Over the last several months, we’ve been writing about common compliance challenges we at STC have observed in our experience conducting mock DOT compliance audits for clients. This month, we’ll be highlighting common problems we see when reviewing vehicle maintenance files.  

Producing thorough, compliant vehicle maintenance files is a challenge for almost every fleet we investigate. The challenge is inherent to the nature of the trucking industry. 

Each vehicle maintenance file has a combination of three buckets of activity: preventative (or scheduled) maintenance, demand maintenance, and emergency maintenance. Often, each of these is handled by a combination of vendors and at different intervals for different types of equipment, making compiling and maintaining a complete set of record, often provided in a combination of paper and electronic format, of a vehicle’s maintenance difficult.  

Preventative maintenance. This refers to routine inspection and maintenance activities that can be scheduled ahead of time. The schedules are often determined by the original equipment manufacturer’s recommendations and handled either in-house or via a maintenance agreement with a reputable third-party shop. In general, most motor carriers have a handle on this, though producing paperwork that can demonstrate compliance can be a challenge. Motor carriers should be sure they have a record of the recommended inspection and maintenance schedules for each vehicle and that they can trace work orders back to those repairs, confirming they were completed on time.  

Demand maintenance. This refers to the protocol motor carriers use to identify maintenance problems on the fly. Think driver vehicle inspection reports (DVIRs), pretrip inspections, and the processes that go into ensuring required repairs are made before the truck is dispatched. This one can be the most challenging for carriers and drivers who are disincentivized to identify pending maintenance problems. That’s because waiting for repairs can mean a service failure and/or fewer miles in the driver’s next paycheck. As a result, this sometimes becomes a proforma exercise that lacks scrutiny or oversight. Many motor carriers have daily electronic DVIR programs that almost never identify critical equipment defects. If they do, they may go unresolved for days or even weeks because motor carriers fail to close the loop on the process. Any DVIR that indicates a safety-related vehicle defect must be reviewed, repaired (if necessary), and signed off on by a manager or a mechanic before the truck is dispatched again. Furthermore, the next driver to operate that vehicle must review the previous day’s DVIR and certify the vehicle is safe to operate.  

Emergency maintenance. Emergency maintenance often kicks in when the two previous inspection and maintenance types are ineffective. Think of a truck being put out of service following a roadside inspection or stranded on the side of the road due to an unanticipated part failure. This is the most expensive category of maintenance problems and often relies on mobile mechanics to resolve. The major compliance challenge here is often collecting and filing the repair orders that demonstrate that out-of-service orders or roadside calls were corrected before the vehicle was allowed to continue down the road. Investigators will insist on seeing these records in the vehicle file and will look to match these repair orders with roadside inspection reports or DVIR entries or lack thereof. The major challenge for carriers here is that these records are seldom integrated with the fleet management software they use to monitor vehicle wellness or retained in vehicle maintenance files.  

For many motor carriers, each maintenance category is handled using different protocols, often by varying people or vendors who rely on different documentation or software suites to track invoices and submit work orders. When asked by an investigator, motor carriers must produce complete vehicle maintenance files, regardless of which process or vendor handled the issue. The ability to combine these processes into one coherent record is a universal challenge. Those who master it will rise to the top and stay off the radar of inspectors.