How to Survive a DOT Random Program Audit

An auditor’s job is to see whether your random program is real, correctly rated, and documented. Here is what they ask for, the findings that sink programs, and how to be ready.

Audit checklist Records Defensibility
Why you

What triggers a review

DOT agency audits (for example an FMCSA safety audit or compliance review), new-entrant reviews, complaints, and accidents can all put your testing program under the microscope. You rarely get much notice — which is why an audit-ready program is one you keep continuously, not one you build in a weekend.

The ask

What auditors request

Policy

Your written D&A policy

A current policy covering the required elements, distributed to covered employees.

Selection

How draws were made

Evidence of a scientifically valid random method and the pool used for each selection.

Certificates

Selection records

A record/certificate for each draw showing date, method, and who was selected.

Notifications

Notice & testing

That selected employees were notified and tested (or a documented reason if not).

Results

Test results & handling

Results routed correctly through the MRO/DER, with refusals and positives handled per Part 40.

MIS & RTD

MIS and follow-up

Annual MIS data, plus return-to-duty and follow-up documentation where applicable.

Don’t get flagged

Findings that sink programs

No proof of randomness

Selections you cannot show were made by a valid random method — the single most common problem.

Rate not met

Fewer selections than the annual minimum, or all bunched into part of the year.

Missing records

No certificate for a draw, no proof of notification, or results that don’t reconcile with the MIS.

Related: How DOT random selection works · DOT MIS report guide · Recordkeeping guide

Keep an audit-ready program by default

Random Pool Manager logs every draw, notification, result, and roster change — so a program can be reconstructed end to end, not just summarized.

See Random Pool Manager