Training Recordkeeping Tips

Motor carriers must maintain a lot of records on their drivers. The Federal Motor Carrier Safety Regulations (FMCSRs) specifically require some recordkeeping, and employers should keep other records as a best practice and risk management strategy.

Here are some tips about what training is required, how long to keep records of that training, and where to keep your training documents.

Required training

• Periodic inspection training for employees who perform annual vehicle inspections and brake inspector training for employees who conduct brake inspections, maintenance, service, or repairs to any CMV. Employers must keep evidence of an individual’s qualifications for at least one year after the individual stops performing inspections. Store these records in an accessible location so that they are available to an investigator during an audit.

• Entry-level driver training (ELDT) for anyone who wants to upgrade a Class B CDL to a Class A CDL; obtain for the first time a Class A or B CDL; or obtain for the first time a passenger, school bus, or hazardous materials endorsement. ELDT recordkeeping falls to the training provider. Employers are not required to have documentation of ELDT for drivers who received their CDL and/or relevant endorsements after February 7, 2022. For drivers who received their CDL and/or relevant endorsements before February 7, 2022, employers must keep ELDT certificates for the duration of employment plus one year. Keep this certificate in the driver qualification (DQ) or personnel file.

• Longer combination vehicles (LCVs) training for any driver who wants to drive a double- or triple-trailer vehicle. The FMCSRs don’t specify how long to keep these training records. Based on other requirements, a good rule of thumb would be to keep them for at least three years after the individual leaves the employer or no longer operates a CMV. These records should be kept in the DQ file.

• LCV driver-instructor training for individuals who provide LCV training to other drivers. Documentation must include evidence that the instructor has met requirements in §§380.301 and .303 and a copy of the instructor’s valid CDL and appropriate endorsements. Employers must keep these records for as long as the employer uses or employs the instructor. Store them in the individual’s DQ or personnel file.

• Drug and alcohol supervisor reasonable suspicion training for supervisors who oversee drivers of vehicles requiring a CDL. Records showing that supervisors received at least one hour of training on the effects and signs of drug abuse and one hour of training on the effects and signs of alcohol abuse should be kept for at least two years after the individual stops acting as a supervisor of drivers operating CMVs requiring CDLs. Keep these records in a secure location with controlled access in accordance with 382.401

• Hazardous materials training for individuals who handle and/or transport hazardous materials. Employers must create and retain a record of training covering at least the previous three years for each hazmat employee. These records must be kept for at least 90 days after the employee leaves a hazmat position. The regulations do not specify where these records must be stored, just that they need to be made available upon request.

• Transportation of Class 7 (radioactive) materials training for drivers transporting a highway route-controlled quantity of radioactive materials. Employers must retain a certificate of training for the duration of the individual’s employment plus three years. The certificate should be both saved in the DQ file and kept in the driver’s possession.

Training as best practice and risk management

• Training on drugs and alcohol for employees subject to Parts 40 and 382. Employers are required to provide drivers of CMVs requiring CDLs with information about drug and alcohol testing and the company’s drug and alcohol policy. Best practice is to include this in an employer’s training program. A copy of the materials and each driver’s certification of receipt must be kept for at least two years after the individual stops being covered by Parts 40 and 382. This documentation must be kept in a secure location with controlled access.

• Training on FMCSRs for all employees subject to 49 CFR Subchapter B. Section 390.3(e) of the FMCSRs is a catch-all that states drivers and employees must know and comply with the regulations that apply to their job responsibilities. Employers should document all training they conduct on the FMCSRs. Include when the training was conducted, who conducted the training, who received the training, and what the training covered. This documentation could be stored in employees’ DQ or personnel files or in a separate file for general training.

• Training on driving skills, company policies, safe use of equipment, refresher training, corrective-action training, and any other training that your company conducts. Training records offer protection in the case of an audit, investigation, or lawsuit. Train regularly, and document everything.