Schedule AR — Audit Readiness Review

About this Schedule

Applies when the Customer engages Crucible for an Audit Readiness Review. Governed by the Master Terms of Service; this Schedule controls for the Review where it conflicts.

AR-1. The Review

1.1 The Audit Readiness Review (the “Review”) is a fixed-fee documentary audit of the Customer’s motor-carrier safety records, modeled on the documentary examination conducted in a compliance review. It examines the records the Customer supplies against 49 CFR Parts 382, 383, 387, 390–396 and, where applicable, Part 397, and presents findings under the six safety-fitness factors of 49 CFR Part 385, Appendix B.

1.2 Intake and sample. The Customer supplies four structured sets against Crucible’s templates — driver roster, equipment roster, accident register (49 CFR 390.15), and roadside inspection history — which the platform parses and the Customer confirms row by row before anything is computed from them. The platform then draws the sample deterministically: every driver and unit with an out-of-service violation or an accident (49 CFR 390.5) within the preceding 24 months is selected; the balance is drawn randomly, by a seeded and reproducible method, to a fleet-sized target, with never fewer than two random selections. Crucible’s advisor may add or remove subjects before the sample issues, with the reason recorded. The selection method, the seed, and every selection reason are preserved in the engagement record and reported.

1.3 Citations. Findings cite Crucible’s stored, versioned copy of the regulations as of the draft date. The corpus is refreshed quarterly and may lag the Electronic Code of Federal Regulations; the official eCFR controls in the event of difference.

1.4 Deliverable. The Audit Readiness Report, presented factor by factor: scope examined, documents reviewed, findings with evidence references and severity, or the affirmative statement that the examined records supported no finding. Findings also enter the Customer’s program record, where the Customer’s acceptance, declination, and corrective actions are recorded. The Report and findings are the Customer’s on payment, subject to Master Terms §6.

AR-2. Fees, invoicing, and credit

2.1 Fee. Fixed, by fleet size (power units) at the tier below, determined from the Customer’s FMCSA registration record at the time of request and subject to re-tiering if the roster delivered under AR-1.2 differs materially:

Up to 10 power units — $3,500 · 11–50 — $5,500 · 51–150 — $8,500 · 151–500 — $12,500 · Over 500 — quoted.

2.2 Elevated history. Where the mandatory selections (out-of-service violations and accidents) materially exceed the sampling targets for the Customer’s fleet size, Crucible may quote the engagement instead of applying the table. A quote is stated in writing before any invoice issues, supersedes the table, and is accepted by the Customer in writing.

2.3 Invoicing. One invoice, issued through Stripe on the Customer’s acceptance of this Schedule (AR-3.3); payment due net 14 by card or ACH. The audit sample issues when the invoice is paid; intake and the draw proceed in the meantime. Master Terms §7 governs late payment.

2.4 Credit. Fifty percent of the fee actually paid credits against the first invoice(s) of any Retained Advisory program under Schedule RA commenced within thirty days after delivery of the Report. The credit is non-cash, non-transferable, and lapses if no program commences within that window.

AR-3. How the engagement forms

3.1 Request. A request submitted through Crucible’s website (including at /start/audit) is a request only. It forms no contract, authorizes no invoice, and opens no document room.

3.2 Confirmation. Crucible confirms each request by hand. On confirmation, Crucible provisions the Customer’s organization and invites the person the Customer designated as its executive user.

3.3 Acceptance. The Review is engaged when the Customer’s executive user, representing that they are authorized to bind the Customer, accepts the Master Terms and this Schedule in the platform’s legal registry, which records the accepting person, the document versions, and the time. The invoice issues, and the document room opens, on that acceptance and not before.

3.4 Issue. The audit sample issues on payment of the invoice.

AR-4. Customer responsibilities and warranties

4.1 Accuracy. The rosters, accident register, and inspection history supplied for sampling are accurate and complete to the Customer’s knowledge.

4.2 Authority to disclose; notice. The Customer is the employer and custodian of the driver and vehicle records it submits and warrants that it is authorized to disclose them to Crucible for the Review, and that it has given any notice to the individuals concerned that its own policies or applicable law require. Crucible supplies the driver notice at Annex AR-3 and records its delivery; the Customer distributes it as its counsel directs and is responsible for having done so.

4.3 DPPA recital and redisclosure record. Motor vehicle records in the Customer’s driver qualification files were obtained by the Customer under a permissible use of the Driver’s Privacy Protection Act, 18 U.S.C. §2721(b) — including subsection (b)(9) for holders of a commercial driver’s license and subsections (b)(2), (b)(3), and (b)(13) as applicable. The Customer’s disclosure of those records to Crucible, as its agent and contractor for the Review, is a redisclosure under 18 U.S.C. §2721(c) for the same permitted use. Crucible will use the information only for that purpose and will not redisclose it except to the subprocessors identified in the Data Processing Agreement under equivalent restrictions. The Customer’s acceptance record for this Schedule serves as the Customer’s record of the redisclosure, identifying the recipient and the permitted purpose, and the Customer will retain it for not less than five years.

4.4 Regulated records — what the Customer will not submit. The Customer will submit only the document types listed on the engagement checklist, and will not submit any item in the never-classes at AR-6.6, including: individual drug or alcohol test results or any record subject to 49 CFR 40.321 or 382.405; medical review officer or substance abuse professional records; the content of Drug and Alcohol Clearinghouse query results; the content of safety-performance-history investigation files under 49 CFR 391.53 (process evidence — inquiry dates, responses received, good-faith-effort documentation — may be submitted); medical examination reports (MCSA-5875) or skill-performance-evaluation or exemption medical documentation; Social Security cards; Form I-9 or other immigration documents; or financial account records. If such an item is submitted, Crucible will remove it from the room, note the removal in the engagement record, and may treat the submission as a material breach of this Schedule.

4.5 Drug and alcohol domain. The drug and alcohol domain is reviewed at the program level — written policy, random-selection records, management information system summaries, the Clearinghouse query log, and supervisor training records — and through the Customer’s own attestations, entered in the platform, of the presence and dates of required results. Individual results are never reviewed under this Schedule.

4.6 Use of findings. The Review is an audit of the Customer’s records. It is not a background investigation or a consumer report under the Fair Credit Reporting Act, 15 U.S.C. §1681 et seq., and no finding is a determination about any individual (Master Terms §8.3). The Customer will not take adverse action against any driver on the strength of a finding without its own review of the underlying record.

4.7 Originals and retention duties. The Customer remains the custodian of its records, retains the originals, and remains solely responsible for its own recordkeeping and retention duties.

AR-5. Disclaimers

5.1 The Review is advisory. It is not legal advice, creates no attorney-client relationship, and is not a determination of compliance by any regulator or under 49 CFR Part 385 or any other authority. Schedule RA §5 applies to the Review as if set out here.

5.2 Crucible does not predict or warrant any FMCSA safety rating, audit outcome, insurance decision, or enforcement result. The Review rehearses the documentary examination; the agency’s own review is the agency’s.

5.3 The Review is sample-based and is not represented as exhaustive. It relies on documents supplied by the Customer, which Crucible does not authenticate.

5.4 The platform is not the Customer’s system of record, and placing a document in it discharges none of the Customer’s own duties.

5.5 The Customer may describe the Review accurately as an advisory review of its records. It will not represent to any regulator, insurer, court, or third party that Crucible audits, certifies, rates, or operates the Customer’s compliance program.

AR-6. Documents and AI-assisted processing

6.1 The document room. Audit documents are uploaded to a private, tenant-isolated document room. Access is enforced server-side; every download re-checks the reader and is audit-logged; each file is hash-pinned at intake; superseded documents are flagged, never erased. The room states on its face that it is not a regulatory filing system.

6.2 When AI assistance applies. Sections 6.3 through 6.9 take effect for the Customer only after Crucible gives written notice, in the platform, that AI-assisted document review is available for the Customer’s engagement. Until that notice, no Customer document is processed by an artificial-intelligence model; documents are read and findings authored by a named Crucible advisor with deterministic platform tooling only.

6.3 Disclosure. Once available, Crucible uses AI assistance — Anthropic’s API under Anthropic’s Commercial Terms of Service, as subprocessor — to accelerate document review. AI output is draft only: every finding is reviewed, edited, and published by a named Crucible advisor before the Customer sees it, and the platform provides no publish path from a model to the Customer.

6.4 Default processing. Before any document text reaches a model, the platform: (a) extracts text from the document on Crucible’s platform — documents from which text cannot be extracted are reviewed by the advisor and are not sent to a model; (b) applies automated redaction of direct identifiers — Social Security numbers, dates of birth, residential addresses, telephone numbers, and financial account numbers; (c) replaces each driver’s license number with a stable engagement-local token, so that cross-document consistency can be checked without the number itself; (d) replaces each subject’s identity with an engagement-local pseudonym (“Driver 3”), matched to the Customer’s confirmed roster on the platform — the pseudonym map and the token map never leave the platform; and (e) computes age and other date-dependent checks on the platform before redaction, so that dates of birth are never required in a prompt. The Customer is told plainly that automated redaction is pattern-based and not infallible.

6.5 Consented pass-through. Certain checks require identity linkage. By separate election made in the manner stated in Annex AR-1, the Customer may authorize pass-through of the following field classes and no others: (a) driver name as it appears on qualification documents; (b) driver’s license number, class, endorsements, and expiration, where tokenization under 6.4(c) is insufficient for the check; (c) medical certificate dates, restrictions, and examiner identity; and (d) motor vehicle record violation entries and their dates. The election is recorded against the engagement, with the accepting person, the document version, and the time; the permitted classes are enumerated in code and cannot be enlarged in the field; and the Customer may revoke the election prospectively at any time.

6.6 Never-classes. The following are not transmitted to any AI processor under any election, and are redacted by pattern before transmission; the first six are also never to be submitted to Crucible at all (AR-4.4): individual drug or alcohol test results and records subject to 49 CFR 40.321 or 382.405; medical review officer and substance abuse professional records; Drug and Alcohol Clearinghouse query content; safety-performance-history investigation file content under 49 CFR 391.53; medical examination reports and exemption or skill-performance-evaluation medical documentation; Form I-9 and immigration documents; Social Security numbers; residential addresses; financial account data; photographs; and medical information beyond the DOT medical certificate.

6.7 Processor terms. Processing under Anthropic’s Commercial Terms of Service and Data Processing Addendum: no training of models on Customer content; retention only as those terms permit, including limited retention for safety review. Crucible will give the Customer thirty days’ notice of any change of AI processor, and the Customer may object by revoking its election.

6.8 Redaction failure. If Crucible learns that a never-class item or an unelected field class reached a model, it will treat the event as a security incident under the Data Processing Agreement, notify the Customer, request deletion from the processor where the processor’s terms allow, and record the event in the engagement record.

6.9 Provenance. Every AI-drafted finding carries its draft status, the model, and the corpus version in the engagement record until the advisor publishes it.

AR-7. Retention and deletion

7.1 Document files remain in the Customer’s document room during the engagement and for 24 months after delivery of the Report, or until the Customer requests their deletion, whichever is earlier.

7.2 The engagement record — findings and their dispositions, the sampling methodology and seed, the Report, the election records, and document metadata (document file names, dates, and hashes, with subject identities pseudonymized on deletion of the files) — is retained by Crucible for not less than six years after delivery of the Report as the record of its professional engagement, and is exportable by the Customer on request.

7.3 Master Terms §3.4 and the Privacy Policy’s retention section apply to anything not addressed above.

AR-8. Term

The Review runs from acceptance until delivery of the Report, with AR-7 surviving. Either party may terminate for material breach uncured thirty days after written notice. If the Customer terminates before the sample issues, Crucible refunds the fee less $500 for intake and draw work performed; after the sample issues the fee is earned and Crucible delivers the record as it stands.

AR-9. Relationship to Schedule RA

The Review is a one-time engagement and does not of itself commence a Retained Advisory program. Where the Customer also holds a Schedule RA program, the advisor-seat, audit-logging, and acknowledgement terms of Schedule SI §2 and Schedule RA §2 apply to the Review, and findings publish through the program record. Schedule RA §5 applies to the Review in all cases.

Annex AR-1 — Pass-through election (form and record)

How the election is taken. Only after Crucible’s notice under AR-6.2, and only inside the authenticated platform. The election is a separate control, unchecked by default, presented to the Customer’s executive user with the text below. Acceptance of this Schedule does not make the election. The platform records the accepting person, their stated title, the version of this Schedule and of this Annex, and the time, and sets the engagement’s pass-through consent field only then, with those values. Revocation is a control on the same screen and takes effect prospectively.

Screen text: “AI-assisted review: identity pass-through election. By default, before any document text reaches the AI model, we remove Social Security numbers, dates of birth, home addresses, telephone numbers, and financial account numbers; replace license numbers with engagement-only tokens; and replace drivers’ names with pseudonyms the model never sees behind. Some checks need real identity fields. If you elect pass-through, we may send only these four classes to the model: (a) driver name as it appears on qualification documents; (b) license number, class, endorsements, and expiration, where the token is not enough for the check; (c) medical certificate dates, restrictions, and examiner identity; (d) MVR violation entries and their dates. Never sent under any election: Social Security numbers, home addresses, financial data, photographs, drug and alcohol results, Clearinghouse content, investigation-file content, medical examination reports, immigration documents, or medical information beyond the DOT certificate. Automated redaction is pattern-based and not infallible. You can revoke this election at any time; revocation applies going forward.”

☐ I am authorized to make this election for [Customer legal name], and I elect pass-through of the four classes above. (Name, title, date and time recorded.)

Annex AR-2 — Document checklist scope statement (room copy)

Shown at the top of the document room and on every upload panel.

Upload only the document types listed for each sampled file. Do not upload: drug or alcohol test results; MRO or SAP records; Clearinghouse query results; the content of prior-employer investigation files (dates and responses are fine); medical examination reports (MCSA-5875) or exemption paperwork; Social Security cards; I-9 or immigration documents; bank or financial records. If one is uploaded, we remove it and note the removal. Documents here are read for Crucible’s advisory work and kept as part of the program record. This room is not a regulatory filing system, and placing a document here discharges no retention duty of your own.

Annex AR-3 — Driver notice

Supplied by Crucible; distributed by the Customer as its counsel directs.

Notice: safety records review by Crucible Group, LLC.

Your employer, [Client legal name], has engaged Crucible Group, LLC, a safety and compliance advisory firm, to review its own motor-carrier safety records. Crucible’s review examines whether your employer’s driver qualification, hours-of-service, vehicle maintenance, and safety program records meet Federal Motor Carrier Safety Administration requirements.

What is reviewed. Records your employer keeps about you under 49 CFR Parts 382, 383, 391, 395, and 396 may be included: your driver qualification file (application, employment verification, motor vehicle record, medical certificate status, road test or CDL equivalence), hours-of-service records, and inspection and accident records involving a vehicle you operated. The review is sample-based and may not include your records at all.

What is not reviewed. Your individual drug or alcohol test results, medical examination reports, Social Security card, and immigration documents are not provided to Crucible.

How your information is protected. Records are held in a private system with access logging. Where Crucible uses AI assistance to speed its review, your Social Security number, date of birth, home address, telephone number, and financial information are removed before any text is sent, your license number is replaced by a token, and your name is replaced by a pseudonym unless your employer has specifically elected otherwise for a narrow set of fields.

What Crucible does and does not do. Crucible reads the records to assess your employer’s recordkeeping and compliance program. Crucible makes no determination about you, provides no report about you to anyone, and plays no part in any employment decision. Your records are not sold and are retained only as the engagement requires.

Questions. Contact your employer’s safety department, or Crucible at legal@gocruciblegroup.com or 8735 Dunwoody Place, Atlanta, Georgia 30350.