JULY 20, 2016 – Most owners of a DOT-regulated business realize the importance of keeping up on their vehicles’ maintenance. What is not always clearly understood, however, is the vehicle maintenance records the Federal Motor Carrier Safety Administration (FMCSA) requires. This includes the specific documents that need to be kept, the manner in which information is to be maintained and the 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
- Is able to transport 8 or more passengers including the driver
Vehicle Maintenance Files (VMFs)
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 a FMCSA audit, this can make it difficult for the safety auditor to make an accurate assessment of the company’s maintenance methods. And that means 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 in 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 he is on top of maintaining his CMVs. He plunks down a large file that he has been keeping for years containing repair receipts, DMV records, insurance forms, etc. What he’s not prepared for is the excruciating 4-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 of his records for years, isn’t it obvious he takes care of his vehicles?
Filing methods and documentation of repairs and maintenance
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?
Here are three steps to keep in mind when creating and maintaining your own files:
1. Create one separate file for each vehicle (including trailers)
The 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 auditor needs to be able to tell what the 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.
3. Document 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 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 in a timely manner. An 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 a FMCSA audit in the near future, do not put off getting organized and implementing an effective Vehicle Maintenance Filing System.
Questions or concerns? Leave them in the comments section below!
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