DOT Vehicle Maintenance Records and Annual Inspection Compliance

What has to be in a DOT vehicle maintenance file?

Under 49 CFR 396.3, you must keep a maintenance file for every vehicle you control for 30 days in a row or more. That includes leased trucks and trailers. If you don't own the vehicle, the file must name who supplied it.

Keep the file where the vehicle is housed or maintained. Keep it for 1 year, and for 6 months after the vehicle leaves your control.

• Vehicle ID: company unit number if marked, make, serial number (VIN) and year
• A schedule showing what inspection and maintenance is due, and when
• A record of each inspection, repair and maintenance job, with the date and what was done

Driver vehicle inspection reports (DVIRs)

Under 396.11, drivers must do a written report at the end of each day's work on each vehicle they drove. The report covers brakes, parking brake, steering, lights and reflectors, tires, horn, wipers, mirrors, coupling devices, wheels and rims, and emergency equipment.

If the driver finds no defect and none is reported to them, no report is required. When a defect is listed, you must fix anything likely to affect safe operation before the truck runs again. Then you certify on the report that it was repaired, or that repair wasn't needed. Keep each DVIR and its repair certification for 3 months.

The DVIR rule in 396.11 does not apply to a motor carrier operating only one commercial motor vehicle. A one-truck owner-operator should still check the truck daily and keep repair records.

What are the annual DOT inspection requirements?

Under 396.17, every commercial motor vehicle you control must pass a periodic inspection at least once every 12 months. The inspection must cover at least the items in Appendix A to Part 396. Trailers count too.

Proof can be the inspection report or a sticker or decal. The decal must show the date, your name and address, the vehicle ID if it isn't clearly marked, and a statement that the vehicle passed. A state inspection program that meets the federal standards also counts.

Under 396.21, the inspector's report must name the inspector, the carrier, the date and the vehicle. It lists the parts checked and the results. Keep it for 14 months where the vehicle is housed or maintained.

Who can do an annual DOT inspection?

You can inspect your own vehicles or use a shop, truck stop or leasing company. Either way, the inspector must meet 396.19. They must understand the standards and be able to spot defective parts.

They also need either a federal or state training program or certificate, or at least one year of combined training and experience as a mechanic or inspector. Keep proof of each inspector's qualifications while they inspect for you and for one year after.

Which vehicle violations fail a new entrant audit?

Section 385.321 lists the violations that fail a new entrant safety audit automatically. Three of them are about vehicles:

• Running a vehicle declared out of service before repairs are made (396.9(c)(2)). One time is enough.
• Running a vehicle before fixing out-of-service defects a driver listed on a DVIR (396.11(a)(3)). One time is enough.
• Using a vehicle that hasn't had its periodic inspection (396.17(a)). This fails the audit when 51% or more of the records checked show it.

Other maintenance violations that hurt your rating

Some gaps don't fail the audit outright but still count against you. Under Appendix B to Part 385, not keeping minimum maintenance records (396.3(b)) and not requiring DVIRs (396.11(a)) are critical violations. A pattern means more than one violation and at least 10% of the records checked. A pattern can cost you the vehicle factor of your safety rating.