, Before, During, and After an Audit, ICC Compliance Center Inc - USA

I have had the “privilege” of going through two DOT audits. I believe that no matter how prepared you are, they are still nerve-racking…what will they find? Did I miss something? What you might not believe is that the auditor is on the same side as you – the safety side. 

Your company will likely be a target for an audit if:

  • There has been a compliant
  • You ship something high risk (i.e., PIH material)
  • Incident history
  • You are registered with the DOT
  • You hold a special permit or competent authority approval

How can you prepare for them just in case?

Keep good records – either virtual or paper. Make sure everything is identified by the “DOT name.” For example, if you do security training as part of your employee orientation, make a note that the record for security awareness training is in the employee orientation folder. Items that should be included in this recordkeeping include, but are not limited to:

  • Training records (make sure they are up to date)
  • Registration per 49 CFR Part 107.601 (if needed)
  • Previous inspection reports/exit interviews
  • Special permits or competent authority approvals
  • Security plans
  • M-Number
  • RIN or CTN if applicable
  • Shipping papers
  • Packaging
    • Closing instructions
    • Tools used

When the inspector arrives, expect to have an introduction meeting. In the meeting, they will identify key individuals, gather a company profile, walk through the facility, look at stock, and review various documents.

The top violations during the audit include:

  • Training records
  • Packaging closure
  • Security plans
  • Shipping paper retention
  • Shipping paper sequence (ISHP)
  • Cylinder record keeping

Once the audit is complete, they will meet to do an exit interview. During the exit interview, they will review any probable violations and request a signature. The signature must be from a high-ranking officer of the company. 

If you have probable violations, you will have 30 days to respond. At that point, the Chief Inspector will determine what “punishment,” if any, will apply.

Get organized now! Don’t wait for the auditor to show up. Need help getting started? ICC can help.

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Karrie Ishmael, CDGP

Karrie Ishmael, CDGP

Karrie Ishmael has been with ICC since 1988. She has contributed to ICC's growth in various capacities, including customer service, sales, and marketing. In her current role as ICC's Senior Regulatory Expert and SDS author, Karrie conducts hazardous materials training classes in 49 CFR, IATA, IMDG, TDG along with OSHA and WHMIS hazard communication courses. When not training, she writes safety data sheets for customers to comply with North American and European requirements. She actively participates in many associations, including DGAC, COSTHA and is the former chair of SCHC’s OSHA Alliance Committee.