Motor Carrier Health and Safety Policy Review

The policy must be signed and dated by the highest-ranking officer accountable for safety — typically the President, COO, or designated Safety Director listed on the MCS-150. A stale signature from a departed executive is a common audit finding during an FMCSA Compliance Review.

Policy text should commit the carrier to comply with 49 CFR Parts 380, 382, 383, 391, 392, 395, 396, and 397 where applicable to operations. Hazmat carriers add Parts 100–185. Generic 'comply with all applicable regulations' language fails a CR-2A scoring review.

Record version number, effective date, and superseded version. Keep prior versions for at least 3 years per general FMCSA recordkeeping practice — auditors will ask which policy was in force on the date of a specific incident.

Every CDL holder, owner-operator, and yard driver signs the acknowledgment and the form goes in the DQ file. Tenstreet or DriverReach can route the acknowledgment electronically. Drivers on extended OTR runs get the form via the ELD message inbox (Motive, Samsara) with a return deadline before next home time.

Pull the open list, escalate to driver managers, and hold the next dispatch until the acknowledgment is signed. A driver hauling without a current policy acknowledgment is a finding in the Driver Fitness BASIC during an audit.

Cross-check the Training Provider Registry against new CDL hires from the past 12 months. Entry-Level Driver Training certificates must precede the CDL skills test; missing ELDT is a disqualifier for the driver and a Part 380 violation for the carrier.

Topics should rotate through HOS / ELD edits, cargo securement (Part 393 Subpart I), winter driving, and post-accident procedures. Record attendance — a meeting with no sign-in sheet did not happen as far as a plaintiff's attorney is concerned.

Driver lounge bulletin board, dispatch window, and shop entry. Photo each posted copy and file the photos with the audit packet — proves accessibility at every reporting location, not just headquarters.

Upload the current PDF to the Motive, Samsara, or KeepTruckin driver document library so it's reachable from the tractor. Owner-operators dispatched through the TMS (McLeod, Truckbase, AscendTMS) should see the same link in their carrier portal.

Replace the policy section in the orientation packet given to every new hire. Old handbooks circulating during onboarding contradict the current policy and create training inconsistencies that surface during incident investigations.

Check the MCS-150 contact and the Drug & Alcohol Clearinghouse designated employer representative (DER) — both should match the current Safety Director. Mismatches block Clearinghouse queries and delay pre-employment screening.

Name which dispatcher reviews prior-day ELD exceptions (11-hour, 14-hour, 30-minute break, 60/70-hour) every morning, and document the edit-and-annotation workflow. Unreviewed HOS violations drive CSA HOS Compliance BASIC scores and are a top FMCSA audit finding.

Confirm line items for A/B/C preventive maintenance services, annual DOT inspections, drug & alcohol consortium fees (Foley, J.J. Keller, USA Mobile Drug Testing), MVR pulls, and Clearinghouse query subscription. A policy with no funding is a policy on paper only.

Pull current Safety Measurement System scores for Unsafe Driving, HOS Compliance, Driver Fitness, Controlled Substances/Alcohol, Vehicle Maintenance, and Crash Indicator. Set targets below the intervention threshold (65% for most BASICs, 60% for HOS and Unsafe Driving, 80% for hazmat).

Express as DOT recordables per million miles. Industry benchmark for general freight runs around 0.7–1.0; tanker and hazmat carriers typically target tighter. Pull crash data from the FMCSA Crash Preventability Determination Program where applicable.

FMCSA minimums for the calendar year: 50% drug rate, 10% alcohol rate of average driver count. Run the math now — if Q3 selection counts trail the pace, the consortium needs to bump Q4 selections before December 31 to avoid a Part 382 violation.

Targets that aren't visible aren't tracked. Post in the TMS dashboard (McLeod LoadMaster, Tailwind) or a shared safety scorecard. Monthly review with the Safety Director and Operations Manager keeps drift visible early.

Pull 10% of active driver files or 30 files, whichever is greater. Check application, annual MVR, medical certificate, road test certificate, previous-employer inquiries (Part 391.23), pre-employment drug screen, and annual Clearinghouse query. Missing inquiries from the 3-year DOT-regulated employment history is the most common DQ finding.

Walk every recordable crash, roadside OOS, and cargo claim from the prior 12 months. Look for patterns — same lane, same shipper, same terminal, same equipment age. Pattern findings reshape next year's training calendar and PM schedule.

Each finding gets an owner, a due date, and a verification step. Track in the safety management system or a shared corrective-action log. Open items from last year's review that are still open is itself a finding worth closing first.

• Driver-level findings: schedule re-training and document.
• File-level findings: complete the missing record within 30 days.
• Program-level findings: revise the SOP and re-issue the policy.

Safety Director and accountable officer both sign. File the review packet — signed policy, acknowledgment roster, posting photos, audit results, corrective action log — in the safety records archive. This packet is the first thing an FMCSA investigator asks for in a Compliance Review.