazard class or division
number on the shipping paper, i.e., Oxygen, compressed, 2.2 (5.1), UN1072.
This became effective on October 1, 2005.
Cylinder Label Update
You must show the appropriate hazard class or division number in the lower
corner of a primary hazard label and any subsidiary hazard labels. This
also became effective on October 1, 2005.
Previous Employer Inquiries
This actually became effective in late 2004, but I still find many of
our members don't know that they now must do safety performance inquiries
along with the drug and alcohol testing results inquiries on any new drivers
hired when the driver was a CDL driver for a previous employer within
the previous three years. There is a November 2004 Traffic Bulletin
that will give you more detail on this subject.
Safety Safari
2005 was the third year of my motor home trips traveling the country,
helping members with on-site audits and training sessions, which have
become known as the Safety Safaris. I visited 42 members in 2005 and in
the process traveled through 46 states. If you want to get on the visit
list for 2006, just let me know and I'll add you to the calendar.
As you can see, 2005 was a busy year for DOT and there is more coming for 2006. Hopefully you have all these new changes implemented into your company compliance programs.
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