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Keith Johnson 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)

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Keith Johnson Regulatory Consultant

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  1. 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.

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

  3. =

  4. §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

  5. §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.

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

  7. Safety Management Controls

  8. OPERATING AUTHORITY #1

  9. §387.31 – MINIMUM LEVELS OF FINANCIALRESPONSIBILITY #2

  10. §390.19 – MCS 150 - MOTOR CARRIER ID #3

  11. Part 390.19 – MOTOR CARRIER ID REPORTEvery 24 months, according to the following schedule:

  12. §366.2 – BOC-3 FORM OF DESIGNATION #4

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

  14. 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

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

  16. VEHICLE LEASE AGREEMENTS (If applicable) #8

  17. POLICIES AND PROCEDURES THAT CONTRIBUTE TO SAFETY MANAGEMENT CONTROLS #9

  18. §390.15 – ACCIDENT REGISTER AND SUPPORTING FILES #10

  19. §391.51 – DQ FILE • Application • Employment verification • Road test • MVR (current & updates) • Annual review • Driver data sheet • Medical Examiner Certificate • Verification of NRCME #11

  20. §382 – RECORD OF DUTY STATUS OR #12 *Must retain records for 6 months

  21. §382 – DRUG & ALCOHOL PROGRAM • §301 Pre-employment • §303 Post-accident • §305 Random • §307 Reasonable Suspicion • §309 Return to duty • §311 Follow-up #13

  22. §40.111 – SUMMARY OF DRUG AND ALCOHOL TESTING #14

  23. §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

  24. ANNUAL INSPECTIONS § 396.17 OR #15c

  25. § 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

  26. CERTIFICATES OF QUALIFICATIONS OF INDIVIDUALS RESPONSIBLE FOR INSPECTIONS #16

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

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

  29. LOSS RUN REPORT #19

  30. 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

  31. BePrepared Be Honest Be Polite

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

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