Skip to main content

PSI is a family-owned New Jersey company that serves hundreds of clients across transportation, education, government, and industrial sectors, with testing programs covering nearly 15,000 safety-sensitive workers.

PSI Prevention Specialists
Schedule Call

Checklist

The DOT audit readiness checklist

An audit is a records exercise: the auditor asks for documents and checks them against the rule. FMCSA can ask to see them at your principal place of business within two business days (49 CFR 382.401(d)). Walk this list against your own files today, with the retention period the rule sets beside each item. Anything that takes more than a few minutes to find is worth fixing before an auditor asks for it.

  • 49 CFR 382.401
  • 49 CFR 382.403
  • 49 CFR PART 40
  • RECORDKEEPING

The written program

  • A current written drug and alcohol policy with the content 49 CFR 382.601(b) requires, including the alcohol thresholds and consequencesKeep: 5 years as a program-administration record
  • The signed certificate of receipt from every driver, original on file (49 CFR 382.601(d))Keep: While the driver performs the function, plus 2 years
  • The name of your Designated Employer Representative in writing: an employee of the company, never a service agent (49 CFR 40.3)Keep: 5 years
  • Written agreements with your collection sites, laboratories, MRO, consortium, and other service agents (49 CFR 40.11(c), 382.401(c)(6))Keep: 5 years
  • Evidence that DOT and non-DOT testing are kept completely separate: separate pool rosters, and non-federal forms for every non-DOT test (49 CFR 40.13)Keep: With the program records

The random pool

  • Documentation of consortium membership or pool administration, and the rate the pool tests atKeep: 5 years
  • A pool roster that matches your actual covered roster today, with only covered employees in it (49 CFR 382.305(j))Keep: 2 years per selection period
  • Selection lists for every period, showing selections unannounced and spread reasonably throughout the calendar year (49 CFR 382.305(k))Keep: 2 years
  • Evidence each selected employee was notified and proceeded to collection immediately (49 CFR 382.305(l))Keep: 2 years

Testing records

Keep test records in a secure location with controlled access (49 CFR 382.401(a)).

  • Pre-employment verified negative results on file before each driver's first safety-sensitive function (49 CFR 382.301(a))Keep: 1 year for negatives
  • Custody-and-control forms for collections, complete and legible, on the Federal formKeep: 1 year for negatives and cancelled tests; 5 years for verified positives and refusals
  • MRO-verified results, including the drug named on any verified positive (49 CFR 40.163)Keep: 5 years for verified positives and refusals; 1 year for negatives and cancelled tests
  • Documentation for every reasonable suspicion and post-accident decision, including decisions not to test, the supervisor's signed written record within 24 hours (49 CFR 382.307(f)), and the two-, eight-, and thirty-two-hour records (49 CFR 382.303(d))Keep: 2 years as collection-process records; 5 years where a violation resulted
  • Split-specimen requests and the results of any split test (49 CFR 40.171)Keep: 5 years with the verified result
  • Shy-bladder medical evaluations and the MRO's determination (49 CFR 40.193)Keep: 5 years where a refusal resulted; otherwise 1 year

The alcohol program

  • Employer copies of the alcohol testing forms, with resultsKeep: 5 years for results of 0.02 or greater; 1 year for results under 0.02
  • Proof each evidential breath testing device is on the DOT-approved list (49 CFR 40.229), plus its calibration and quality-assurance records (49 CFR 40.233)Keep: 5 years
  • Training records for every BAT and screening test technician (49 CFR 40.213)Keep: While the person performs the function, plus 2 years
  • Records of any driver kept off safety-sensitive duty under the 24-hour rule when an alcohol test could not be done (49 CFR 382.307(e))Keep: 2 years

Previous-employer inquiries

  • For every driver hired since 2020: the driver's written consent and your inquiry to previous DOT-regulated employers for the prior two years, obtained within 30 days of the first safety-sensitive function (49 CFR 40.25)Keep: With the driver's records
  • For FMCSA-regulated previous employers the Clearinghouse full query satisfies this since January 6, 2023; for previous employers under other DOT agencies, the written inquiry and its response (49 CFR 391.23(e))Keep: With the driver's records

Training

  • Supervisor reasonable-suspicion training certificates: at least 60 minutes on alcohol and 60 minutes on controlled substances (49 CFR 382.603)Keep: While the supervisor holds the role, plus 2 years
  • Records of the educational materials distributed to drivers and the training of anyone else the rule requiresKeep: While the person performs the function, plus 2 years

Clearinghouse

  • Pre-employment full query for every driver, with the driver's specific consent, before the first safety-sensitive function (49 CFR 382.701(a))Keep: 3 years; a valid registration satisfies this
  • Annual queries on every driver, and the driver consents for any limited queries, with a full query within 24 hours wherever a record existed (49 CFR 382.701(b))Keep: 3 years
  • C/TPA designation documented (required for owner-operators, 49 CFR 382.705(b)(6))Keep: 5 years
  • Every violation, negative return-to-duty test, and follow-up completion reported within three business days (49 CFR 382.705(b))Keep: 5 years

Annual summaries

  • A copy of each annual calendar-year summary, and the MIS report for any year FMCSA selected you (49 CFR 382.403)Keep: 5 years

Print this page and walk it through your file cabinet; it is designed for that. The retention periods are the minimums in 49 CFR 382.401(b); many employers keep everything five years for simplicity. If items came up empty and you want them fixed before an auditor finds them, that is ordinary work for us: schedule a call or phone 732-869-2900.