What a Corrective Action Determination letter?

Many of my clients are undergoing USDOT safety audits which have resulted in a failed safety audit.  We are happy to have our friends at National Fleet Services LLC (www.NationalFleetServicesllc.com) help our client with providing the required written reponse to get out of "hot water" and to start rolling again.  I thought that I would share with you some of things I am seeing within my client's Federal Motor Carrier Safety Administration (FMCSA) determination letters that have determined to unacceptable within the the motor carrier's corrective action plans (CAP).

1. A copy of the company's writen Controlled Substance and Alcohol Testing Policy as required by 49 CFR Section 382.601(b).
2. Evidence that each driver received a copy of your company's written Controlled Substance and Alcohol Testing Policy as required by 49 CFR Section 382.601(d).
3. Evidence that all designated supervisors have received the required Supervisor Training as required by 382.603.
4. Copies of any pre-employment controlled substance test results on all drivers hired during the previous 365 days.  These test must be USDO compliant tests.
5. The list of motor carrier's drivers currently enrolled in the Controlled Substance and Alcohol Random testing program.
6. Provide a description of your company's random testing procedures if your company has an agreement with a consortium/third-party administrator (C/TPA) including:
   1. The name, address and telephone number of the consortium, collection facility, or site;
   2. Identify the designated employer representative that will be contacted by the consortium or service provider;
   3. Description of your system for contacting the driver(s) selected for testing and rules on what actions the driver should take once contacted;
   4. Describe procedures for updating the list of CDL drivers with the service provider.

 

So, ask you..... What Corrective Actions should you be taking?  What has been your experience with the FMCSA audits during the past 6 months and since CSA has come into our lives?