Key takeaways from the DOT Recordkeeping FAQ webinar
For many carriers, Department of Transportation (DOT) compliance management seems to always break down in the same familiar place: recordkeeping. Documentation requirements are detailed, deadlines are strict, and enforcement has shifted to a faster, digital-first audit model.
In a recent webinar hosted by U.S. Compliance Services (USCS), compliance experts Alex Elias and Steven Harz answered the most common recordkeeping questions they hear from carriers and explained why paperwork issues still account for nearly 60% of DOT audit violations.
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The Real Cost of Recordkeeping Violations
Recordkeeping violations remain so common because the DOT doesn’t judge intent; it judges evidence. And the rules are harsh.
“I assure you, the DOT doesn’t care why it wasn’t done,” Harz said during the webinar. Whether it’s unclear regulations, lack of effort, or things falling through the cracks, carriers are still held accountable.
Missing or incomplete records often trigger a chain reaction. A paperwork violation can lead to deeper audits, worsening Compliance, Safety, Accountability (CSA) scores, increased insurance scrutiny, and added legal exposure after accidents.
“People always think in terms of DOT fines,” Harz added. “But the impact goes beyond that. Your CSA score affects who will hire you, what you pay for insurance, and how closely the DOT watches you going forward.”
Clearinghouse Documentation is a Top Recordkeeping Issue
While the webinar covers a range of compliance areas, Clearinghouse documentation surfaced repeatedly as a top risk area.
Despite being in effect for years, Federal Motor Carrier Safety Administration (FMCSA) Drug and Alcohol Clearinghouse violations remain among the most frequently cited audit findings. These issues are rarely complex; they’re procedural.
“It’s very straightforward,” Harz said. “You just have to put forth the effort to do it.”
Common failures discussed in the webinar included missed pre-employment queries, annual limited queries completed outside the required 365-day window, failure to retain proof of queries, and missing driver consent documentation.
Harz also emphasized the importance of getting driver consent before running queries, as federal law requires this of all background screening processes. “You can’t run a background check without consent,” he said.
Driver Qualification Files Are Still a Major Weak Spot
Another recurring audit issue discussed during the session was incomplete or improperly maintained Driver Qualification Files. Harz emphasized that one mistake continues to show up across audits: using a generic employment application instead of a DOT-compliant driver application.
“If you have a generic job application in a driver qualification file, that file is non-compliant,” he said. “That’s one of the most common problems we see, especially with private carriers.”
Driver Qualification Files have to be kept separate from personnel files, Motor Vehicle Reports must be obtained directly by the employer, and Safety Performance History requirements still apply even with the Clearinghouse in place.
Harz also noted that many carriers do well during hiring but struggle to maintain files over time. “A lot of companies do a spectacular job with that initial driver file and do a horrible job making sure it remains up to date,” he said.
Record Retention Is About Access, Not Just Storage
“How long do I keep this?” remains one of the most common compliance questions, and the webinar spent significant time clarifying retention requirements.
Carriers are required to retain documentation for drug and alcohol testing, Clearinghouse activity, Driver Qualification Files, and Hours of Service records, including Electronic Logging Device data and supporting documents.
But retention alone is not enough. Digital audits have dramatically shortened response times. In the past, auditors might give 30 days’ notice. Now it’s often two days. “They could call you on a Monday, say, we’re going to do this on a Wednesday,” Harz said. “Your amount of runway to get stuff cleaned up is lessened.”
Records must be stored securely, access-controlled, and readily retrievable. Improper storage, missing backups, or mixing DOT records with non-DOT files can all result in violations even when documentation technically exists.
Paper files, single-computer storage, and outdated systems create serious risks in a digital audit environment where records must be transmitted quickly and securely.
Hours of Service Records Still Require Careful Oversight
Hours of Service violations continue to rank among the most cited audit findings, and the webinar addressed several persistent problem areas.
Carriers must retain Records of Duty Status, maintain backup Electronic Logging Device data, and preserve supporting documents such as fuel receipts and bills of lading. This responsibility does not disappear when switching vendors.
“That data belongs to you,” Harz said. “Not the provider. You need to make sure you keep it.”
Why Digital Recordkeeping Prevents Violations Before They Start
Throughout the webinar, Elias and Harz returned to one consistent theme: prevention matters more than cleanup. Whether carriers manage compliance internally or work with a partner, the key is having a system that keeps files audit-ready at all times.
Centralized digital recordkeeping systems help carriers track deadlines, receive alerts, maintain secure access, and identify compliance gaps before they become violations. Paper-based or fragmented processes increase the risk of missing something.
Watch the DOT Recordkeeping FAQ Webinar On Demand
This recap highlights the key takeaways, but our full webinar includes deeper explanations, real-world examples, and detailed answers to common compliance questions.
Watch the webinar to hear the full discussion and learn how carriers can strengthen their DOT recordkeeping programs before enforcement does. With documentation issues still driving the majority of DOT audit violations, consistent and accurate recordkeeping is one of the most effective ways to reduce risk.
