Top 5 Recordkeeping Mistakes Leading to Violations
FMCSA audits are document-heavy—and lapses in recordkeeping can trigger citations, fines, or conditional ratings. Below are five of the most common recordkeeping oversights that DOT auditors frequently cite, along with guidance on how to prevent them.
1. Missing Driver Qualification (DQ) File Components
A driver’s qualification file must include more than just a copy of their CDL.
Commonly Missing Items:
Medical Examiner’s Certificate (not merged or updated into MVR)
Road test certification or equivalent CDL documentation
Notes to the Annual MVR reviews
Driver’s employment application
Regulation: 49 CFR § 391.51
Compliance Tip: Use a DQ file checklist to audit driver files. conduct DQF audits to identify and collect missing records.
2. Inadequate Hours-of-Service (HOS) Documentation
Even with ELDs, timekeeping records should be consistent and verifiable.
Frequent Issues:
Unassigned driving time left unresolved
Missing driver certifications on edited logs
Incomplete records for short-haul drivers relying on exemptions
Regulation: 49 CFR § 395.8
Compliance Tip: Set up a system to review HOS logs. Address unassigned drive time. Confirm accurate time records for short-haul exempt drivers.
3. Failure to Maintain Drug & Alcohol Program Records
Drug and alcohol testing records are scrutinized and subject to retention timelines.
Common Violations:
No evidence of pre-employment drug test
Random selection process not documented
Missing MIS annual summary (if applicable)
Drug & alcohol clearinghouse inquiries missing
Regulation: 49 CFR § 382.401
Compliance Tip: Retain positive test results for five years and all negative test records for at least three years. Maintain chain-of-custody forms. Conduct annual clearinghouse inquiries of the fleet.
4. Improper Vehicle Maintenance Records
Maintenance files should show a full service history and current inspection status.
Typical Gaps:
Missing annual DOT inspections
No repair documentation for violations discovered during roadside inspections
Incomplete or outdated preventative maintenance records
Regulation: 49 CFR § 396.3–396.17
Compliance Tip: Keep vehicle maintenance logs in a standard format. Each unit should have its own file or digital profile with inspection dates that match DOT inspection dates and repair records.
5. Failure to Retain Required Records for the Appropriate Period
Retention timeframes vary by record type. Discarding files too early—or holding unnecessary records—can cause audit confusion.
Examples:
Accident registers should be maintain for 3 years
DQ file contents have varying retention based on driver status
Supporting documents for HOS logs should be retained for 6 months
Regulation: Refer to FMCSA retention requirements and 49 CFR § 390.29
Compliance Tip: Build a retention schedule into your record management policy. Automate purge alerts for outdated files.
Audit-Readiness Action Item Best Practices
Select three driver files and two vehicle files this week. Use a recordkeeping checklist to confirm:
Presence of required documents
Accurate retention periods
Consistency between digital and physical records
