📋 Key Takeaways
- DQ file retention: Maintain while employed + 3 years after separation
- Drug test records: Negative results 1 year; positive results and refusals 5 years
- Hours of service logs: 6 months retention required
- Vehicle maintenance: Retain while vehicle is in company control + 1 year after
- Electronic records: FMCSA permits fully electronic systems if records are readily accessible, backed up, and printable on demand
- Penalty: Each missing record can result in fines up to $16,864 during compliance reviews
What Are DOT Recordkeeping Requirements?
DOT recordkeeping requirements are the federal mandates that specify which documents motor carriers must maintain, how long they must be retained, and how they must be organized for FMCSA compliance [1]. Proper recordkeeping is essential for passing compliance reviews—incomplete or missing records are among the most common violations discovered during FMCSA audits. Charlotte-area fleet managers must maintain records across multiple categories: driver qualification, drug testing, hours of service, vehicle maintenance, and accidents.
Charlotte DOT Exam Center provides properly formatted medical documentation that meets FMCSA recordkeeping requirements. Every DOT physical includes documentation formatted for easy filing and audit readiness.
Record Retention Periods by Category
| Record Category | Retention Period | FMCSA Regulation |
|---|---|---|
| Driver Qualification Files | 3 years after employment ends | 49 CFR 391.51 |
| Medical Examiner’s Certificate | 3 years | 49 CFR 391.51(b)(7) |
| Drug Test Results (negative) | 1 year | 49 CFR 382.401 |
| Drug Test Results (positive/refused) | 5 years | 49 CFR 382.401 |
| Alcohol Test Results (0.02 or higher) | 5 years | 49 CFR 382.401 |
| Hours of Service Records | 6 months | 49 CFR 395.8 |
| Vehicle Inspection Reports | 3 months | 49 CFR 396.11 |
| Annual Vehicle Inspections | 14 months | 49 CFR 396.21 |
| Accident Register | 3 years | 49 CFR 390.15 |
Driver Qualification File Records
The Driver Qualification (DQ) File must contain specific documents [2]:
- Driver’s Application for Employment — Including 3-year employment history, signed
- Previous Employer Safety Performance History — Drug/alcohol violations, accidents from prior employers
- Motor Vehicle Record (MVR) — Initial and annual inquiries from state DMV
- Road Test Certificate — Or notation that CDL serves as equivalent
- Medical Examiner’s Certificate (MCSA-5876) — Current and previous certificates
- Annual Review of Driving Record — Documented annual review by carrier
- Driver’s Certification of Violations — Annual certification signed by driver
Medical Documentation Requirements
The medical portion of DOT recordkeeping has specific requirements [3]:
Required Documents
- Medical Examiner’s Certificate (MCSA-5876) — Must be current; retain 3 years
- Skill Performance Evaluation (SPE) Certificate — If driver has limb impairment
- Vision Exemption Documentation — If driver has vision waiver
- Diabetes Exemption Forms — MCSA-5870 for insulin-treated drivers
Recommended Documents
- Medical Examination Report (MCSA-5875) — Complete examination record
- Specialist Clearance Letters — Cardiology, endocrinology, sleep medicine
- Previous Medical Certificates — Documentation of certification history
Drug and Alcohol Testing Records
| Record Type | Retention Period |
|---|---|
| Negative drug test results | 1 year |
| Positive drug test results | 5 years |
| Alcohol test results (0.02+) | 5 years |
| Refusal to test documentation | 5 years |
| Random selection records | Indefinitely (good practice) |
| Consortium agreements | Duration of agreement + 1 year |
| SAP reports (return-to-duty) | 5 years |
| Follow-up testing schedules | 5 years |
Electronic vs. Paper Records
FMCSA permits electronic record retention provided certain conditions are met [4]:
- Records must be readily retrievable for inspection
- Electronic signatures must comply with requirements
- Backup systems must prevent loss of records
- Original documents can be destroyed after proper electronic capture
- Records must be printable upon request
Many Charlotte-area fleets maintain hybrid systems: electronic databases for tracking with paper copies of signed documents in physical files.
Common Recordkeeping Violations
| Violation | Common Cause | Prevention |
|---|---|---|
| Missing medical certificate | Driver never submitted; expired not replaced | Track expiration dates; request copies |
| No annual MVR inquiry | Overlooked annual requirement | Calendar reminders; annual review process |
| Incomplete application | Sections skipped; unsigned | Review applications before filing |
| Missing previous employer info | 30-day investigation deadline missed | Track new hire deadlines |
| Expired drug test records | Records destroyed too early | Follow retention schedule strictly |
Charlotte DOT Exam Center Documentation
Every DOT physical examination at our facility includes properly formatted documentation:
- MCSA-5876 (Medical Examiner’s Certificate) — Laminated card + employer copy
- MCSA-5875 (Medical Examination Report) — Complete examination record
- Examiner Credentials — National Registry number for verification
- Electronic Submission Confirmation — Proof of FMCSA registry upload
- Clear Expiration Dates — Easy to track for renewal scheduling
Frequently Asked Questions
Can we keep all records electronically?
Yes, FMCSA allows fully electronic recordkeeping systems provided records are readily accessible, backed up, and printable on demand. Many carriers use fleet management software that integrates document storage with compliance tracking.
What happens if we can’t produce records during an audit?
Missing records are documented as violations during compliance reviews. Each missing document can result in fines up to $16,864. Multiple missing records may result in an Unsatisfactory safety rating and potential out-of-service orders.
How should we organize driver files?
Best practice is alphabetical by driver name with consistent internal organization. Each file should have tabbed sections: application/employment, medical, MVR/driving record, drug testing, training certifications. Maintain a master index of all active and separated drivers.
When can we destroy old records?
Follow the retention periods strictly. Create a records destruction schedule and document what was destroyed and when. Never destroy records that are subject to ongoing investigations or litigation holds.
Get Audit-Ready Documentation
Charlotte DOT Exam Center
8415 Pineville-Matthews Road, Suite 102
Charlotte, NC 28226
Phone: 704-544-3494
Email: appt@tebbyclinic.com
References
- [1] FMCSA. Motor Carrier Safety Regulations. FMCSA.dot.gov
- [2] 49 CFR § 391.51 – General requirements for Driver Qualification Files. eCFR.gov
- [3] 49 CFR Part 391 Subpart E – Physical Qualifications and Examinations. eCFR.gov
- [4] 49 CFR § 390.31 – Electronic documents and signatures. eCFR.gov
