DOT Compliance

Understanding DOT Compliance

Department of Transportation (DOT) compliance encompasses the full range of federal regulations governing commercial motor vehicles, drivers, and carriers. While FMCSA administers many of these regulations, DOT compliance is broader—covering everything from driver licensing to vehicle maintenance to drug testing. For dispatchers and carriers, maintaining DOT compliance is essential for legal operation and safety.

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What is DOT Compliance?

Department of Transportation (DOT)

Role:

• Cabinet-level federal agency
• Oversees all modes of transportation
• FMCSA is a sub-agency focusing on motor carriers
• Sets and enforces transportation safety regulations

DOT for Trucking:

• Federal safety standards for commercial vehicles
• Driver qualification requirements
• Vehicle inspection and maintenance standards
• Hazardous materials regulations
• Drug and alcohol testing programs

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USDOT Number - Your Identifier

What is a USDOT Number?

Definition:

• Unique identifier assigned by FMCSA
• Required for interstate commercial motor vehicles
• Used for safety monitoring and compliance tracking

Who Needs It:

• ✅ Interstate carriers with vehicles:
  • 10,001+ lbs gross vehicle weight, OR
  • Transporting 9-15 passengers for compensation, OR
  • Transporting 16+ passengers (not for compensation), OR
  • Transporting hazmat requiring placards

What It's For:

• Safety monitoring
• Compliance reviews
• Crash and inspection data tracking
• Insurance verification
• Authority to operate

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Obtaining and Maintaining USDOT Number:

Application:

• Apply online at portal.fmcsa.dot.gov
• Provide company information
• Describe operations
• Free to obtain

Biennial Update:

• Must update every 2 years
• Even if no changes to company information
• Reminder sent 90 days before deadline
• 60-day grace period after deadline
• Failure to update = USDOT number deactivated

Dispatcher Tip:

• Set calendar reminders for biennial update
• Mark it 90 days before due date
• Deactivated number = Cannot operate legally

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CDL Requirements

Commercial Driver's License (CDL)

Who Needs a CDL:

• Drivers operating vehicles with:
  • Gross Vehicle Weight Rating (GVWR) of 26,001+ lbs, OR
  • Towing vehicle with GVWR 10,001+ lbs (combined 26,001+ lbs), OR
  • 16+ passengers (including driver), OR
  • Hazardous materials requiring placards

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CDL Classes:

Class A:

• Combination vehicles with GCWR (Gross Combination Weight Rating) of 26,001+ lbs
• Towed vehicle must be 10,001+ lbs
• Examples: Tractor-trailers, truck and trailer combinations
• Most common for over-the-road trucking

Class B:

• Single vehicles with GVWR of 26,001+ lbs
• May tow vehicle under 10,001 lbs
• Examples: Straight trucks, large buses, dump trucks, box trucks
• Typical: Local delivery, construction, buses

Class C:

• Vehicles not Class A or B that:
  • Transport 16+ passengers, OR
  • Transport hazmat requiring placards
• Examples: Passenger vans, hazmat vehicles under 26,000 lbs

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CDL Endorsements:

H - Hazardous Materials:

• Required for transporting hazmat requiring placards
• TSA background check required
• Renewed every 5 years with background recheck

N - Tank Vehicles:

• Required for tank vehicles (liquid/gas) with 1,000+ gallon capacity
• Individual tanks or aggregate

P - Passenger:

• Required for vehicles carrying 16+ passengers (including driver)

S - School Bus:

• Required for school buses

T - Double/Triple Trailers:

• Required for pulling two or three trailers

X - Combination:

• Tank + Hazmat (HX endorsement)

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CDL Restrictions:

E - No Manual Transmission:

• Tested in automatic, restricted to automatic only

L - No Air Brake Equipped Vehicles:

• Tested without air brakes, cannot operate air brake vehicles

Z - No Full Air Brake Equipped Vehicles:

• Can operate hydraulic brakes only

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Dispatcher Verification:

Before Dispatching Driver:

1. ✅ Verify CDL is valid (not expired, not suspended)
2. ✅ Verify CDL class matches vehicle (Class A for tractor-trailer)
3. ✅ Verify endorsements match cargo (H for hazmat, N for tanker)
4. ✅ Check restrictions don't prohibit operation (air brakes, etc.)

How to Check:

• State DMV/DPS online portals
• Annual MVR (Motor Vehicle Record) pull
• Driver qualification file

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Medical Certification

DOT Physical Exam:

Requirement:

• All CDL drivers must have valid Medical Examiner's Certificate (MEC)
• Issued by FMCSA-certified medical examiner
• Valid for up to 24 months
• Must be carried by driver while on duty

Medical Standards:

• Vision: 20/40 in each eye (corrected OK)
• Hearing: Forced whisper at 5 feet OR hearing aid
• Blood Pressure: <140/90 (may be certified for shorter periods if higher)
• Diabetes: Controlled, may require exemption
• Cardiovascular: No disqualifying conditions
• Medications: No disqualifying medications

Disqualifying Conditions:

• Epilepsy (unless 8-year seizure-free)
• Insulin-dependent diabetes (unless exemption granted)
• Vision worse than 20/40 corrected
• Hearing loss not correctable
• Certain heart conditions

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Medical Certification Process:

Step 1: Exam

• Driver visits FMCSA-registered medical examiner
• Complete physical examination
• Cost: $50-$150 (driver pays)

Step 2: Certificate Issued

• If qualified, examiner issues Medical Examiner's Certificate (MEC)
• Valid up to 24 months (may be shorter for certain conditions)

Step 3: Submit to State

• Driver provides MEC to State Licensing Agency
• State updates CDL status to show medical certification
• Self-certification also required (type of driving)

Step 4: Keep on File

• Carrier maintains copy in driver qualification file
• Driver carries copy in truck

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Dispatcher Tracking:

Critical:

• ✅ Track every driver's medical card expiration date
• ✅ Set reminders 60 days before expiration
• ✅ Driver cannot operate after expiration
• ✅ Downgraded CDL if not renewed in time

System:

• Use spreadsheet or TMS software
• Set automated alerts
• Monthly review of upcoming expirations

Violation:

• Operating without valid medical card = Immediate out-of-service
• Fine: $1,000-$5,000
• CSA points

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Drug and Alcohol Testing

FMCSA Drug & Alcohol Program Requirements:

Mandatory for:

• All CDL drivers
• Required by federal law (49 CFR Part 382)

Testing Types:

1. Pre-Employment:

• Before first safety-sensitive duty
• Must pass drug test
• Alcohol testing not required pre-employment

2. Random:

• 50% of drivers tested annually for drugs (minimum)
• 10% of drivers tested annually for alcohol (minimum)
• Unannounced, unpredictable selection
• Must use truly random selection method

3. Post-Accident:

• Within 8 hours of accident if:
  • Fatal crash, OR
  • Driver issued citation AND injury with medical treatment, OR
  • Driver issued citation AND disabling damage requiring tow
• Test for drugs and alcohol

4. Reasonable Suspicion:

• When supervisor has reasonable belief driver is using drugs/alcohol
• Based on observed behavior, appearance, speech
• Supervisor must have training in detection
• Must document observations

5. Return-to-Duty:

• After violation, before returning to safety-sensitive duties
• Must pass test after SAP evaluation and treatment

6. Follow-Up:

• Minimum 6 tests in 12 months after return-to-duty
• Can extend up to 60 months
• Unannounced

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Substances Tested:

Drug Panel (5-panel):

• Marijuana (THC)
• Cocaine
• Opiates (codeine, morphine, heroin)
• Amphetamines (methamphetamine, MDMA)
• Phencyclidine (PCP)

Alcohol:

• 0.04 BAC limit while on duty
• 0.02-0.039 BAC = 24-hour out-of-service
• 0.04+ BAC = Violation, requires SAP process

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Consequences of Failed Test:

Immediate:

• Driver removed from safety-sensitive duties immediately
• Cannot drive until completing SAP process

SAP Process:

• Evaluation by Substance Abuse Professional (SAP)
• Treatment/education as recommended
• Pass return-to-duty test
• Subject to follow-up testing

Clearinghouse:

• Drug & Alcohol Clearinghouse (FMCSA database)
• All violations reported
• Employers must check before hiring
• Annual query for current drivers

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Dispatcher Responsibilities:

Program Administration:

• ✅ Ensure company enrolled in testing consortium (if small carrier)
• ✅ Verify random testing conducted quarterly
• ✅ Maintain testing records (5 years)
• ✅ Report violations to Clearinghouse within 2 business days

Before Hiring:

• ✅ Check Clearinghouse for violations
• ✅ Obtain pre-employment test
• ✅ Verify previous employer testing history (3 years)

If Violation:

• ✅ Immediately remove driver from service
• ✅ Provide SAP resources
• ✅ Report to Clearinghouse
• ✅ Do NOT allow return until cleared

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Vehicle Inspections

Driver Vehicle Inspection Report (DVIR):

Requirement:

• Driver must inspect vehicle before and after each trip
• Report any defects or deficiencies
• Complete Driver Vehicle Inspection Report (DVIR)

When Required:

• Pre-trip inspection before operating vehicle
• Post-trip inspection after completing day's work

What to Inspect:

• Brakes: Function, air pressure, wear
• Lights: Headlights, taillights, brake lights, turn signals
• Tires: Tread depth, inflation, damage
• Steering: Function, play, alignment
• Suspension: Springs, shocks, airbags
• Horn: Function
• Windshield: Cracks, wipers, washer fluid
• Mirrors: Condition, adjustment
• Coupling: Fifth wheel, kingpin, airlines, electrical
• Cargo: Securement, weight distribution

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DVIR Process:

1. Driver Inspection:

• Conducts pre-trip inspection
• If no defects, marks "No defects" and signs
• If defects found, lists them on DVIR

2. Carrier Review:

• Motor carrier reviews DVIR
• Certifies defects corrected or notes vehicle does not need correction
• Signs DVIR

3. Documentation:

• DVIR kept in vehicle until defects corrected
• Original DVIR maintained by carrier for 3 months

4. Out-of-Service:

• If defect could affect safety, vehicle out-of-service until repaired
• Brake violations, lighting, tires, steering = common out-of-service defects

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Dispatcher Role:

Before Dispatch:

• ✅ Verify driver completed pre-trip inspection
• ✅ Check for open defects on vehicle
• ✅ Ensure defects corrected before dispatching
• ✅ Do NOT dispatch out-of-service vehicle

After Delivery:

• ✅ Review post-trip DVIR
• ✅ Address reported defects
• ✅ Schedule repairs as needed

Violation:

• Dispatching vehicle with out-of-service defect = $15,000+ fine
• Dispatcher can be held personally liable

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Cargo Securement

Federal Cargo Securement Standards:

Requirement:

• All cargo must be properly secured to prevent:
  • Shifting during transit
  • Falling from vehicle
  • Affecting vehicle stability

General Rules:

• Cargo must be restrained in all directions
• Working Load Limit (WLL) must be sufficient
• Proper tie-down devices (straps, chains, binders)

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Tie-Down Requirements:

Minimum Tie-Downs:

• Under 5 ft: 1 tie-down
• 5 ft to 10 ft: 2 tie-downs
• Over 10 ft: 2 tie-downs + 1 for every additional 10 ft

Working Load Limit:

• Total WLL of all tie-downs must be at least 50% of cargo weight
• WLL is marked on straps/chains

Examples:

• 10,000 lb cargo: Needs tie-downs with total WLL of 5,000 lbs
• 4 straps × 2,500 lbs WLL = 10,000 lbs total WLL = Sufficient

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Special Cargo:

Flatbed:

• Tarping required for weather-sensitive freight
• Securement varies by load type
• Coils, machinery, lumber have specific requirements

Oversized:

• Additional securement
• Pilot cars may be required
• Follow permitted route exactly

Hazmat:

• Specific placarding
• Segregation requirements
• Emergency response information

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Dispatcher Responsibility:

Before Dispatch:

• ✅ Confirm cargo weight and dimensions
• ✅ Ensure driver has proper securement equipment
• ✅ Verify driver knows securement requirements for load type

En Route:

• ✅ Remind driver to inspect securement after first 50 miles
• ✅ Remind driver to re-inspect every 150 miles or 3 hours

Violation:

• Improper securement = Out-of-service
• Fines: $500-$10,000
• Liability if cargo falls and causes accident

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Record Keeping Requirements

Required Records:

Driver Qualification Files:

• Application for employment
• MVR (Motor Vehicle Record) - annual
• Medical certificate
• Road test OR equivalent
• Drug/alcohol testing records
• Previous employer inquiries
• Annual review of driving record

Vehicle Maintenance:

• Inspection reports (DVIRs)
• Maintenance and repair records
• Annual inspections
• Evidence of systematic maintenance program

Hours of Service:

• ELD or paper logs (6 months minimum)
• Supporting documents

Accident Register:

• All accidents for 3 years
• Details of accidents involving company vehicles

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Retention Periods:

Record Type	Retention Period
Driver Qualification File	3 years after driver leaves
DVIRs	3 months
Annual Vehicle Inspection	14 months
Maintenance Records	1 year + 6 months after vehicle leaves fleet
HOS Records	6 months
Drug/Alcohol Test Results	5 years
Accident Register	3 years
Employment Applications	3 years

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Audit Readiness:

Be Prepared:

• ✅ Records organized and accessible
• ✅ Files maintained up to date
• ✅ Missing records = violations

FMCSA Can Audit:

• With advance notice OR
• Unannounced (rare)

Dispatcher Tip:

• Set up filing system (electronic preferred)
• Regular audits of your own files
• Address gaps immediately

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Conclusion

DOT compliance is comprehensive—covering drivers, vehicles, operations, and recordkeeping. Successful dispatchers don't just react to compliance issues—they proactively maintain systems to prevent violations.

Key Takeaways:

Driver Requirements:

• ✅ Valid CDL with proper class and endorsements
• ✅ Current medical certificate (track expirations!)
• ✅ Drug/alcohol testing program compliance
• ✅ Driver qualification file complete and current

Vehicle Requirements:

• ✅ Daily inspections (DVIR) completed and reviewed
• ✅ Maintenance program documented
• ✅ Annual inspections conducted
• ✅ No out-of-service defects

Operational Requirements:

• ✅ Cargo securement proper for all loads
• ✅ HOS compliance monitored continuously
• ✅ Records maintained per retention schedules

Dispatcher Must:

• ✅ Verify driver and vehicle compliance before dispatch
• ✅ Never dispatch out-of-service vehicle or unqualified driver
• ✅ Maintain audit-ready records
• ✅ Create culture of compliance

"DOT compliance is not a checklist—it's a continuous process of monitoring, documentation, and improvement."

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Continue Learning:

• FMCSA Regulations
• Driver Qualification Files
• Understanding ELDs

Master DOT compliance to operate safely and legally. Continue your education at Carriversity.