DOT Filing System

Members have asked me how they should keep their DOT files. DOT allows you to keep them in just about any fashion that you wish, provided the driver qualification and the drug and alcohol files are kept secure with authorized access only. Here is a suggested method I have put together that seems to work well. These items do not cover every situation, but they will help 95 percent of GAWDA members.

Here is what the bullets stand for:

  • Hanging File Folders (retention period)
    • Manila File Folders (retention period)

Files and Suggested Tab Titles:

  • DOT Filing System (place this list inside the folder to use as a table of contents)
  • MCS-90 (current)
  • MCS-150 (current)
  • Hazardous Materials Registration (three years)
  • Unified Carrier Registration (only if you have CMVs in interstate commerce)(three years)
  • List of Drivers (current)
  • List of Commercial Motor Vehicles (current)
  • Accident Register
    • Accident Register (three years retention)
    • Accident Register and Accident Report Forms (blank forms)
  • DOT Accidents
    • (Place actual DOT accidents into separate manila folders)
  • Company Policy Regarding Alcohol & Controlled Substances (current version)
  • Annual Summaries of Drug & Alcohol Testing (five years of summaries)
  • Driver Supervisor D&A Substance Abuse Recognition Training (current)
  • Documentation of Brake Inspector/Adjusting Training (retained by motor carrier for period during which that individual is performing annual motor vehicle inspections for the motor carrier and for one year thereafter)
  • Documentation of Annual Inspector Qualifications (retained by motor carrier for period during which that individual is performing annual motor vehicle inspections for the motor carrier and for one year thereafter)
  • Schedule of Commercial Vehicle Maintenance (current)
  • Vehicle Maintenance Files (retained where the vehicle is either housed or maintained for a period of one year and for six months after the motor vehicle leaves the motor carrier’s control)
  • Leased Vehicles (maintenance lease only)(copies of the lease agreement)(current)
  • Roadside Inspection Reports (copy of the inspection and any repair bill, kept for one year)
  • Previous DOT audits (either State or Federal)
  • Driver Qualification Files (set up folders for each driver)
    • DQ file folder (kept for three years after leaving or ceasing driver functions)
    • Driver Drug & Alcohol File folder
  • Hazmat Training (training required every three years) (current)
  • Security Awareness Training (training required every three years)(current)
  • DOT Security Program (these three items only if required to have one)
    • Vulnerability Assessment (used for the security plan)
    • Security Plan (current)
    • In-Depth Training on Security Plan (training required every three years)(current)
  • Post Trip one (driver daily vehicle inspection forms) (three months)
  • Post Trip two
  • Post Trip three
  • Post Trip four

Many people do not have their employees doing their own brake adjustments or annual DOT vehicle inspections, so they would not need the above two files documenting the training certifications (Documentation of Brake Inspector/Adjusting training, Documentation of Annual Inspector Qualifications).

Many people do not have a maintenance lease set up for their vehicles, so they will not need the file titled “Leased Vehicles.”

Having these files set up and together in a filing system will really help you stay organized and look very good during a DOT audit.

Gases and Welding Distributors Association
Michael Dodd Meet the Author
GAWDA’s DOT, OSHA & EPA Consultant Michael Dodd is president of MLD Safety Associates in Poplar Bluff, Missouri. Members can reach him at 573-718-2887 and MLDSafety@hotmail.com.