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DOT Recordkeeping Requirements

The Federal Motor Carrier Safety Administration (FMCSA) requires motor carriers to keep records to document compliance with the safety regulations. This documentation must be retained for varying lengths of time as established by the applicable regulations. This post discusses some of these recordkeeping requirements and was written to help carriers purge their files on a regular basis.

Record-Retention Requirements

The following is a quick review of record retention requirements in a few key compliance areas:

Drug and Alcohol Testing

Remember all DOT drug and alcohol test (DAT) records must be maintained in a secure location with controlled access. This means all DAT records must be kept in a separate file under lock and key; they should not be stored with personnel files. As the rules make no exceptions for one-driver companies, we advise owner-operators to maintain their DAT files separately as well.

The Following Records Must Be Maintained for At Least Five Years:

  •   Alcohol test results indicating a BAC of 0.02 or greater
  •   Verified positive controlled substances test results
  •   Refusal to test documentation
  •   Substance Abuse Professional (SAP) evaluation reports
  •   Copy of annual calendar year summary if required by 49 CFR 382.403

The Following Records Must be maintained for at Least Two Years:

  •   Random selections
  •   Reasonable-suspicion testing documentation
  •   Medical evaluations for shy lung and shy bladder situations

The Following Records Must be maintained for at Least One Year:

  •  Negative and canceled drug test results
  •  Alcohol test results with a BAC below 0.02

Additional Retention Requirements:

The employer’s policy, driver’s signed receipt and all records related to employer and supervisor education and training must be retained while the individual performs safety-sensitive and/or supervisory functions and for two years thereafter.

 

Driver Qualification

Both the Driver Qualification and Safety Performance History Files must be retained for as long as the safety-sensitive individual is employed by the company, and for three years thereafter.

The following documentation may be discarded from the Driver Qualification File three years from the date of execution:

  •   Annual List of Violations
  •   Annual Inquiry to State Agencies
  •   Annual Review of Driving Record
  •   Medical Examiner’s Certificate
  •   Safety Performance Evaluation Certificate (if applicable)

 

Hours-of-Service

  •   Driver logs and supporting documents must be retained for six months.

Vehicle Maintenance

For every vehicle in their control for 30 days or more, motor carriers must retain the following records for one year at the location where the vehicle is garaged and for six months after the vehicle leaves the carrier’s control:

  •   Identifying information (company number, make, serial number and tire size)
  •   Inspection schedule, including type and date

Other Retention Requirements:

  •   Post-Trip Inspection Reports must be retained for at least three months from the report date
  •   Periodic Inspection Report or Copy must be retained for 14 months from the report date
  •   Evidence of an inspector’s qualifications for one year after the inspector ceases to perform inspections for the carrier

Stay Organized

Remember it is always easier to create a clean, organized system from the beginning. Motor carriers can waste a lot of time trying to use or fix a recordkeeping system that is barely limping along. Save yourself a lot of time by setting up your files correctly and maintaining them on a regular basis.

Although these are the minimum requirements, I recommend that you keep copies (in a separate file) of documents related to a serious or fatal accident until the case is adjudicated or settled.

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