Trucking and Freight Editing and Proofreading Services

Forms built from 49 CFR 396.11 can copy the list and still drop two words from the sentence above it. The rule says a driver's report "shall cover at least the following parts and accessories," and eleven are named, from the service brakes to the emergency equipment.¹ A form carrying those eleven and no more has reproduced a minimum. The duty falls on two parties: every motor carrier "shall require its drivers to report," and every driver "shall prepare a report in writing at the completion of each day's work on each vehicle operated."¹ That sentence excepts intermodal equipment tendered by an intermodal equipment provider, which paragraph (b) covers separately.¹ Three kinds of operation sit outside the section: "a private motor carrier of passengers (nonbusiness), a driveaway-towaway operation, or any motor carrier operating only one commercial motor vehicle."¹

A report that is sometimes not written

Whether a report exists depends on what was found. "Drivers are not required to prepare a report if no defect or deficiency is discovered by or reported to the driver."¹ Where one is prepared, it "must identify the vehicle and list any defect or deficiency discovered by or reported to the driver."¹ The defects meant are those "which would affect the safety of operation of the vehicle or result in its mechanical breakdown."¹

The driver signs the report, and on two-driver operations one signature suffices "provided both drivers agree as to the defects or deficiencies identified."¹ On a report which lists any defect or deficiency, the motor carrier or its agent certifies "that the defect or deficiency has been repaired or that repair is unnecessary."¹ That is done "before the vehicle is operated again."¹ The carrier maintains the report, the certification of repairs, and the certification of the driver's review "for three months from the date the written report was prepared."¹

A driver about to drive has three duties under 49 CFR 396.13. The first is being satisfied that the vehicle is in safe operating condition. The second is reviewing the last report where 396.11(a)(2)(i) called for one.² The third is signing it "to acknowledge that the driver has reviewed it and that there is a certification that the required repairs have been performed."² That signature requirement does not apply to listed defects on a towed unit which is no longer part of the vehicle combination.²

The periodic inspection, and who keeps the paper

Section 396.17(c) is a prohibition, not a schedule, and it binds two parties. A motor carrier "must not use a commercial motor vehicle, and an intermodal equipment provider must not tender equipment to a motor carrier for interchange," unless two conditions hold.³ Each component identified in appendix A has passed an inspection "at least once during the preceding 12 months," and "documentation of such inspection is on the vehicle."³

"The original or a copy of the inspection report shall be retained by the motor carrier, intermodal equipment provider, or other entity that is responsible for the inspection."⁴ The period is "fourteen months from the date of the inspection report."⁴ The report is kept where the vehicle is either housed or maintained.⁴

Evidence of the inspector's qualifications carries a period of its own. Carriers and providers retain it while that individual performs annual inspections for them "and for one year thereafter."⁵ The same paragraph removes the duty in one case, for "those inspections performed as part of a State periodic inspection program."⁵

A driver qualification file holds eight enumerated items and "shall be retained for as long as a driver is employed by that motor carrier and for three years thereafter."⁶ Five of the eight may be removed three years after the date of execution.⁶ The file is kept whole while part of it becomes removable.

The commercial records have a schedule of their own. Under 49 CFR part 379, consignors' shipping orders and copies of bills of lading are retained one year.⁷ Dispatchers' sheets and registers pertaining to movement of transportation equipment are retained three years.⁷ Two records of one movement are held for different periods.

What the roadside record shows

In 2023 there were 1,994,946 vehicle inspections producing 3,097,660 vehicle violations.⁸ The most frequent single violation was an inoperable required lamp, cited 336,623 times.⁸ Next was "Operating a CMV without proof of a periodic inspection," cited 190,975 times.⁸ That row is named for the documentation, and 396.17(c) puts the inspection and the documentation in one sentence.

Three questions the page can settle

Safe operating condition and the need for a repair are matters for drivers, mechanics, and the carrier's maintenance staff. Neither is an editor's call. We are not a compliance service and we do not audit a file. Our work is on report forms, driver handbooks, maintenance procedures, and training material.

Three things in those documents are written down twice. A retention note names a period and so does the document it cites. A sentence states a count, and the list under it can be counted too. A procedure calls a part by one name, and may call the same part by a second name a page later. All client material stays confidential.

Six retention periods appear above. Some are measured from the date a document was made, and others from the day a person stopped inspecting or a driver left. A single retention note written on a maintenance file will be wrong for some of what the file holds.