1. Recordkeeping & Audits
Dotting all the i‘s for the DOT

2. Today’s Webcast Who has to comply Driver records Vehicle records
Driver Qualification, Drug/Alcohol, Training
Hours of service
Vehicle records
IFTA/IRP
Other DOT-related records
Recordkeeping & audit considerations
Copyright © 2013 J. J. Keller & Associates, Inc.® All rights reserved.

3. Applicability
Operators of “commercial motor vehicles” (CMVs) as defined in 49 CFR §390.5:
Interstate commerce, public roadways; and
10,001 lbs. or more (rating or actual); or
designed or used for 9+ passengers (including driver) for compensation, or 16+ passengers not for compensation; or
placarded for hazardous materials.
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4. Applicability
Operators of “commercial motor vehicles” (CMVs) as defined in §383.5 & 382.5:
Interstate OR intrastate commerce; and
GCWR or GCW of 26,001 lbs. or more, including trailer(s) with a GVWR or GVW of more than 10,000 lbs.; or
GVWR or GVW of 26,001 lbs. or more; or
Designed to transport 16 or more passengers, including the driver; or
Used for placarded hazmat.
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5. Why Recordkeeping?
Records are your proof of compliance with FMCSRs and other regulations
Regulators rely on you to document your compliance activities
Having compliant records starts with compliance
See Topic Index: Recordkeeping
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6. Driver Qualification File
Document
Rule
Retention
Driver application
§391.21
Employment,
plus 3 years
Motor vehicle record (MVR) from time of hire
§391.23
Road test form and certificate, or photocopy of CDL
§391.31
§391.33
Safety Performance History (as of 10/30/2004)
Previous employer inquiry (prior to 10/30/2004)
Annual MVR & annual review of driving record
§391.25
3 years
Annual list of violations
§391.27
Medical Examiner’s Certificate (wallet card) and any medical exemptions/waivers
§391.43
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7. Medical Certificate / MVR
If MVR contains medical certification information, then keep MVR in place of wallet card in DQ file
Obtain new MVR every time driver gets a new medical exam; place in DQ file
Applies to interstate CDL drivers
New system to be fully in place by January 30, 2014
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8. Medical Certificate / MVR
You may accept a copy of the med card until the medical data appears on the MVR, but no more than 15 days from the date the card was issued
Monitor the dates!
Use the Employee & Driver recordkeeping feature to manage driver med cards and much more!
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9. Driver Investigation History
Recordkeeping: §391.53
Requires confidentiality, unlike the rest of the DQ file
Driver Investigation History file must be in a secured location with access limited to those involved in the hiring process
May be combined with DQ file, but then entire file must be stored securely
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10. DQ/DIH Retention Document Rule Retention
Driver Qualification and Driver Investigation History files
§391.51
§391.53
3 years after termination
Record of safety performance history sent to prospective or new employers
§391.23
1 year
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11. PSP Recordkeeping
Driver’s signed consent form must be retained for 3 years
Must contain FMCSA-specified language
Subject to auditing by PSP contractor
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12. Poll Question
Do you combine your DQ, drug/alcohol, and driver investigation history files, or keep them all separate?
We combine all 3
We combine 2 of the 3
We keep them all separate
Not applicable
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13. Drug & Alcohol Records 40.333 / 382.401 / 40.25 Document Retention
Negative/cancelled test CCF/MRO results (except return-to-duty and follow-up)
1 yr from document date
Positive test CCF/MRO results
Records of refusals to test
Return-to-duty (RTD) and follow-up CCFs/MRO results (positive or negative)
Substance Abuse Professional (SAP) reports
5 yrs from document date
Documentation of failed pre-employment tests
Violation noted – 5yrs (along with RTD records)
No violation – 3 yrs
Signed receipt for policy & educational materials
Employment, plus 2 yrs
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14. Drug & Alcohol Records 40.333 / 382.401 Document Retention
DOT Drug & Alcohol Policy
While enforced and 5 years after it has been replaced/revised
Driver roster for random pull
2 years
Names selected for random tests
Tracking of who was tested
MIS/calendar-year summary
Semi-annual lab summaries
5 years
Service provider contracts
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15. Drug & Alcohol Records 382.401 Document Retention
Explanation of why a DOT post-accident drug and/or alcohol test was not completed on time
2 years
Documentation surrounding a DOT reasonable suspicion test (even if negative)
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16. Drug & Alcohol Records §382.401: Training Records
Kept for duration of employment plus 2 years:
Supervisor reasonable-suspicion training
Urine specimen collector, BAT, and STT training (if in-house)
See Training Center:
“Alcohol & Drug” training for supervisors and drivers
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17. Drug & Alcohol Records Confidentiality considerations
Secure location with controlled access (§ and § )
If combined with other files, they all have to be secured.
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18. Training Records 380.509, 380.401, 380.301/.303 Document Retention
Entry-level driver training certificate
Employment + 1 year
LCV driver-training certificate
Employment + 3 years
LCV driver-instructor qualification file
While instructor is used/employed
Other training documentation?
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19. Hours of Service
Logs and supporting documents must be kept for 6 months, in a usable form
Examples:
Accident reports
Bills of lading
Credit card receipts
Delivery receipts
Dispatch records
Fuel receipts/statements
Gate & lumper receipts
Toll receipts/billing
GPS records
Over/short/damage reports
Lessor settlement sheets
Port-of-entry reports
Phone bill statements
Traffic citations
Weight/scale tickets
E-mobile communications & tracking systems
Copyright © 2013 J. J. Keller & Associates, Inc.® All rights reserved.

20. Hours of Service: Time Records
New or occasional drivers need to show previous 7 days before operating CMVs
Shows compliance with:
60/70 hour rule, and
8/10 hours off-duty prior to first dispatch
Statement is kept by the carrier for 6 months, but driver does not need it while on the road (§395.8(j)(2))
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21. Hours of Service: Time Records
Short-haul provisions (§395.1(e))
Company must document:
Daily start time
Daily end time
Total daily on-duty time
Total time for preceding 7 days (if intermittent)
Records do not have to be in vehicle
Caution: payroll and time records are kept longer than 6 months
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22. Hours of Service: E-Logs
In the vehicle:
Instruction sheet for accessing data
Blank paper logs to cover the whole trip
List of location codes, if necessary
In the office:
Manufacturer certification
Back-up copy of electronic files, by month, kept for 6 months
Copyright © 2013 J. J. Keller & Associates, Inc.® All rights reserved.

23. Poll Question Do you store your DOT documents electronically?
Yes, most or all of them
Yes, some of them No
Copyright © 2013 J. J. Keller & Associates, Inc.® All rights reserved.

24. Vehicle Records Records for vehicles controlled for 30+ days:
Vehicle ID: company number, make, serial number, year, tire size, and name of person furnishing the vehicle (e.g., leasing company, owner-operator)
Records indicating the nature and due date of the various inspection and maintenance operations to be performed
A record of inspection, repairs, and maintenance (including date and nature), from simple fixes to preventive maintenance to major repairs
For buses: a record of tests conducted on pushout windows, emergency doors, and emergency door marking lights
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25. Vehicle Records
Must be kept for at least 12 months, where vehicle is either housed or maintained
Records on vehicles leased or sold must be kept for either:
the remaining time left on 12 months, or
6 months from when the vehicle leaves your control, whichever occurs first
Copyright © 2013 J. J. Keller & Associates, Inc.® All rights reserved.

26. Vehicle Records: Inspections
49 CFR Part 396
Document
Retention
Daily vehicle inspection report (DVIR)
3 months
Annual inspection form
14 months
Proof of annual inspection in or on vehicle (report form or decal)
Continuously
Roadside inspection forms
12 months
Evidence of inspector qualifications
Employment + 1 yr
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27. Vehicle Records: Inspections
Carrier is responsible for:
Evidence of annual inspector credentials (§396.19)
Evidence of brake inspector credentials for carrier employees (§396.25)
At least one year of experience and/or training, plus knowledge of the rules
Keep records until 1 year after employee stops performing inspections
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28. Accident Records
For each “accident” as defined in §390.5 for the past 3 years:
Records
Retention
Rule
Accident register:
Date & location
Driver’s name
Number of injuries/fatalities
Whether hazmat was released
Copy of accident report
3 years
390.15(b)
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29. Financial Responsibility
Proof of insurance:
Records
Location
Rule
MCS-90 (MCS-90B),
MCS-82 (MCS-82B), or
FMCSA authorization to self-insure
Principal place of business
387.7(d) and (d)
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30. IFTA and IRP Recordkeeping
International Fuel Tax Agreement (IFTA)
International Registration Plan (IRP)
Qualified/Apportionable vehicles:
>26,000 pounds GVW or RGVW, single vehicle or combination
3 or more axles, regardless of weight
Copyright © 2013 J. J. Keller & Associates, Inc.® All rights reserved.

31. IFTA/IRP Distance Recordkeeping
Distance records captured on an individual vehicle basis on the individual vehicle distance record (IVDR), also referred to as:
Individual vehicle mileage record (IVMR)
Trip sheets
Trip reports
Drivers must capture certain information on the trip reports
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32. IFTA/IRP Distance Recordkeeping
Trip reports must include:
Date of trip, starting and ending
Trip origin and destination
Routes of travel
Beginning/ending odometer readings
Total trip miles/kilometers
Miles or kilometers by jurisdiction
Unit number or vehicle identification number
Vehicle fleet number
Registrant’s name
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33. Electronic Distance Recordkeeping
On-board devices or global positioning systems (GPS) may be used to track distance
IFTA electronic systems requirements in IFTA Procedures Manual, Section P600
IRP electronic systems requirements in IRP Plan, section 1010 (eff. 7/1/13)
Copyright © 2013 J. J. Keller & Associates, Inc.® All rights reserved.

34. Tax-Paid Fuel Documentation
IFTA licensees must maintain fuel records in order to take tax-paid fuel credits on the IFTA quarterly return
Fuel is purchased at the pumps (retail) or carriers may maintain bulk fuel storage
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35. Tax-Paid Fuel – Retail Tax-paid fuel receipts must include:
Vehicle’s plate or unit number
Purchase date
Seller’s name and address
Number of gallons/liters purchased
Fuel type
Price per gallon/liter or total sale
Unit numbers
Purchaser’s name
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36. Tax-Paid Fuel – Bulk Bulk fuel records must contain:
Date of withdrawal from bulk fuel tank
Number of gallons or liters
Fuel type
Unit number or other details identifying the vehicle
Purchase and inventory records to show that fuel tax was paid
Carriers must also maintain bulk fuel reconciliations
Copyright © 2013 J. J. Keller & Associates, Inc.® All rights reserved.

37. IFTA/IRP Record Summaries
Monthly summaries show total distance of the vehicle by jurisdiction and total distance and total fuel for the month
Quarterly summaries also required under IRP
Get your questions answered through the Personal Assistant feature found on FleetMentor and receive answers within one business day.
Copyright © 2013 J. J. Keller & Associates, Inc.® All rights reserved.

38. Record Retention and Organization
IFTA:
4 years from tax return due date or filing date, whichever is later
IRP:
3 years following the close of the registration year, in effect 5 ½ years
Registration year January 2013-January 2014
Based off records from July 1, 2011, to June 30, 2012
January 2014, plus 3 years, is January 2017
Copyright © 2013 J. J. Keller & Associates, Inc.® All rights reserved.

39. IFTA/IRP Audits What do auditors look for? Internal controls Gap miles
No odometer readings
Inconsistent distance reporting
High/Low MPG/KPL
Unused IFTA decals
See Topic Index: International Fuel Tax Agreement (IFTA) and International Registration Plan (IRP)
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40. Business Records Corporate and general records
Financial and accounting
Property and equipment
Personnel and payroll
Insurance and claims
Shipping and agency documents
Transportation of household goods
See Appendix A to Part 379
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41. Recordkeeping Basics §390.29, Location of records or documents.
May store records at:
Principal place of business,
Regional office, or
Driver work-reporting location
(Unless otherwise specified in FMCSRs)
Must be made available to FMCSA within 48 hours at your principal place of business
Copyright © 2013 J. J. Keller & Associates, Inc.® All rights reserved.

42. Recordkeeping Basics §390.31, Copies of records or documents.
Acceptable formats: scanned, microfiche, photocopies, digital
Must be as legible as original to authenticate signatures if necessary
May destroy originals once suitably scanned
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43. Potential Liability
Be sure to speak with legal counsel before tossing a record if the vehicle or driver is involved in a lawsuit
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44. Closing Thoughts FMCSRs list minimum retention periods
Optional records in your files can and will be audited for violations if presented to enforcement
Address problems but don’t try to cover them up
Never make matters worse by falsifying documents or creating fraudulent records
Copyright © 2013 J. J. Keller & Associates, Inc.® All rights reserved.

45. FleetMentor: Recordkeeping & Audits
Topic Index:
Toolbox:
Recordkeeping
Roadside Inspections Tracking
FMCSA recordkeeping
Roadside inspections
FMCSA Scorecard
Inspection Selection System
Motor Carrier Safety Audit
Accident File/Investigation and Tracking (DOT)
Vehicles & Equipment
Employees & Drivers
IFTA
Policy & Procedure Handbooks
Training Center
Accident Register
Classroom & Online Training
Best Practice & Quick Studies
“Recordkeeping Requirements of the FMCSR”
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46. Thank You for Participating! Roadside Warning vs Violations vs
Join us for FleetMentor’s Next Webcast:
Roadside Warning vs Violations vs
Out of Service:
The difference between success and failure
Thursday, April 25, :00 PM Central Time

47. Due to the constantly changing nature of government regulations, it is impossible to guarantee the total and absolute accuracy of the material contained herein or presented. J. J. Keller & Associates, Inc., cannot and does not assume any responsibility for omissions, errors, misprinting or ambiguity contained. J. J. Keller, shall not be held liable in any degree for any loss, damage or injury caused by any such omission, error, misprinting or ambiguity present. It is made available with the understanding that J. J. Keller is not engaged in rendering legal, accounting or other professional service. If legal advice or other expert service is required, the services of such a professional should be sought.