Webinar Transcript: Recordkeeping Secrets for Your Drug & Alcohol Testing Program

Below is a full transcription of our popular webinar on Drug & Alcohol Testing recordkeeping requirements and tips called “Recordkeeping Secrets for Your Drug & Alcohol Testing Program.”

Hello everyone. And welcome to Foley’s Drug and Alcohol Testing Program Recordkeeping webinar. I can see people logging in, so thank you for joining us today. We are going to wait about 60 seconds for everyone to get into the webinar and then we will begin. So again, if you’re just joining, this is Foley’s Drug and Alcohol Testing Program Recordkeeping webinar. Thank you for joining us today. We look forward to going through this content. We are going to wait just 30 more seconds and make sure we have all of our registered participants joining today, and then we will get started, so thank you again for your patience. 

Okay, so let’s get started. So, we are here today to talk about Drug and Alcohol Testing Program Recordkeeping, so thank you to everyone who has logged in and is joining us.  

We are going to run through this content to try to share information and provide best practices for companies regulated by the Federal Motor Carrier Safety Administration in the execution of their drug testing program and how to make sure that you stay on top of running that program and your associated DOT Clearinghouse requirements to ensure that you’re ready for audits.  

So, first I’ll introduce myself. My name is Scott Mogensen and I’ve been with Foley for over 15 years. And specifically, I work with a number of companies that run drug and alcohol testing programs, especially those regulated by the Department of Transportation. So, it’s always a pleasure to get to talk with carriers and other industry partners that have the need to prepare themselves for DOT compliance purposes. So, I definitely want to thank everybody for joining so we can run through this today together. 

Program Basics: Who Must Comply? 

So, let’s start with some of the basics of an FMCSA drug testing program and make sure that we’re covering exactly what we need to be today. So, first off again, we’re going to be talking specifically about motor carriers that are falling under 49 CFR Part 382. That’s the Federal Motor Carrier Safety Administration’s drug and alcohol testing requirements. And those apply to any employer who has CDL drivers who operate vehicles that have a gross vehicle weight rating of 26,001 pounds or greater, or who transport 16 or more passengers. And that would be where the vehicle is designed for 16 passengers, including the driver. And then, any vehicle that is requiring placarding because they’re carrying a quantity of hazardous materials that require a placard to be placed on the vehicle. Those would be the definitions of what a vehicle would be that falls under the DOT’s drug-testing program. And essentially, if that driver is employed to drive that vehicle, they have to participate in the drug-testing program. 

Two Key Regulatory Requirements 

There are numerous requirements within the FMCSA’s drug testing regulation. Most of them are probably familiar to those companies that do employ drivers in this space. But certainly, there has been some change there in the past couple of years as the DOT drug testing regulation for Federal Motor Carrier Safety Regulated companies has expanded to include this new sub-component of a DOT drug testing program, which is the DOT Clearinghouse. So, in addition to all of the standard compliance requirements of a DOT drug testing program, there is now DOT Clearinghouse requirements where carriers need to upload violations into this centralized government database, as well as query the Clearinghouse to ensure that their drivers have no prohibited conduct, which has been uploaded in the past through other employers or companies that they applied to drive for. 

Testing Overview 

So just to give a quick overview. We have obviously some of the key components of the standard drug testing program here, which is compliant with Part 40, which is shared with all of the other modes of the DOT. Some of the key components are obviously that a company must be running pre-employment drug testing to ensure that none of their drivers get behind the wheel and begin operating a vehicle in safety sensitive capacity without the pre-employment drug test already having been returned as a negative result showing that that driver is not prohibited from driving. Additionally, you have to run a random drug testing program to ensure that there are deterrents for existing employees, and that there is an unannounced program of random testing, which can apply to any driver in a safety-sensitive capacity. 

Furthermore, there’s incident testing related to either post-accident or any incidents of reasonable suspicion where a trained supervisor might identify an employee displaying signs and symptoms of potential impairment and then there’s procedures for testing that individual to rule out the possibility of them being impaired. And further, there has to be a return to duty and follow up program in place, which complies with the DOT’s requirements, if a company chooses to allow in their policy for individuals to return to duty following a violation of some kind. So, those are probably pretty familiar to companies running DOT drug testing programs, but if not, certainly, I’d advise you to talk with an expert and try to get information on ensuring that your program does comply with DOT’s requirements. 

Clearinghouse Overview 

And additionally, as we mentioned, the DOT Clearinghouse was added to the FMCSA drug testing program recently as an additional requirement that just went into effect at the beginning of 2020. So specifically on January 6th, 2020, this new regulation went into effect and became enforced, which essentially means that all employers of CDL drivers must now be running pre-employment queries on all new hires and reporting their violations into the Clearinghouse upon receipt. So specifically, the medical review officers that companies employ are reporting up the drug tests, and employers have to report the alcohol and actual knowledge violations as well as refusals which would occur and make sure those violations get into the Clearinghouse so that the database is filled with any violations which have occurred on CDL drivers. 

 And that’s meaningful because employers are now required to run limited annual queries on each driver that they have in a safety-sensitive capacity over the duration of their employment. So at least every 12 months, an employer has to check the Clearinghouse to make sure that their driver has no violations which have been submitted in there. And that basically validates that their driver is safe and qualified to drive. And that there’s no prohibited conduct, which might have been uploaded by another employer or by a company where your driver might have applied to work, but never actually taken a job. So by now, in order to complete all these requirements, each company that does employ CDL drivers should have a Clearinghouse account registered. You should have activity because obviously it’s been enforced for more than a year, so any new hires which you’ve had, or at least any of your existing drivers, you should have some annual query activity on them by now. So, that’s important because auditors are enforcing this now. 

Enforcement Action (DOT Enforcement)   

Now that it’s been in place for more than a year, we should see things like registration for employers because by now every CDL-employing company would have had to at least run annual queries, if not pre-employment if there had been hiring. These pre-employment and annual queries should be performed and there should be a record of them, and they should be performed on the appropriate timeline. So that means, you would do a query before you hired a new employee and they started, or the annual queries should be run at least every 12 months. In fact, not more than 12 months should elapse between queries. And then any violations which you have been made aware of from either refusals happening or alcohol testing results or the drug tests associated with your employees, should be reported into the Clearinghouse. 

And all of this is now enforceable, and there is a centralized database, which the auditors have access to. So, you want to ensure that you’re complying with these requirements because obviously it’s very cut and dry and easy for enforcement officials to determine if that information is making it into the Clearinghouse and if the required steps are being done when they’re supposed to be. 

Consequences of Non-Compliance 

And that’s important because there are significant consequences now to non-compliance. Just recently, the FMCSA did publish updates to their fine requirements for certain instances of non-compliance and the Clearinghouse was one of them. So, non-compliance with a Clearinghouse requirement could result in a fine of $5,800 per violation. That’s pretty significant, and obviously, we want all carriers to be aware of that because complying with the Clearinghouse is not all that difficult if you have a good program in place and you run it with a trusted partner. But certainly, not taking required action could result in some substantial penalties as you see here. 

DOT Recordkeeping Basics 

 Okay, now let’s get into DOT recordkeeping basics. So in this section, what we really want to talk about is what are the steps that you as an employer need to undertake to ensure that you’re keeping the required records that will be necessary to prove your compliance during a DOT audit. And that’s going to be really important here because as we look at the industry, a key fact to point out is that the majority of DOT violations resulting from audits and enforcement actions come from recordkeeping violations. And what that really speaks to is the fact that certainly, records are the proof of the steps that you take in order to comply. 

So if you run a drug-testing program, as an example, you might be doing everything that you need to be doing, but if you have no records to prove that you took the required steps, or your records aren’t in a state where you can easily display for an auditor that you did everything you were supposed to do, you could still get a violation or fine as a result of you not having the evidence to show that you took the right steps. So, that’s really what we want to try to avoid and what we want to talk about in terms of what are best practices and what should you be thinking about when you review what your current company actions are on this front. 

FMCSA Recordkeeping 

So, just to start with some of the basics.   

Certainly, the DOT has requirements in place around the type of records that you need to keep. These would be the things related to the safety programs you run, your compliance steps, and certainly the evidence of your insurance and financial responsibility. So, there’s a pretty good description of what needs to be stored and what needs to be on file.  

Now, another requirement that you’ll see in the regulations is certainly related to security and the protection of that information. The DOT won’t necessarily tell you where to store your documents, but they will say they have to be stored in such a way that personal information, which could be contained within it, is not just kind of public information for those who work in the company. And rather, only those with a need to know have access to these documents and these records. And certainly, that’s a best practice beyond just DOT compliance. 

If you have personal information related to your employees, you don’t want that to be something that is easily accessible to anyone. You’d rather it be restricted and secured such that only the right people within your organization that have a need to know can get to that information. And finally, one other point that’s worth noting, is that there is a timeliness requirement in DOT regulations. So specifically, if a DOT auditor or authorized individual requests information from you; the requirement is you need to be able to turn that request around and get them back the information that they’re looking for within 48 hours – which could sound like a long time to some people. But bear in mind, you don’t necessarily know what the request is going to be or when it’s going to come in. 

We see a lot of carriers struggle with this, and the reason is quite simply that the audit could be very targeted and maybe there’s been some type of incident with a certain individual, they got into an accident or something along those lines. The DOT may want to see very specifically, you know, show me the files on this person, or conversely, it could be a very broad request. They might come back and say to you we want to see all your records related to the hiring that you’ve done over the last 24 months. So every employee that you’ve hired, which could be a long list or a short list, but basically it could span a wide range of documents and getting all of that together, especially if your filing system looks something like the picture you see here on the screen, could be challenging because a lot of carriers don’t necessarily think about how they’re storing documents. They know they’re taking the steps that are required, but where those records are, and in what state they are in, may not be a top concern until you get a request in from the DOT and then you’re scrambling. 

We want to prevent that, and that’s one of the reasons we wanted to have this webinar today because we see a lot of change happening in the industry, and we want to make sure that we talk about what some of the best practices are to help companies deal with the requirements around what they have to keep, where they have to keep it, and how fast they need to be able to turn it around. 

Record Retention Rules 

Some basic rules here to keep in mind is that, as the world goes more digital, so too the DOT is going digital, and we are seeing a rise in offsite audits and the requirements to have information protected in such a way that it’s both secured against physical damage, and it can be uploaded quickly in the event of an offsite audit. So as you think about transitioning away from a paper process into a digital process, that’s definitely something to bear in mind that it should be done correctly and documents have to be stored so that they’re legible. Certainly, they need to be able to be authenticated as true and original. If you do scan the originals up and you retain a copy of that original, you know, a lot of companies don’t necessarily retain the physical copy. And then specifically, there are retention requirements around different categories of documents, and those are going to be important to know, so that you’re retaining documents for the minimum required amount of time, based on what that record is. And we’ll have a list here in a second of what some of the common ones are, but you’ll see they vary based on what they are. Knowing what those retention periods are is important, and even better would be a situation where your filing system and the tool you use to store your records is aware of those retention requirements and manages it for you to ensure that you’re not discarding a record too soon, and that you’ve kept it for the required retention period and alerts you to that process. 

Retention Requirements: DOT Drug and Alcohol Testing 

So, as I mentioned in the world of DOT drug and alcohol testing, there are a number of documents that you have to retain. So custody and control forms, the chain of custody form that a drug test may be conducted on is going to be a record that you have to retain. And depending on whether the result is negative or positive, could mean the difference between having to retain that record for one year (in the case of a negative) to five years in the case of a positive. Similarly are violations like refusals or testing following a violation like return-to-duty or follow-up testing; these are records that you have to retain for five years. But in addition to that, there’s records like your semi-annual laboratory statistics, which may be sent to you from the laboratory. Or your policy and educational materials that you are required to share with your employees to make them aware of their requirements. 

These are requirements that you need to be able to prove to an auditor that you’ve taken these steps. That you’ve shared the policy with your employees. You’ve gotten the acknowledgment form signed off to ensure that your employees are aware of what the program requirements are. You want to ensure that you have reasonable suspicion training, if that’s something that’s required for you. If you’re a carrier of the size that you require reasonable suspicion training, and you have employees, you’re going to need to ensure that you have documentation that the supervisors who supervise regulated employees have gone through reasonable suspicion training. 

So certainly, there are a number of requirements you see here, and even after this webinar, if you have further questions on specific documents or documents beyond the scope of DOT drug testing and other areas of DOT enforcement, we’re more than happy to help and share information and provide citations for specifically what the retention periods are and how you can know how long you have to keep each document. But I think the important takeaway here is that these documents are going to be varied and they’re going to be different, and there’s a number of them. So, you want to make sure you have the required steps in place for each and every one of them from your random selection list to the qualifications of the people performing the collections, which of course can be maintained for you by your third-party administrator, which is a big advantage of using a third-party administrator. 

Retention Requirements: DOT Clearinghouse 

And then furthermore, new requirements are coming into play such as the DOT Clearinghouse requirements. You need to be able to prove that you have certain documents or records, like you’ve proven that you’ve done the annual queries or the pre-employment queries that are required for hiring and for your existing employees. And furthermore, in order to run those limited queries on an annual basis, you need consent which is stored outside of the Clearinghouse. It’s a consent form that you would provide to your employees to ensure that they are giving you the authorization to run their information from the Clearinghouse. All of these records have to be stored for a minimum of three years and retained by you as the employer. These are new requirements that are coming into place just within the last couple of years here. And it’s important that you stay on top of that. 

Important Consent Reminder 

So again, we do hit on the point of the limited query consent because that one obviously is new and it’s one we’ve seen a lot of carriers struggle with. As you saw in the previous slide, that’s something that you have to retain for three years. You have to have this consent outside of the Clearinghouse – so in essence, the Clearinghouse isn’t going to manage that consent for you. But furthermore, ideally, you should really have this consent form, which we would recommend you use an expert, whether it’s your HR, your legal team, or a trusted industry partner, to review. But we would recommend that you have it written up to give you the authorization to run limited queries on your employee for the duration of the time that they’re employed with you, which hopefully is a long, prosperous period of time. 

But if that’s the case, and you have a driver driving for you for 25 years, you’re really going to want to maintain that document for all 25 years, because you want that to be your proof that yes, this employee did provide me the authorization and the consent to go ahead and continue to their Clearinghouse record year after year. So, that’s an important call out because while there are certain minimums in the document requirements, that’s an important one that you want to have stored and you want to make sure you retain it for the right period of time. 

Why Paperwork Management Matters

Let’s talk about why the management and the execution of these requirements we’ve been talking about matter. And I’ve alluded to a couple points along the way, but certainly one of the things that you want to be aware of is that if you don’t have your paperwork in order, you can run into some sticky situations with DOT audits. 

So, whether you’re subject to a new entrant safety audit, or as most established carriers would more commonly run into, a compliance review, you could be in a situation where if you can’t provide the documentation of the steps that you’ve taken, you could be subject to needing to put together corrective action plans and essentially respond to a failed audit, needing to invest time and energy and document corrective actions you’re going to take to ensure that you do comply going forward. And those can be expensive and really take up a lot of time. You could run into situations where you have out-of-service orders issued. So, not having documentation either at the driver level or during an audit, could result in either drivers being put out of service or your company running into situations with unsatisfactory ratings and not being able to operate. You know, DOT number deactivations go hand in hand with that. 

If you do not get a positive result and end up being deemed unsatisfactory during a compliance review, that’s going to prevent your business from being able to operate. And even if it’s short of that, you are subject to civil penalties and fines in the event of serious non-compliance during a compliance review. And that certainly can be a costly situation. We don’t want to see that happen, so we want to raise awareness of this and kind of point that out. Even if you’re trying your best to be in compliance and do all the required steps, if you don’t have good, solid recordkeeping to prove that you’ve done everything you need to do, you could still run into some nasty consequences – so we want to make sure that that doesn’t happen. 

The Problem With Paper Files 

And one of the major things that we’re telling carriers here at Foley, is that it’s really time to start looking beyond paper files. And that’s because we see several key problems with paper. This comes out of our review of violations across the entire industry, but also the fact that we work with a very large number of motor carriers. And we see the common recurring themes with companies that struggle with recordkeeping, and we thought we would distill that down and share that here. 

So, one of the major problems with paper is that they are physically, usually only stored in one location. So a company does their required steps. So, an example would be, they do a drug test on an individual. There’s a copy of that chain of custody form, maybe a copy of that result, but it’s only accessible in that one location. It’s in a file cabinet somewhere. It’s hanging in a Manila folder somewhere in that file cabinet, and that’s the only place it is. So, if you have a company that’s spread out across a couple different offices, or you’re on the go a lot, there’s a greater risk of not being able to find that file when you need it. We hear stories all the time and we see examples of a file being incomplete because something got lost or it’s misfiled, and it’s not where it should be. Or there’s been damage as a result of floods or fires, or just relocations and something was in a good place and then the office was moved around or the business moved and all of a sudden we’re not quite sure where that document is. So, that’s certainly a real problem with paper is that it’s subject to just being misplaced. 

Furthermore, it’s not necessarily really conducive to an offsite audit. So you’re not necessarily ready to be audited remotely if you get notice of the audit and you need to submit all your documentation into a webpage where the DOT is going to review your records to ensure that you’re in compliance. That puts you in the position of having to empty out your file folder and scan all your documents in, get them categorized and labeled and in the right place, and uploaded to the DOT in the timeframes that they require. And that can be a big undertaking if you’re just getting notice now, and you’re starting from a standing stop, because that may not be falling at an opportune time. You might have a lot on your plate already, and getting those paper files converted into electronic images can be a rush and can pull you away from other things that you need to be doing for your business. 

And then obviously, as we’ve talked about, retention times and expiration dates, that’s harder to manage if we’re dealing with paper. If you’re dealing with electronic records, that becomes much less of a challenge. But if it’s just paper folders hanging in a filing cabinet; it’s going to take time and effort to kind of go through and figure out, okay, what can I get rid of and what needs to be kept longer, and what do I do with the documents as they get older? So, that’s something that carriers do struggle with, is just kind of managing that effectively and not having to invest a huge amount of time in doing it. 

The Current Crisis 

So on top of that, there’s also the situation of what’s been going on with the world since 2020. And as the pandemic started in 2020, a lot of organizations have seen change, and that could mean more work going on remotely or fewer employees actually in the office. The staff that was back in the office may not necessarily physically be there anymore. They may be working remotely or just basically embracing more technology to work from varied locations. So as that change has gone on, we’ve seen a lot of companies have the challenge of their paper-based filing system being put under even more strain because the person who used to manage the records is not physically in the same place as the records anymore. 

The advantage of going electronic is simply that documents are available anywhere once they’re stored in a good platform where you can access them from a computer, tablet or mobile device. And it just makes them accessible to people that are either on the road or are working remotely – wherever they happen to be provided they have the right access. 

Preparing for Offsite Audits 

And then as I mentioned before, the other big driver of carriers looking to get more electronic with their records is offsite audits for the FMCSA. The data shows offsite audits are up 400% this year. They’re certainly becoming more and more prevalent, and that really is because it’s going to be advantageous and really effective for the regulatory agencies like FMCSA to be able to get to more carriers and validate which carriers are doing the right things and which carriers need help in running their safety programs. If they don’t have to physically come out to each carrier, they can get through more audits and more interactions by running everything remotely. 

The flip side of that of course, is that employers may have to prove compliance in a more compressed timeframe. They may need to upload their documentation, they can’t just sort of invite the auditor in and say there’s the filing cabinet, you know, have at it. Rather, the FMCSA is going to basically provide a very specific list of what they want to see. Employers are going to have a time window to be able to get those documents, get them converted to electronic records, and uploaded into the FMCSAs preferred application to review those. 

Offsite Audit = Paper Free 

 So certainly, that’s putting pressure on carriers and what we see again is that there’s a time limit to this. And once a carrier has really embraced going digital in advance of the audit, it makes for a much faster and easier audit process. And that’s because you don’t have to have the scramble to find the documents, and you don’t have to have a scramble to get them scanned and labeled and organized. Rather, if you’ve already gone digital and you’re already storing all your important records in a software platform; that platform can then turn around and really just allow you to export those files and send them up to the FMCSA in a really structured manner that makes it a breeze to prove that you’re doing what you’re supposed to be doing. 

Going Digital: Are Your Files Safe?

 So what we want to talk about next is what does it mean to go digital? We’ve talked about some of the benefits and why we see this as an emerging trend that a lot of motor carriers are doing to ensure that they’re prepared for audits and that they’re in a good place to be able to prove their compliance. What really is that going to entail? Well, again, just as a refresher; we’ve talked about the fact that there are consequences to not preparing for this. Security is one key; you want to ensure that you’re able to show that files have been secured. And certainly, when your records are in an online system, that’s really going to be protected by authorized personnel having the right accounts, usernames and passwords. And for other employees of the company they’re not going to have access in there. So, that’s really one key piece – just ensuring that this best practice is established and that it’s not a a filing cabinet that somebody can get into without your knowledge. 

Not All Digital Files Are Created Equally 

 And then beyond just that, you want to ensure that when you go digital, and when you think about where you’re going to store these platform documents, you’re really aware of the fact that just kind of throwing them on a hard-drive isn’t necessarily the same as using an online platform. And one of the big advantages there that you want to take advantage of is the fact that if you use a platform which gives your employees access to documents from any location, that’s a huge plus. So, if you throw the documents on a hard drive – they may be scanned, they may be electronic, but it’s really only accessible to that person on that device, that computer, that tablet, whatever it happens to be. 

 But if you go about the route of using an online platform and you have that platform selected so that it’s accessible to your employee population, whether you happen to be on the road, whether you happen to have employees spread out in various places, they can access those from any device. You need to see something on a phone, you need to see something on a tablet or a laptop computer – whatever you happen to be using, you can get access and review those documents to make sure you have them or take action on them. For example, if there’s one person who is responsible for making decisions when you get back queries from a pre-employment test or a pre-employment query or a drug test for a new hire; having those records in a place where various different people in your company can see them so that they can take the next step is really an advantage. 

The Benefits of Going Online 

 So, not all digital files are created equally, so don’t just think because you have a scanner that that’s going to make everything better. Certainly, scanning is a good thing, but we want to make sure that all carriers recognize that a real solution would be one that your employees can get to from wherever they happen to be. Furthermore, beyond just security, you can take advantage of additional benefits of having your documents online and stored in a managed solution by a third-party compliance provider.  

 And there’s a lot of great tools for automation that are possible once you get your documents in an electronic format. And what that really boils down to is, you can take advantage of business intelligence from some of your TPAs and your industry partners that manage things like retention periods and monitoring to make sure you have all the required documents and alerting you if there’s any situation that needs your attention where something that is required is missing or something that you need to be doing is upcoming. So, really getting your records into an electronic, digital format opens the door for a lot of possibilities to take the work off of your plate and make sure that you’re in a better compliance situation. 

Tracking Due Dates 

So, a key example here is making sure that everything is tracked in terms of when upcoming actions are. If your documents are in the system and uploaded, then that automation can really ensure that you have ample warning so that you don’t miss something like a physical exam upcoming, for example. If you have a driver who needs to get a physical done to get their medical certification – if the license is going to be upcoming for renewal, you want to be able to have that tracked. So, that type of monitoring is possible once your records become digital. 

The Advantage of Automation 

 So, what are the advantages of automation? Well, certainly, once your records become automated and you have monitoring happening, there’s a lot less room for error. Your programs are easier to maintain because anything that requires your attention can be called out to you as opposed to you having to go hunt and quality check everything. So essentially, if your records are stored on paper, then the onus is really on you or one of your employees to go check those documents from time to time and see, is there anything missing? Do we have everything we need to have? And rather, if you choose the digital route, then what we see carriers able to do is not necessarily go check to find problems, but rather the platform and the system that they’re putting their documents into sends them the alerts and the notifications when things are either not in place that should be, or when actions are upcoming, like due dates or required steps that people have to take. 

 So, the difference is really the automation does the checking for you and really calls to attention only the things that you need to worry about, versus, with carriers using older paper-based systems, you have to manage that yourself, which just takes time and leaves room for error. 

TPA = Automated Compliance 

 So obviously, one of the big advantages of using an industry partner like a third-party administrator is that these types of compliance or background screening procedures can be managed for you. And obviously, there are a lot of things that you can partner with qualified firms to help you with – from Clearinghouse registration, and getting all of your drivers registered, get your account registered, to kind of running that application process for you and helping kind of capture all the data that you need upfront from the hiring process, to being an expert and ensuring that you’re in compliance with the fair credit reporting act or the privacy act, and ensuring that either your HR department -or if you happen to be your HR department – that you are supported from industry expertise. 

So, one of the things that we see successful carriers doing is really taking advantage of the resources that they have at their disposal. And recognizing that partnering with a third-party administrator really is a way of automating compliance and having a team working for you to ensure this is done. 

Have Questions? (860) 815-0764 

 So certainly, that’s one thing that we wanted to point out is that we are your partner if you want us to be, and we’re here to answer as many questions as we can, and be able to help you get set in the world of DOT compliance. So, hopefully today you’ve found the content that we’ve run through helpful and relevant to the situations that you’re in. But obviously, there’s a lot to talk about, and we may not have touched on every question or point that you have today. If that happens to be the case, there’s a number here that you can call and we are more than happy to go over any specific subjects that you’d like to run through. Be it clarifying anything we touched on today, or maybe something we didn’t that you just want to ask the question. We are more than happy to help out in any way we can. 

 So with that, I think we’ve wrapped up for the day. So, thank you again to everyone who has joined us. We definitely appreciate everyone’s engagement with this, and look forward to doing these webinars each time because certainly, it’s good for us to share what we’re seeing with the 60,000 or so motor carriers around the country that we work with. And it’s definitely a good opportunity for us to give back a little bit of the insights we’re seeing and hear from you.  

 So again, thank you very much for joining. And with that, I will wrap up and hope everybody has a great rest of your day. Thank you.