Section 01 · Driver Files
Driver Qualification Files
Every CDL driver you dispatch needs a complete, current qualification file (49 CFR Part 391). Pull each driver's file and confirm every item below is present, signed, and not expired.
Retention tip
Keep each DQ file for the length of employment plus three years after the driver leaves your company.
Employment application
Completed and signed, including the previous three years of employers (ten years for CDL driving jobs).
Motor vehicle record (MVR)
Pre-hire MVR from every state licensed in the past three years, plus an annual MVR from each licensing state.
Previous employer checks
Safety performance history investigations for prior DOT employers, completed within 30 days of hire.
Road test or CDL copy
Road test certificate, or a copy of a valid CDL accepted in place of the road test.
Medical examiner's certificate
Current DOT medical card from a National Registry examiner, plus verification of the examiner's registry listing.
Annual review & violations list
Signed annual review of each driving record, with the driver's annual list of violations or certification.
Clearinghouse queries
Full pre-employment query and annual limited queries, with signed driver consent on file.
Entry-level driver training
ELDT completion record in the Training Provider Registry for drivers who earned their CDL after Feb. 7, 2022.
CHECKLIST 02
Vehicle & Maintenance Records
Under FMCSA Part 396, every unit you control for 30 days or more needs a complete inspection, repair and maintenance file. Use this checklist to confirm each truck and trailer has the paperwork an auditor will ask to see.
Unit Identification
- Company unit number, make, serial number (VIN), year and tire size on file
- Ownership or lease agreement for each unit
- Schedule and type of inspections to be performed
Inspections & DVIRs
- Annual periodic inspection report for every unit, completed within the last 12 months
- Qualified inspector and brake inspector certifications on file
- Driver Vehicle Inspection Reports (DVIRs) with defects noted and certified as repaired, kept 3 months
- Roadside inspection reports signed and returned within 15 days
Repairs & Retention
- Dated record of all inspections, repairs and maintenance performed
- Invoices and work orders matched to each unit number
- Push-out-window or lubrication schedule documented
- Records kept 1 year at the location and 6 months after a unit leaves your control
Audit tip: Pull three random units and trace each one from its annual inspection through its most recent DVIR and repair invoice. Any gap you find is a gap an auditor will find too.
Checklist 03 · Hours of Service
Hours of Service Review
HOS violations are among the most common findings in a DOT audit. Pull a sample of recent logs for every driver and check them against the limits below and the supporting documents that prove they are accurate.
Property-carrier limits at a glance
- 11 hours max driving after 10 consecutive hours off duty
- 14-hour on-duty window — no driving after the 14th hour
- 30-minute break after 8 cumulative hours of driving
- 60 hours in 7 days or 70 hours in 8 days
- 34 consecutive hours off to restart the weekly clock
ELDs & driver logs
- ☐ Every truck has a registered ELD listed on FMCSA's self-certified list
- ☐ ELD user manual, malfunction instructions and 8 days of blank paper logs are in each cab
- ☐ Logs for the last 6 months are retained and retrievable for every driver
- ☐ Unassigned driving time is reviewed and assigned or annotated
- ☐ Edits and annotations include a clear reason and driver certification
- ☐ Form-and-manner errors (missing shipping docs, trailer numbers) are corrected
Supporting documents & exceptions
- ☐ Supporting documents (fuel receipts, bills of lading, dispatch, tolls) kept 6 months
- ☐ Logs spot-checked against supporting documents for accuracy
- ☐ Short-haul, adverse-driving and personal-conveyance uses are documented and justified
- ☐ Yard-move and personal-conveyance policies are in writing
- ☐ Recurring violations are tracked with documented driver coaching
Pro tip: Audit a random sample of at least 10% of driver logs each month so issues are caught before an investigator finds them.
Checklist 04
Drug & Alcohol Compliance
Under 49 CFR Parts 40 and 382, every carrier with CDL drivers needs an active testing program, accurate records, and Clearinghouse queries on file. Use this list to confirm each requirement is documented and easy to produce during an audit.
Owner-operators take note
Single-driver carriers must still join a consortium/third-party administrator (C/TPA) for random testing. You cannot test yourself.
Program & Policy
- ☐ Written drug & alcohol policy on file
- ☐ Signed policy receipt for every driver
- ☐ Active C/TPA or consortium enrollment
- ☐ Designated employer representative (DER) named
- ☐ Supervisor reasonable-suspicion training records
Testing Records
- ☐ Negative pre-employment result before first drive
- ☐ Random selection lists and test results
- ☐ Post-accident tests when required
- ☐ Reasonable-suspicion documentation
- ☐ MRO-verified results and chain-of-custody forms
FMCSA Clearinghouse
- ☐ Carrier registered in the Clearinghouse
- ☐ Full query before hiring each driver
- ☐ Annual limited query for every CDL driver
- ☐ Driver consent forms retained
- ☐ Violations reported within required timelines
Retention & Return-to-Duty
- ☐ Positive results & refusals kept 5 years
- ☐ Negative results kept 1 year
- ☐ SAP evaluations and return-to-duty tests filed
- ☐ Follow-up testing schedule tracked
- ☐ Annual MIS summary ready if requested
SECTION 05
Registration & Insurance Checklist
Lapsed authority, expired cab cards, or insurance gaps can put a truck out of service on the spot. Confirm every registration, license, and policy is current, accurate, and easy to produce during a roadside inspection or compliance review.
Pro tip
Set calendar reminders 60 days before every renewal date — UCR, IRP, IFTA, MCS-150, and insurance policies.
Operating Authority
- USDOT number active and displayed correctly on both sides of the vehicle
- MC number / operating authority active (if required)
- MCS-150 updated within the last 24 months
- BOC-3 process agent designation on file
Vehicle Registration
- IRP apportioned cab card current and in every power unit
- Trailer registrations valid and plates match records
- Heavy Vehicle Use Tax (Form 2290) proof filed and paid
- VINs match titles, registrations, and insurance schedules
Fuel Tax & State Filings
- IFTA license and decals current on every qualified vehicle
- Quarterly IFTA returns filed on time with mileage and fuel receipts
- UCR registration paid for the current year
- State permits (oversize, weight-distance, KYU, NM, NY HUT) if applicable
Insurance Coverage
- Liability coverage meets FMCSA minimums for your cargo type
- BMC-91/91X filing active with FMCSA
- Certificate of insurance in each truck, with correct named insured
- All units and drivers listed on the policy; cargo coverage verified
Checklist 06
Accident Records Management
Under 49 CFR 390.15, motor carriers must keep an accident register covering the past three years. Use this checklist to confirm every DOT-recordable crash is documented, complete, and ready for an auditor.
Accident Register
- ☐ Register covers all DOT-recordable accidents from the last 3 years
- ☐ Date, city, and state of each accident listed
- ☐ Driver name recorded for every entry
- ☐ Number of injuries and fatalities noted
- ☐ Hazmat releases (other than fuel) identified
Supporting Documents
- ☐ Police reports filed with each accident record
- ☐ Insurance claims and correspondence retained
- ☐ Driver written statements collected
- ☐ Photos, tow receipts, and repair estimates on file
- ☐ Copies of state or insurer accident reports kept
Post-Accident Follow-Up
- ☐ Post-accident drug and alcohol tests completed when required
- ☐ Reasons documented if a required test was not done
- ☐ Crash Preventability Determination (DataQs) filed where eligible
- ☐ Corrective actions and driver retraining recorded
- ☐ Vehicle repairs and inspections logged before return to service
Pro tip: Compare your accident register against your FMCSA SMS crash data. Missing or mismatched entries are a common audit finding.
Section 7 · Audit-Day Preparation
Ready for Audit Day
When an auditor calls, organized records and a calm, prepared approach make all the difference. Use this final checklist in the days before and on the day of your DOT compliance review.
Before the Auditor Arrives
- ☐ Confirm the audit date, time, format (on-site or remote) and the list of requested documents
- ☐ Name one point of contact who knows where every record is kept
- ☐ Organize files by category: driver files, maintenance, HOS, drug and alcohol, insurance, accidents
- ☐ Run a final internal review and fix any missing signatures, dates or expired documents
- ☐ Pull your FMCSA SMS / CSA scores and be ready to explain any alerts
- ☐ Scan and back up records so they can be shared electronically if needed
On Audit Day
- ☐ Have your USDOT number, MC number and company information ready
- ☐ Provide a quiet workspace and only the records that are requested
- ☐ Answer questions honestly and clearly — don't guess or volunteer extra information
- ☐ Keep a log of every document provided and every question asked
- ☐ Ask for clarification on any finding before the auditor leaves
- ☐ Note any violations and the deadline for a corrective action plan
READY FOR YOUR NEXT AUDIT?
Not sure your records would pass? Let’s review them together.
A self-audit is a great start, but gaps in driver files, HOS logs or drug and alcohol records can still lead to costly violations. MD Carrier Compliance Services will walk through your records, flag issues before the DOT does and help you get audit-ready with confidence.