Truck maintenance records: what to keep and for how long

Why maintenance records matter

A maintenance program you cannot show on paper does not exist as far as an auditor is concerned. In the US, the records required by 49 CFR 396.3 are how a carrier proves it systematically inspects, repairs and maintains its vehicles. In Canada, NSC Standard 11 says the maintenance standard is enforced in facility audits: the auditor picks vehicles at random, asks for their files, and checks that each file is current and complete. Failing to keep vehicle records current is recorded as a violation on the carrier’s profile and affects its safety rating.

Good records also pay off outside an audit. They show which units keep coming back for the same repair, they are the data behind your maintenance cost per mile, and documented brake measurements can save pulling wheels at the periodic inspection.

What US rules require: 49 CFR Part 396

Maintenance records (396.3)

Every motor carrier must keep records for each motor vehicle it controls for 30 consecutive days. The records must include:

1. An identification of the vehicle: company number if marked, make, serial number and year, and, if the carrier does not own it, the name of the person furnishing it.
2. A means to indicate the nature and due date of the various inspection and maintenance operations to be performed: in practice, your PM schedule.
3. A record of inspection, repairs and maintenance indicating their date and nature.
4. For buses, a record of tests on pushout windows, emergency doors and their marking lights.

The records are kept where the vehicle is housed or maintained, for 1 year, and for six months after the vehicle leaves the carrier’s control.

Driver vehicle inspection reports (396.11 and 396.13)

Drivers report in writing at the end of each day’s work on each vehicle they operated. Under the current rule, a driver does not need to prepare a report when no defect is found or reported. Before the vehicle runs again, the carrier repairs any defect likely to affect safety and certifies on the report that it was repaired or that repair is unnecessary, and the next driver reviews and signs it. The carrier keeps the report, the repair certification and the driver’s review three months from the date the report was prepared. Our DVIR guide covers the process in detail.

Annual inspection reports (396.17 and 396.21)

Every vehicle must pass a periodic inspection at least once in the preceding 12 months, with proof on the vehicle. The inspector’s report must identify the inspector, the carrier, the date, the vehicle, the components inspected and the results, and certify the inspection. The carrier keeps the original or a copy fourteen months from the date of the report, where the vehicle is housed or maintained, and must produce it on demand. If someone else did the last annual inspection, you are still responsible for obtaining the report when an official asks. If you use your own inspectors, keep evidence of each one’s qualifications while they do your inspections and for one year after.

Roadside inspection reports (396.9)

Within 15 days of a roadside inspection, the carrier certifies that the violations noted were corrected, returns the form if the issuing state asks, and keeps a copy at its principal place of business or where the vehicle is housed, 12 months from the date of the inspection.

Electronic records (390.32)

Any record Part 396 requires may be kept electronically, as long as it accurately reflects the required information, can be retained, and can be reproduced accurately when someone entitled to see it asks. Electronic signatures are allowed too.

What Canadian rules require: NSC Standard 11 and the provinces

Part A of NSC Standard 11 requires every carrier to keep, for each commercial vehicle:

• identification: licence plate number, unit or company number, make, serial number, year and tire size, and the leasing company if the carrier does not own it;
• a means to show the nature and due date of the inspection and maintenance operations to be performed;
• a record of inspections, repairs and maintenance with their date and nature, keeping all invoices and marking measurements on the company inspection forms;
• a lubrication record;
• a record of axle or suspension modifications that affect the gross vehicle or gross axle weight rating.

The standard also asks for the odometer reading at every service or repair. Records are kept where the vehicle is housed or maintained, at least two years, and six months after the vehicle leaves the carrier’s control; the standard’s compliance notes put the file at the principal place of business. It adds that many jurisdictions require proof of maintenance, such as brake repair invoices, for four or five years, and that periodic inspection reports may have to be kept up to four years.

Daily trip inspections follow NSC Standard 13: drivers forward each report within 20 calendar days, and the carrier keeps the original report and certification of repairs at least six months from the date it was prepared.

Ontario

Ontario Regulation 199/07 lists the records an operator keeps for each truck, trailer and converter dolly. Beyond identification, the schedule and a record of each inspection, maintenance and repair, it asks for who did the work, the outside shop’s invoice, the invoice for any part, the odometer reading at the end of the job, copies of annual and semi-annual inspection certificates and equivalents from other jurisdictions, and the roadside notices and reports drivers hand in.

They are kept at least two years or, for a vehicle the operator stops operating, six months after it stops, whichever period is shorter. Daily inspection reports are kept at least six months. Records sit at the principal place of business or another terminal, and electronic records may be kept elsewhere if they can be readily accessed from the principal place of business.

British Columbia

CVSE’s record-keeping guide for National Safety Code carriers lists three years for maintenance and repair records and receipts, three years for copies of current and past CVIP inspections, three months for trip inspection reports, and six months after disposal for the records of a vehicle that leaves the fleet, or hand them to the new owner. The guide notes that the Motor Vehicle Act and its regulations govern if they differ.

Quebec

The SAAQ requires the owner to keep the vehicle maintenance record at the place of business: identification (VIN, plate, make, year, owner and long-term lessor), the schedule of upcoming inspections, the work done at each service, maintenance sheets and proof of repairs. Each maintenance sheet shows the VIN, plate or unit number, odometer, date, the components checked as compliant or non-compliant, brake lining or camshaft rotation measurements for vehicles of 7,258 kg or more, and the signature of the person who did the work. The record covers the last two years the vehicle was in use and is kept 12 months after the vehicle is disposed of. Circle check reports are kept six months.

Retention periods at a glance

Where rules overlap, keep each record for the longest period that applies to you, and check your province’s current rules before you destroy anything.

A maintenance records checklist for every unit

Build the same file for every truck, trailer and converter dolly. The right-hand column shows which rules ask for each item.

Registration, insurance and permits are not maintenance records, but most fleets keep them in the same unit file because they expire on fixed dates and officers ask for them at the same time.

Organizing records by unit and getting ready for an audit

Auditors work by vehicle, so organize by vehicle. One file per unit, named by unit number and VIN, beats one big folder of invoices sorted by date. Inside each file, keep the same order every time:

1. Identification: the unit sheet, and the lease if the unit is leased.
2. Schedule: the current PM schedule and what is due next.
3. Service history: work orders and outside invoices, newest first, each with the odometer reading.
4. Inspections: the current periodic inspection report, past reports, and roadside reports with your certification.
5. Driver reports: the rolling set of driver inspection reports for the retention period.
6. Disposal: when the unit left your control, so you know when its file may be destroyed.

Set a destruction date for each record type and never purge a sold unit’s file early: both countries expect records for a while after the vehicle is gone. Electronic files are allowed under US rules and Ontario’s regulation as long as you can produce or print them when asked, and a scanned invoice attached to the right unit is far easier to find than a paper one in a shoebox.

Before an audit, pick three units at random and check each file against the checklist above: is every service there with a date and odometer, does the schedule match what was done, is the periodic inspection current, and is every driver-reported defect certified as repaired? Fix the gaps before the auditor finds them. TruckerPro’s fleet document management keeps the rest of the carrier’s files, such as permits and driver documents, in the same system.