The Complete FMCSA Safety Audit Checklist
Preparing for an FMCSA New Entrant Safety Audit doesn't have to be overwhelming. This comprehensive checklist covers all six evaluation factors that auditors review, helping you identify compliance gaps before they become costly violations. Ensure DOT compliance and avoid automatic failure violations with this step-by-step preparation guide for motor carriers.
About The Audit & Checklist
The New Entrant Safety Assurance Program is an FMCSA program designed to educate and evaluate new motor carriers during their first 18 months of operation. The program's goal is to ensure a new carrier has implemented effective safety management systems and is compliant with the Federal Motor Carrier Safety Regulations (FMCSRs).
A safety audit will be conducted by an FMCSA-certified auditor within the first 12 months of operation, who will review your records and operational procedures. Before this time, you will usually receive a letter in the mail from the FMCSA asking you to call the listed number to complete the new entrant registration process. If you fail to contact this number, you may be placed out of service for Refusal of Audit / No Contact – if you have already filed your DOT number several months ago and still have not received this letter, please contact us right away for further instructions.
While the New Entrant Safety Audit is reserved only for those who operate under FMCSA jurisdiction (interstate), states still have the ability to, and regularly conduct, audits very similar to the FMCSA audit. Regardless of your eligibility for the new entrant audit, it is highly advised to assume you will have some sort of audit or inspection after applying for your USDOT number and to be prepared for such an occasion.
This checklist is a guide intended for preparation purposes. It is not a substitute for a thorough understanding of the Federal Motor Carrier Safety Regulations or direct instructions from the official who is conducting your audit. For complete and official information, please refer directly to the FMCSA website and the official text of the Federal Motor Carrier Safety Regulations (FMCSRs), as well as your state’s resources for any intrastate requirements.
Part A: General Operational Requirements
Regulations: 49 CFR Parts 387 & 390
This section covers the foundational records that prove your company is a legitimate, insured, and properly identified motor carrier. The auditor will verify that your company information is current with the FMCSA, that you maintain adequate insurance, and that you have a system for tracking accidents.
☐ Proof of Financial Responsibility
You have proof of current public liability insurance for bodily injury and property damage (e.g., Form BMC-91, MCS-90, etc.)
☐ USDOT Number & Vehicle Marking
All Commercial Motor Vehicles (CMVs) in your fleet are marked with the legal name or single trade name of the motor carrier and the USDOT number assigned to the carrier. Also has markings for intrastate requirements as defined by your base state.
☐ MCS-150 Updated & Accurate
Your MCS-150 form has been updated at least every 24 months, or more recently if your company information has changed.
☐ Accident Register & Supporting Documents
You maintain a register of all DOT-recordable accidents. This register must include for each accident:
Date of accident
City and State where the accident occurred
Driver's Name
Number of injuries
Number of fatalities
Whether any hazardous materials (other than fuel from the vehicle) were released
Copies of any accident reports required by state or other government entities and any supporting documentation related to those accidents are kept.
☐ Driver List
You maintain a list of drivers operating under your USDOT number with the following information:
Last Name
First Name
Date of Birth
Date of Hire
License Number
License State
Part B: Qualification of Drivers
Regulations: 49 CFR Parts 391
You must maintain a complete Driver Qualification File for every driver you employ who operates a CMV. This file demonstrates that each driver has the necessary experience and is legally, and medically qualified to operate their assigned vehicle safely.
Files must be kept for the duration of employment and for three years after employment ends.
☐ Driver's Application for Employment
You have a complete employment application on file for every commercial driver, signed by the driver.
☐ Inquiry to Previous Employers (Safety Performance History)
You have records showing you contacted all previous DOT-regulated employers from the last three years for each driver, including records of their responses and any supporting documents.
☐ Inquiry to State Agencies (Motor Vehicle Record - MVR)
An MVR was obtained at the time of hire from every state in which the driver held a license in the preceding 3 years.
An MVR is obtained for each driver at least once every 12 months thereafter.
☐ Annual Review & Certificate of Violations
You have a record of your annual review of each driver's MVR.
You have a list (or certificate) from each driver detailing any traffic violations from the past 12 months.
☐ Medical Examiner's Certificate (Med Card)
A valid Med Card is on file for every driver, and you’ve verified that their certificate was provided by an approved licensed medical examiner.
For CDL drivers, you have a copy of the MVR / CDLIS Report showing the current medical certification status.
☐ Road Test & Certification
You have obtained a copy of the driver's road test certificate, or a copy of their valid Commercial Driver's License (CDL), and it is kept on file.
☐ Entry-Level Driver Training & Other Cases
For any driver with less than one year of experience, you have proof they completed the required entry-level driver training.
Other documents such as Skilled Performance Evaluation or LCV driver training certificates when applicable.
☐ DOT Compliance
Ensure your trucking business meets all Department of Transportation regulations with our expert guidance and support. Stay safe, legal, and ahead of audits.
☐ Business Filings
Streamline your paperwork with our professional assistance to keep your filings organized and up to date.
Part C: Controlled Substances & Alcohol Testing
Regulations: 49 CFR Parts 40 & 382
You must have a compliant drug and alcohol testing program for all drivers operating CDL-required vehicles. This program is critical for ensuring drivers are not operating under the influence of prohibited substances and do not have any pending violations that require a Substance Abuse Program to be completed prior to operating.
☐ Company Workplace Policy
You have a written drug and alcohol policy that has been distributed to every driver. Includes information about the drug-free workplace and driver responsibilities.
☐ Certificate of Enrollment & Test Reports
You are enrolled in a random testing consortium or have established your own compliant random testing pool with documents to prove your enrollment.
You have records showing that drivers have been selected and tested at the required annual rates (currently 50% for drugs, 10% for alcohol [MIS REPORT]).
☐ Negative Pre-Employment Test Results
You have proof of a negative pre-employment controlled substance test result for every CDL-required driver that meets FMCSA requirements for substances tested.
☐ Supervisor Training
You have proof of a negative pre-employment controlled substance test result for every CDL-required driver that meets FMCSA requirements for substances tested.
☐ FMCSA Clearinghouse Enrollment & Management
Your company is registered in the Drug & Alcohol Clearinghouse.
You have conducted a full pre-employment query in the Clearinghouse for every CDL driver you employ.
All queries are documented, including copies of the consent forms signed by the drivers
☐ Other Test Records
You have records for any random, post-accident, reasonable suspicion, return-to-duty, or follow-up tests that were conducted.
Part D: Hours of Service (HOS) Compliance
Regulations: 49 CFR Parts 395
You must have a system in place to ensure your drivers comply with Hours of Service regulations, preventing fatigued driving. This involves utilizing and monitoring driver logs (Records of Duty Status) and retaining supporting documents to verify their accuracy. Carefully review the ROD requirements and exemptions to ensure you are keeping the required records.
☐ ELD System | Paper Logs | Time Records
All drivers must use an ELD listed on FMCSA's registered ELDs list at www.fmcsa.dot.gov/devices, unless they qualify for an exemption (e.g., short-haul exemption, drivers using paper logs 8 days or less in any 30-day period)..
☐ HOS Limits Monitoring
System to ensure drivers comply with:
11-hour driving limit after 10 consecutive hours off duty
14-hour driving window (cannot drive beyond 14th hour after coming ‘on duty’)
30-minute break after 8 cumulative hours of driving
60/70-hour limits (60 hours in 7 days or 70 hours in 8 days)
☐ ELD In-Cab Requirements
Each vehicle must have:
ELD user’s manual
Instructions for malfunction procedures and data transfer
Blank paper logs sufficient for at least 8 days
☐ 6 Month Record Retention
All driver logs and supporting documents are retained for at least 6 months from date of receipt, with ELD records backed up on a separate device.
☐ Malfunction Procedures
System in place to correct ELD malfunctions within 8 days with drivers trained to maintain paper logs during malfunctions.
☐ Exemptions Identified & Documented
You must identify which drivers qualify for ELD and HOS exemptions and maintain proper documentation to support their exempt status. Information on exemptions can be found in 49 CFR Part 395.1. This includes:
Short-haul exemption (CDL)
Short-haul exemption (Non-CDL)
8 Days in 30 days exemption
Pre-2000 Vehicle exemption
Agricultural commodity exemption
Part E: Vehicle Maintenance & Inspection
Regulations: 49 CFR Parts 396
A vehicle list record must be maintained to track vehicles / equipment in use for your USDOT Number. You must demonstrate that all commercial motor vehicles under your control are systematically inspected, repaired, and maintained to be in safe and proper operating condition at all times.
☐ Vehicle List
You maintain a vehicle list that tracks the following information:
Unit Number (if applicable)
Vehicle Identification Number (VIN)
Year | Make | Model
License Plate Number
License Issuing State
Vehicle Type / Gross Vehic
☐ Vehicle Maintenance Files
You have a dedicated maintenance file for each truck and trailer, containing:
Vehicle identification information (company number, make, model, VIN, tire size)
A schedule or record of all maintenance and inspections performed
☐ Annual Inspection Reports
Every truck and trailer has proof of a valid annual (periodic) inspection performed by a qualified inspector.
☐ Driver Vehicle Inspection Reports (DVIRs)
You have a system for collecting daily post-trip DVIRs from your drivers and a process to show that any safety-related defects listed on a DVIR were repaired before the vehicle was dispatched again.
☐ Inspector/Brake Technician Qualifications
You have proof that the individuals performing your annual inspections and brake-related maintenance/repairs are qualified under FMCSA standards.
☐ Record Retention
Maintenance records are kept for 1 year, and for 6 months after the vehicle leaves your control. DVIRs and annual inspection reports are kept for specified periods.
