Top Recordkeeping FAQs on CMV Vehicle Inspections and Maintenance

Commercial vehicle inspections are critical to highway safety. Yet safety managers, mechanics, and drivers frequently have questions about the paperwork they need to fill out and retain. We'll look at some of their commonly asked questions about vehicle inspections and maintenance recordkeeping.

However, before we jump into that, we need to clarify that these FAQs apply to anyone who operates a Commercial Motor Vehicle (CMV) as defined in section 390.5 of the Federal Motor Carrier Safety Regulations (FMCSRs). These rules apply to motor vehicles used in interstate commerce, making them subject to federal safety rules instead of vehicles operating in intrastate commerce within one state, subject to that state's laws. States typically follow the same federal regulations, but some states have a different definition for what constitutes a CMV. If you operate in intrastate commerce, it's essential to know your state's requirements and how those rules differ from federal standards.

Drivers do not need to carry a copy of the last completed DVIR or even last week's or last month's DVIRs. They don't even need to have blank DVIRs. In 1998, the Federal Motor Carrier Safety Administration (FMCSA) removed the drivers' requirement to carry their last completed DVIR in the vehicle. Today, a driver not having a copy of a previous DVIR to show an officer is not in violation, even if the officer asks to see it.

Still, some carriers see the value in the vehicle inspection recordkeeping process, in particular, the use of electronic DVIRs, or eDVIRs.  They automate the collection of odometer readings to ensure timely preventive maintenance (PM), help fleet professionals stay on top of compliance gaps through notifications of overdue maintenance and out-of-service (OOS) defects, and provide an additional record of compliance with the FMCSRs in the event of a crash. The Encompass® Fleet Management System and the Encompass® DVIR mobile app meet these carrier expectations and more.

Drivers do not need to carry the annual long inspection form IF they have an annual inspection decal on the vehicle. But it is legal to possess the long form instead of the decal - they need one or the other, but not both.

You are required by law to keep accurate and thorough records, which must include:

Vehicle information

• Make and model
• VIN and fleet number
• Tire size
• Preventive maintenance schedule

12-month record of inspection, maintenance, and repairs

• 14 months for annual inspections
• Three months for DVIRs
• Length of ownership plus three years for engine changes

You need documentation to show that individuals conducting your annual inspections, including third parties, are qualified to do so and have at least a year of experience and/or training on annual inspections.

Digital or electronic recordkeeping methods are allowed under section 390.32. You are required to ensure documents:

1. Contain all the necessary elements (including signatures),
2. Are stored for as long as required, and
3. Are accessible for auditing.

You can scan in paper forms or use electronic systems to create documents electronically. Electronic records and fleet management systems help you avoid problems that pop up with paper, like routing DVIRs to everyone who needs to see them, dealing with multiple plies and carbons, drivers misplacing documents or forgetting to sign them, and so on. If you haven't gone electronic to maintain your records, consider an automated fleet management system like Encompass. It saves a lot of time and ensures compliance with the FMCSRs.

An exception in section 390.3 is offered in the regulations removing the maintenance file requirements for vehicles that you control for less than 30 days.

Request your free copy of J. J. Keller's BIG 5 Roadmap for a Strong FMCSA Compliance Program for best practices, risks, and requirements related to FMCSA maintenance and inspections. This 28-page guide also covers fleet legalization, hours of service, as well as driver qualification, and alcohol and drug testing.