Case study · New Authority
A new authority went from no systems to audit-ready in 60 days.
A Texas-based refrigerated OTR new entrant reached us at month 9 of its new-entrant period with no written safety management plan, no documented drug-and-alcohol program, an incomplete drug-and-alcohol consortium enrollment, and DQ files in three different formats. The 12-month FMCSA audit was scheduled. Sixty days later the carrier passed on first attempt.
Texas new entrant · 14 power units
New-entrant safety audit
PASSED
on first attempt
- New-entrant safety audit passed on first attempt
- Written Safety Management Plan stood up from zero
- 14 DQ files rebuilt to 49 CFR Part 391
- Drug-and-alcohol consortium enrolled; pre-employment + Clearinghouse queries reconstructed
The problem
The problem.
The owner was driving and dispatching simultaneously. Safety was being handled as exception-based phone calls, not as a documented program. The carrier did not know that the new-entrant audit examines whether the safety management controls are in place — not whether the carrier had any incidents. Without remediation, the audit would have been a downgrade for documentation alone.
Diagnostic
What we found in the diagnostic.
No written SMP. No documented internal audit cadence. No accident register.
DQ files in three different formats; 6 of 14 had at least one Part 391 deficiency.
Drug-and-alcohol consortium enrolled but no documented pre-employment queries on file for 4 drivers.
No HOS records review process; ELD compliance unconfirmed for 2 trucks.
What we did
What we did.
- 01
Authored the SMP and ancillary documentation
Written Safety Management Plan, accident register, drug-and-alcohol policy with Clearinghouse procedure, vehicle maintenance program, and an internal-audit cadence — all in 14 days, all signed by ownership.
- 02
DQ-file rebuild + missing-record reconstruction
Every Part 391 deficiency closed. Pre-employment Clearinghouse queries reconstructed from records. Annual MVRs and MECs verified through state and the National Registry.
- 03
Pre-audit dry run two weeks out
A consultant ran the same audit FMCSA would. Two minor findings remediated within five days. Live attendance at the actual audit.
Results
Results at the audit.
- New-entrant audit outcome
- PASSED
- Audit findings (FMCSA)
- 0 critical, 1 minor
- DQ-file Part 391 deficiencies
- 6 → 0
- Days from intake to audit
- 60
- Authority status post-audit
- Permanent (no downgrade)
They walked the auditor through every record before the auditor asked. We thought we had a program. After this we actually do.
Lead consultant
InfoMax compliance team — Naperville, IL
Related programs
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