Mock CVOR Facility Audit
When it comes to a Ministry of Transportation of Ontario (MTO) CVOR Facility audit, yes, when the officer comes to your door, there are just three main things that they are going to be looking at. Yes, merely three categories. And they are Maintenance, Driver Files and Hours of Service.
That is it, just three. It sounds like to prepare for an audit; it would be simple and easy.
But it is not! It is difficult because of all the detail that the Ministry of Transportation of Ontario (MTO) will be looking for. Yeah, details. So in the article, we will go deep into each of the three sections and discuss the typical pitfalls that other trucking companies get into trouble with. In this way, you can prepare for an audit and avoid similar aggravation.
How important is it that you PASS an MTO Facility Audit? With trucking insurance getting tougher and tougher, it is complicated, and some would say impossible, to get trucking insurance with a "Conditional" rating. How to you get a conditional rating? There are a couple of ways, but the one that this article is concerned about is a "Fail" score on the audit. That will absolutely get you a "Conditional" Rating. Failure to Pass a Ministry of Transportation of Ontario (MTO) Facility Audit will guarantee you a CONDITIONAL Rating. This is something to be avoided.
So let's dive into the three pieces of an MTO Facility Audit.
Vehicle Maintenance for the Ministry of Transportation of Ontario (MTO)
The way that the MTO does their audit, Maintenance is broken down into four subcategories. They are DR&R, PM, Annual, Semi Annual, and Records.
DR&R is an acronym for Detection, Reporting and Repair.
Detection, this is for the drivers mostly. Detection really comes down to this, "Are the drivers performing their Daily Vehicle Inspections and can you prove it?" You need to be able to provide to the MTO officer the "Daily Inspection Reports." You may also need to show that in each truck, you have the appropriate "Schedule" in the vehicles.
Do you have all of the Commercial Vehicle Inspection Reports (CVIR). These are the forms generated by the inspection officers at the scales during a scale inspection. Did the driver hand it into you, and did you file it so that you can find the report when needed?
Were there any defects noted in the report? If so, you will likely need to show the officer the repair work order or the repair invoice.
If the equipment was allowed back on the road before being repaired, you would lose points.
Now the officer will be reviewing your records, work orders and invoices. If they don't have the appropriate information on them, points again will be deducted.
Below are the areas for DR&R that points will be deducted.
1 Are the inspections being performed by the appropriate person?
2 Collect all the CVIRs
3 Repairs performed before the vehicle is back in service
4 Information missing on your records
Preventative Maintenance (PM)
Enter your text here...
Are you doing your preventative Maintenance, and can you prove it? You need to have proper records and documentation. You also need to have your PM in writing.
So here is the process. The officer takes your Maintenance interval and reviews a sample of your files. The officers are looking to ensure that you are inspecting the equipment at least as often as you say in writing that you are. If you are not, then you are going to lose points.
Next up in the Maintenance area are your Annual or Semi-Annual Inspections. In trucking, the law usually requires annual inspections. In the transportation of people, it is typically Semi-Annual inspections. (Find out what you are required to do.)
The auditor is looking to see if you operated any of your equipment on the road with an expired Annual or Semi-Annual. If you did, here again, you will be deducted points.
Last up in the Maintenance section is "Records." There are four areas that the officer will be reviewing, and these are generally easy for you to comply with.
1 Is your PM in writing?
2 Are your records and reports kept at your offices?
3 Are your records and reports being kept for two years or six months after the equipment has left your company?
4 Do your records and reports contain the correct information such as Date, Odometer reading etc...
The maintenance area is 100 possible points.
QR&R or Qualification Records and Reporting
This area of the Audit is focussing on Driver Files. The driver files need to have certain documents and information contained in them. Again QR&R can be divided into 4 main areas. Qualification, Driver Abstracts, Conviction Records, and Collisions.
Well for the area of "Qualification" you will need:
1 You need to have a copy of a "Valid Driver Licence." A photocopy of the driver's licence (both sides) will do as long as it has not expired.
2 You need to make sure that the driver has the proper class of license for the equipment that they are operating. Yes, I know that when you hired the driver, they had the correct class of licence, but things happen, and if the driver makes a mistake with the Ministry, their class can get changed.
3 You will need to prove that the driver has the proper endorsements for the equipment that they are operating. For example, if the driver is operating a truck with airbrakes, the driver must have an airbrake endorsement.
4 If you are hauling Dangerous Goods, then you will need to prove that you are training he drivers at least every three years. Keep a copy of the training certificate in the driver file.
You need to have a copy of the driver abstract in the file that is not older than 12 months. I would recommend that you have a copy of both the Drivers CVOR abstract and the three-year Abstract. (Having both is not required for the Audit, it is a recommendation only.)
You need to be able to demonstrate that you know about all convictions for the last 24 months. It is recommended that you take action regarding any conviction that happened in your equipment. You do need to know about all convictions, including those that occurred in a driver's personal vehicle.
For the collision section of the Audit, the Officer will be looking to see if you know about the accident and what action was taken by the company. Generally, action taken is referencing the company issuing a letter to the driver and any action taken by the company to discipline or re-train the driver.
This driver file section is also worth 100 points.
Hours of Service
The last area for the Audit is Hours of Service.
If you are using paper logbooks, this might be the most difficult area to review in house. If you are using Electronic Logging Devices in your trucks, generally, it is easier for you to review. Either way, the Officer will be going through your Hours of Service very carefully. This is often the area that companies fail.
What is the Officer looking for? They are looking at the 13, 14 and 16-hour rules. Has the driver violated any of these? How does the Officer do this? They will be asking for receipts, such as fuel, tolls, or anything that can place the driver on the road. They will then compare these time markers to the logbook. Any error that is greater than 15 minutes will be an infraction.
The Officer will also be looking at the 70 hours in 7 days and the 120 in 14 days rules. Again any violation greater than 15 minutes will be taken into account and will count as an infraction.
If any logs are missing, they will be scored as missing. If the Officer finds a "False" record and if the time difference is greater than 2 hours, then the time will be doubled.
Hours of Service is a maximum of 100 points.
In conclusion, all three sections (Maintenance, QR&R, Hours of Service) must be passed with a score of at least 50% each, and the Overall Score for the Audit must be 55% or higher.
If you fail, then your rating will be "Conditional." But "Pass," and you will receive either "Satisfactory."
What happens if you fail? The repercussions vary by whom you ask.
Ask your insurance company. Your insurance company will likely take a dim view of a "Conditional" rating. Some insurance companies refuse to off coverage to a company with a conditional rating.
Ask a shipper. Some shippers will not ship with a company that has a Conditional rating. Why? With lawsuits often naming shippers, they might be afraid to use a carrier with less than a Satisfactory rating.
Ask the Ministry of Transportation of Ontario (MTO), and again, the answer depends. It depends on your Overall Violation Score, the number of your collisions and convictions.
If you have any questions, please reach out. I would be happy to help and answer your questions.