Direct Answer
To prepare for an FMCSA compliance review, organize your Driver Qualification files, Hours of Service records, vehicle maintenance and inspection records, and corrective action documentation for any past violations. Auditors look for evidence that your safety management practices are real and functioning, not just that paperwork exists.
What This Means
An FMCSA compliance review (formerly called a compliance audit) is an on-site examination of a motor carrier's records, practices, and safety management systems. Investigators evaluate your carrier against federal safety regulations.
The review results in one of three safety ratings:
- Satisfactory: Your safety management programs adequately prevent unsafe driving and unsafe vehicles.
- Conditional: Deficiencies were found in some areas but not a systemic failure.
- Unsatisfactory: Significant safety management failures found; may result in operations shutdown.
A carrier can also be reviewed without a rating change, resulting in violations, civil penalties, or consent orders.
What Triggers a Compliance Review
- Elevated CSA BASIC scores (particularly above intervention thresholds in multiple BASICs)
- A serious crash involving fatalities or injuries
- A complaint filed with FMCSA
- A carrier that has been granted new authority and is selected for a new entrant safety audit
- Routine selection as part of FMCSA's compliance review program
You may receive advance notice (several days to a few weeks) or very little notice depending on the type of review.
What FMCSA Auditors Evaluate
| Category | Key Documents Examined |
|---|---|
| Driver Qualifications (Part 391) | DQ files, medical certificates, CDL copies, MVR checks |
| Hours of Service (Part 395) | ELD records, RODS for last 6 months, time card/payroll cross-reference |
| Driver Fitness | DQ file completeness, drug/alcohol pre-employment and random testing records |
| Controlled Substances & Alcohol (Part 382) | Drug and alcohol testing program documentation |
| Vehicle Inspection / Maintenance (Part 396) | Inspection records, maintenance records, DVIR logs |
| Accident Register (Part 390) | Accident register for crashes meeting FMCSA thresholds in past 12 months |
30-Day Preparation Checklist
Driver Qualification Files (Part 391)
- ☐ Pull DQ files for all drivers active in the past 12 months
- ☐ Verify: employment application, CDL copy (current), medical certificate (current), MVR (at hire + annual), previous employer contacts, road test certificate
- ☐ Flag and resolve any incomplete or expired documents before the review
Hours of Service Records (Part 395)
- ☐ Pull ELD records for all drivers for the past 6 months
- ☐ Verify ELD device compliance (current mandate)
- ☐ Check for HOS violations your own system flagged, resolve and document
- ☐ Cross-reference ELD records with payroll/fuel receipts to verify accuracy
Vehicle Maintenance (Part 396)
- ☐ Pull maintenance records for all vehicles active in the past 12 months
- ☐ Verify: annual inspection (every 12 months per 396.17), DVIR completion by drivers, repair orders for any defects noted
- ☐ Compile corrective action files for any past roadside violations
Drug & Alcohol Testing (Part 382)
- ☐ Verify you have a compliant testing program with a certified FMCSA-registered C/TPA
- ☐ Pull testing records: pre-employment, random, post-accident, reasonable suspicion
- ☐ Verify random testing pool size and selection documentation
- ☐ Confirm MRO and SAP records are current for any positive tests
Accident Register (Part 390.15)
- ☐ Compile accident register for last 12 months (crashes above threshold: fatality, injury requiring immediate medical attention, or disabled vehicle towed)
- ☐ Verify each entry includes: date, location, driver, injuries, fatalities, hazmat release, vehicles involved
During the Review
- Be cooperative but organized. Produce documents promptly and in order.
- Do not volunteer information beyond what is asked. Answer questions directly and specifically.
- If a document cannot be located, say so immediately. Do not present substitutes or approximations.
- Assign one person to accompany the investigator at all times.
- Take notes. Document every document requested, every question asked, and every finding mentioned.
After the Review
- Request a copy of the preliminary findings before the investigator leaves if possible.
- Respond to any findings promptly with corrective action documentation.
- If you receive a Conditional or Unsatisfactory rating, you have the right to petition FMCSA for a rating change after demonstrating corrective action.
Evidence Checklist
- ☐ Complete, organized DQ files for all active drivers
- ☐ 6 months of ELD / RODS records
- ☐ 12 months of vehicle maintenance and inspection records
- ☐ Drug and alcohol testing program documentation
- ☐ Accident register (last 12 months)
- ☐ Corrective action files for any past violations
Prevention Tips
Treat every month like an audit is coming next month. Carriers that maintain continuous document compliance are far less stressed when an actual review is scheduled, and far less likely to receive serious findings.
Self-audit annually. Use FMCSA's compliance review checklists (available at fmcsa.dot.gov) to audit your own records before an investigator does.
Frequently Asked Questions
Q: How much notice does FMCSA give before a compliance review? It varies. New entrant safety audits typically provide notice. Focused compliance reviews triggered by crashes or complaints may arrive with little to no advance notice.
Q: Can we fail a compliance review even if we've never had an OOS violation? Yes. Compliance reviews evaluate your records and programs, not just your roadside history. Missing drug testing records, incomplete DQ files, or lack of a maintenance program can result in a Conditional or Unsatisfactory rating.
Q: What happens if we get a Conditional rating? A Conditional rating means deficiencies were found but your safety management is not deemed inadequate overall. FMCSA will typically provide a corrective action opportunity. You can petition for a rating upgrade after demonstrating compliance.
Q: Does a previous satisfactory rating protect us in a new review? No. Each compliance review is evaluated independently based on current records and practices.