Navigating the complexities of Department of Transportation record-keeping requirements is no easy task. The DOT has strict guidelines governing the way that transportation companies operate. These rules are in place to keep drivers and citizens safe, but because they frequently change, it can be difficult to keep track of them all.
One of the requirements of the Federal Motor Carrier Safety Administration (FMCSA) is that companies keep and maintain accurate records. Carriers are required to save different documents for varying lengths of time. DOT auditors will carefully comb through your records during safety audits and DOT compliance reviews. If you don’t have the right records, it will cost you in fines and penalties. Conversely, if your records are curated and well-organized, it will speed up the review process and go a long way with the auditor.
We will go over the various requirements for DOT records here so that you can organize and maintain them properly.
Drug and Alcohol Testing Results
It is important to note that you must keep all DOT drug and alcohol testing results in a secure storage area with controlled access. That means you have to have them in a separate, locked file. You can’t keep them in the same place as personnel files.
This regulation applies to single-driver companies as well as large organizations. So, even if you are the only driver, you still need to keep your drug and alcohol testing files separate.
These Documents Must be Kept for Five Years
- Test results indicating a blood alcohol level (BAC) of 0.02 or greater
- Verified positive test results for controlled substances
- Documentation when an employee refuses to test
- Evaluation Reports for Substance Abuse Professionals (SAP)
- A copy of the calendar year summary if it is required by regulation 49 CFR 283.403
The Following Documents Must be Kept for Two Years
- The subjects of random selections
- Documentation of reasonable suspicion
- The medical documentation of “shy lung” and “shy bladder” situations
Documents That Must be Kept for One Year
- Negative drug and alcohol test results
- Results that indicated a BAC of less than 0.02
Driver Qualification and Performance Records
According to FMCSA regulations, any driver who operates a vehicle over 10,000 pounds, who drives eight people or more (including the driver), or who transports hazardous materials must have a file with documentation of their qualifications. That file must include:
- The driver’s employment application
- A certificate of the driver’s road test
- A DOT medical exam certificate
- A skilled performance evaluation certificate
- The driver’s motor vehicle driving record and any incidents and violations
- The annual review of the driver’s driving record
The qualification documents can be included with the driver’s personnel file. Carriers must keep them for the duration of the driver’s employment with the company and three years afterward.
Records of Vehicle Maintenance
Motor vehicle carriers must keep records of vehicle maintenance for vehicles they have direct control over for at least 30 days, often longer. These regulations show that the vehicle receives proper maintenance and provides authorities with accurate, up-to-date information in case of an accident.
The maintenance records must include the following information.
- Identifying vehicle information–the company’s name, serial number, make of the vehicle, etc.
- An inspection schedule that includes the type and date of the last inspection.
- Post-trip inspection reports.
- Repair information–the type of repair needed and the date and action taken on those repairs.
Post-trip inspection reports must be kept for at least three months from the inspection date, and the period inspection report (or a copy of it) must be retained for at least 14 months from the date of the inspection. The inspector’s qualifications must be kept for at least one year after the inspector stops performing inspections for the company.
Electronic Logging Devices
Starting in 2017, the FMCSA required that most commercial drivers have and use an electronic logging device (ELD). These devices automatically track driving statistics and are intended to create safer conditions for drivers. The device gathers the following information.
- Date, time, and location
- The driver’s identification
- The vehicle information
- Number of hours the engine has been in use
- The number of miles the vehicle has traveled
- The motor carrier details
The information on the device is the Record of Duty Status (RODS) data, which must be kept for six months along with the backup data. The backup ELD data must be stored in a separate place from the device where it was recorded.
Supporting Documents
The FMCSA requires carriers to retain the following supporting documents for six months in addition to the Records of Duty Status.
- Dispatch and trip records
- Driver expense receipts
- Bills of lading and manifests
- Fleet management communication records
- Weight station tickets
- Phone bill statements
- Payroll records and settlement statements
Establish a System
The easiest way to ensure you have all the required documents for the DOT is to have a well-organized system. Whether you use a digital, online record-keeping system or you keep physical files, it is imperative that you keep the files organized and that you regularly review and maintain files as well as purge unnecessary paperwork. While it might seem a monotonous and overwhelming task now, your future self will thank you for your diligence.
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Infographic
Navigating DOT record-keeping requirements can be challenging. Missing documentation could result in fines, while well-organized records can expedite the review process. Check out this infographic to learn how to effectively organize and maintain DOT records.
