Most business owners who operate DOT-regulated Commercial Motor Vehicles (CMVs) realize the importance of keeping up on vehicle maintenance. What is not always clearly understood is the thorough documentation the Federal Motor Carrier Safety Administration (FMCSA) requires in terms of recordkeeping, such as specific documents, the manner in which information is organized, and retention periods.
This applies to any owned or leased vehicle (provided the leased vehicle is being operated for at least 30 days) with a Gross Vehicle Weight Rating (GVWR) or Gross Combination Weight Rating (GCWR) of 10,001 pounds or more, or any vehicle carrying hazardous materials that requires placarding.
About Those Vehicle Maintenance Files…
The FMCSA requires that individual files be maintained for all CMVs. Many companies do retain maintenance records, however, 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. Disorderly recordkeeping can cause headaches—and possibly hefty fines—for the company.
Let’s take a moment to look at a situation that although hypothetical, is a common scenario that has occurred to many DOT-regulated businesses. The owner of a primarily local home service company undergoes an FMCSA compliance review. When the safety auditor requests to see vehicle maintenance records, the owner feels confident, knowing that he is on top of maintaining his CMVs. He plunks down a large file that he has been keeping for five years containing repair receipts, DMV records, insurance forms, etc. … And then, unfortunately, he finds himself unprepared for the excruciating four-hour examination of documents by a stringent auditor who has to rummage through a mass of disorganized paperwork. He receives several violations for failing to keep records of inspection and vehicle maintenance. The owner is shocked! He has been maintaining all records for years. Isn’t it obvious he takes care of his CMVs?
Think Like an Auditor
A good way to make sure you set up acceptable Vehicle Maintenance Files (VMFs) is to put yourself in the auditor’s shoes for just a minute. Would you want to go through a jumbled mass of years of paperwork, trying to sift out pertinent documents?
The auditor wants to select a vehicle file and be able to immediately and clearly identify the vehicle. Therefore, the first standalone document should be a Vehicle Identification Record, containing identifying information such as the make, model, year and VIN.
Maintenance and repair receipts: It’s important to keep maintenance and repair receipts, but the auditor needs to be able to tell what each receipt is for. For example, you purchase new windshield wipers, light bulbs and batteries. You also throw 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.
Roadside inspections: Any time a roadside inspection occurs, whether violations are found or not, you need to keep the roadside inspection report in the vehicle’s file. Moreover, if defects (aka violations) are found, it is crucial to get them fixed immediately and to staple evidence of the repair to the inspection report.
Systematic/periodic maintenance program: Your VMFs need to reflect that you are on top of all regular maintenance needs, and that you repair all defects in a timely manner. The auditor wants to be certain that your vehicle is able to 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.
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 are under the impression that having the sticker is sufficient, yet the hard copy of the report is just as important. As stated above, the FMCSA requires these reports to be retained for 14 months.
Even if you are not expecting an FMCSA audit in the near future, do not put off getting organized and implementing an effective Vehicle Maintenance Filing System.
As with all DOT regulations, these requirements have been put into place to ensure safety on our nation’s roads.