FMCSA Compliance Checklist

Quarterly compliance review a safety director runs to keep the carrier audit-ready across driver qualification, hours of service, vehicle maintenance, drug & alcohol program, and accident reporting. Use this on a recurring cadence so missing MVRs, lapsed medical cards, and...

5 sections 22 steps Collects data
1

Driver Qualification Files

  1. Audit DQ files against Part 391 checklist
  2. Pull annual MVR for every active driver
  3. Run annual Clearinghouse limited query
    • Part 382.701(b) requires a limited query at least once per year per CDL driver. Confirm signed driver consent on file before running. Any 'records found' result triggers a full query within 24 hours and pulls the driver from safety-sensitive functions until resolved.

  4. Verify medical certificate expirations
    • Cross-check medical card expirations against the MVR's CDLIS medical certification status. A driver with a valid paper card but a 'not-certified' MVR status is out-of-service. Flag any card expiring within 60 days for DOT physical scheduling.

    Collects list
  5. Schedule DOT physicals with NRCME examiner
    • Book the appointment with a National Registry-certified examiner before the current card lapses; a one-day gap means the driver cannot legally operate a CMV. Send the driver the long-form medical history packet and current medication list ahead of the visit.

  6. Confirm prior-employer inquiries on file
    • Part 391.23 requires written inquiries to all DOT-regulated employers from the past 3 years, with documentation of the request even when the prior employer never responds. Common audit finding: inquiry mailed but no proof of mailing or follow-up after 30 days.

2

Hours of Service & ELD

  1. Review prior-quarter HOS exception report
    • Pull the exception report from Motive, Samsara, or your ELD of record for the last 90 days. Focus on 11-hour driving, 14-hour duty, 30-minute break, and 60/70-hour rolling violations. Repeated violations by the same driver pattern into the Unsafe Driving and HOS BASICs in CSA.

    Collects number Collects text
  2. Verify ELD registration on FMCSA list
    • Confirm the device model and firmware version still appear on FMCSA's Registered ELDs list. Devices removed from the list (revoked registration) must be replaced within 60 days or the carrier reverts to paper-log violations.

  3. Audit unassigned-driving segments
    • Unassigned drive time on a tractor must be reviewed and either claimed by a driver or annotated as yard move / shop / mechanic. Segments left unassigned beyond 14 days are an automatic finding in a Compliance Review.

  4. Counsel drivers on logged exceptions
    • Driver manager meets one-on-one with any driver showing 3+ HOS exceptions in the quarter. Document coaching in the driver file with date, exception type, and corrective action. Repeat offenders move to a written warning per the safety policy.

3

Drug & Alcohol Program

  1. Confirm random pool rate hits 50/10
    • Part 382.305 minimums: 50% controlled-substance and 10% alcohol annual rate against average driver count. Mid-year check should show carrier on pace; falling short by Q3 forces a year-end bump-up that strains the TPA and creates audit pattern risk.

    Collects list
  2. Schedule bump-up testing with TPA
    • Coordinate with the consortium (Foley, J.J. Keller, USA Mobile, etc.) to add selections in the next quarter that close the gap. Document the math behind the bump-up — auditors want to see how the carrier identified the shortfall and corrected it before year-end.

  3. Review post-accident testing decisions
    • For every recordable accident this quarter, confirm the post-accident decision matrix was applied within 32 hours (drugs) and 8 hours (alcohol). Document why a test was not required when applicable — fatality, injury with transport, or disabling damage with citation triggers mandatory testing.

  4. Verify supervisor reasonable-suspicion training
    • Part 382.603 requires every supervisor of CDL drivers to complete 60 minutes drug + 60 minutes alcohol training, one-time, documented. Verify certificates are in the personnel file for every dispatcher, terminal manager, and driver manager added in the past quarter.

4

Vehicle Maintenance & Inspection

  1. Pull annual DOT inspection expiration roster
    • Part 396.17 annual inspection sticker must be current on every power unit and trailer. Run a fleet report from Fleetio / Whip Around / RTA showing units within 60 days of expiration so shop can schedule before the sticker lapses.

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  2. Spot-check DVIRs for honest defect reporting
    • Sample 10 driver DVIRs across the quarter. A pattern of 'no defects' on a tractor that visited the shop for repairs the same week is the signature of copy-paste DVIRs — a finding that destroys post-accident defense. Coach drivers and document the corrective action.

  3. Review CSA Vehicle Maintenance BASIC trend
    • Pull the FMCSA SMS snapshot. Brake out-of-adjustment, lights, and tires are the three line items that move the Vehicle Maintenance percentile fastest. A score above the 80th percentile triggers intervention — surface this to the shop manager before the next roadside inspection.

    Collects number
  4. Confirm PM schedule adherence by unit
    • Compare A/B/C-service intervals in the maintenance system against actual completion. Units more than 10% past PM mileage get pulled at the next yard return. Skipped PMs become Part 396.3 violations during a Compliance Review even without a roadside finding.

5

Accident Register & Reporting

  1. Update the Part 390.15 accident register
    • Register must include date, city/state, driver name, number of injuries, number of fatalities, and hazmat release for every DOT-recordable accident in the prior 3 years. Auditors ask for this on day one of a Compliance Review.

  2. Classify each accident as DOT-recordable
    • DOT-recordable means a fatality, an injury with immediate medical transport from the scene, or disabling damage requiring tow. Fender-benders without injury or tow are NOT recordable, but should still be tracked internally for trend analysis and insurance reporting.

    Collects list
  3. Complete root-cause investigation packet
    • For each recordable accident, assemble the packet: police report, driver statement, dashcam clip, ELD log for 24 hours pre-accident, post-accident drug/alcohol results, photos, witness contacts. Send to insurance carrier and retain in the driver file for 3 years minimum.

    Collects file Collects paragraph
  4. Brief leadership on findings and corrective actions
    • Safety director walks the operations director and CEO through trends, BASICs movement, DQ findings, and any open audit risks. Document corrective actions with owners and target dates so the next quarterly review can verify closure.

    Collects signature

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Sections 5
Steps 22
Category Transportation
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