The short version
- Classify every role: DOT-covered, policy-covered, or not covered
- Write the policy down, have it reviewed before enforcement, and keep each driver's signed certificate of receipt (49 CFR 382.601(d))
- Name your DER: an employee of the company, never a service agent (49 CFR 40.3), and make sure they know it
- Run the previous-employer inquiry and the Clearinghouse query on every new driver before the first safety-sensitive function (49 CFR 40.25, 382.701)
- Set up random pools, collection logistics, and supervisor training (49 CFR 382.305, 382.603)
- Keep every record an auditor could ask for, for the period 49 CFR 382.401 requires
