Most Safety Managers and owners of DOT-regulated businesses understand the importance of keeping up with maintaining their commercial vehicles. What is not always clearly understood, however, is the vehicle maintenance records the Federal Motor Carrier Safety Administration (FMCSA) requires.
According to FMCSA regulations, There are specific documents that must be kept for certain retention periods. These regulations apply to any owned or leased vehicle (provided the leased vehicle is being operated for at least 30 days) that meets one or more of the following requirements:
- Has a Gross Vehicle Weight Rating (GVWR) or Gross Combination Weight Rating (GCWR) of 10,001 pounds or more
- Carries hazardous materials and requires placarding
- Can transport eight or more passengers, including the driver
DOT Vehicle Maintenance Files (VMFs)
The FMCSA requires that individual files be maintained for all CMVs. Many companies do retain maintenance records, but they are often disorganized and kept in one file. In the event of an FMCSA audit, this can make it difficult for the safety auditor to make an accurate assessment of the company’s maintenance methods and paper files are not accepted during offsite DOT audits. That means headaches — and possibly hefty fines — for the company.
Let's consider a hypothetical situation that is a common scenario with many DOT-regulated businesses:
The owner of a home services company undergoes an FMCSA compliance review. When the safety auditor requests to see vehicle maintenance records, the owner is confident knowing that they are on top of maintaining their CMVs. They plunk down a large file that they have been keeping for years containing repair receipts, DMV records, insurance forms, etc.
What they're not prepared for is the excruciating 4-hour examination of documents by a stringent DOT auditor who has to rummage through a mass of disorganized paperwork. They received several violations for failing to keep records of inspections and vehicle maintenance. The owner is shocked…they have been maintaining these records for years, isn’t it obvious they take care of their vehicles?
Documentation & Filing Methods of Vehicle Repairs & Maintenance
To ensure you set up acceptable Vehicle Maintenance Files (VMFs), we suggest putting yourself in the DOT auditor’s shoes for just a minute. Would you want to go through a jumbled mess of years of paperwork, trying to sift out important documents?
Here are three steps to keep in mind when creating and maintaining your DOT vehicle maintenance files:
1. Create one separate file for each vehicle (including trailers)
A DOT auditor wants to be able to select a vehicle file and be able to immediately and clearly identify the vehicle. Therefore, the first stand-alone document should be a Vehicle Identification Record that contains identifying information such as the make, model, year, and VIN.
2. Clearly identify receipts of repairs and regular maintenance
It’s important to keep receipts, but the DOT auditor needs to be able to tell what the receipt is for. For example: You purchased new windshield wipers, light bulbs, and batteries. You also threw in some air fresheners, heavy-duty garbage bags, and a pack of gum. You should keep a document or form of the vehicle purchases and staple the receipt to it, highlighting the date and the purchases that pertain to the vehicle.
3. Document roadside inspections
Whenever any of your vehicles are selected for a roadside inspection, whether violations are found or not, you need to keep the roadside inspection report in the vehicle’s file. If defects (violations) are found, it's crucial to get them fixed promptly and to staple evidence of the repair to the inspection report.
Your VMFs need to reflect that you are on top of all regular maintenance needs and that you repair all defects promptly. An auditor wants to be certain that your vehicle can be safely operated on public roadways. Therefore, not only do you want to be able to document when you last had maintenance performed, but also when you project it will next be needed.
DOT Record Retention Periods
All vehicle maintenance records must be retained for a minimum of 12 months with one exception: Annual DOT inspection reports must be retained for 14 months.
DOT Periodic/Annual Inspections and Reports
Annual or periodic DOT inspection reports are a crucial aspect of maintenance records that are often overlooked. These are the inspections in which you receive a sticker on the CMV indicating that it has passed its annual inspection. Many DOT-regulated business owners believe that having the sticker is sufficient, yet the hard copy of the report is just as important.
Get Your Vehicle Maintenance DOT Records Organized & Digitized
Even if you aren't expecting an FMCSA audit soon, do not put off getting organized and implementing an effective vehicle maintenance filing system. As your business grows and you add additional trucks to your fleet, the more difficult it will become to keep up with your DOT recordkeeping requirements.
Dash, Foley's DOT recordkeeping software solution, makes it easy to transfer all your paper files to an electronic format, so you're always ready for DOT compliance reviews. Get a free demo of Dash now by clicking here or filling out the form below.
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