Dealing with an FMCSA Compliance Review
What triggers a compliance review, what investigators examine, how safety ratings are determined, and how to prepare for and respond to an FMCSA investigation.
What Is a Compliance Review?
A compliance review (CR) is an on-site examination of a motor carrier's operations and records by an FMCSA investigator. The purpose is to determine whether a carrier is in compliance with the Federal Motor Carrier Safety Regulations (FMCSRs) and Hazardous Materials Regulations (HMRs). Compliance reviews are the mechanism through which FMCSA assigns official safety ratings.
View enforcement data for carriers on our enforcement page.
What Triggers a Compliance Review?
Compliance reviews can be triggered by several factors:
- High SMS scores: Carriers with BASIC percentiles above intervention thresholds in the CSA program may be prioritized for investigation
- Serious crash events: A fatal or severe crash may trigger an immediate investigation
- Complaints: Complaints from the public, drivers, or other carriers about unsafe operations
- New entrant follow-up: Part of the new entrant monitoring process
- Pattern of violations: Repeated high-severity violations in roadside inspections
- Random selection: Carriers may be randomly selected for review
- Follow-up: A previous conditional or unsatisfactory rating requires a follow-up review
What Investigators Examine
The compliance review is comprehensive. Investigators typically examine records and practices in these areas:
Driver Qualification Files (DQ Files)
- CDL verification and status
- Medical examiner's certificates (DOT physicals)
- Employment applications and verification of previous 3 years of employment
- Annual motor vehicle record (MVR) reviews
- Road test certificates or equivalents
- Driver training records
Hours of Service Records
- ELD compliance and data integrity
- Log accuracy and completeness for the past 6 months
- Supporting documents (fuel receipts, toll records, shipping documents)
- HOS violations: driving beyond limits, form and manner errors, falsification
Vehicle Maintenance and Inspection
- Systematic inspection, repair, and maintenance records
- Annual inspection reports for all vehicles (current within 12 months)
- Driver Vehicle Inspection Reports (DVIRs)
- Brake inspector qualifications
- Preventive maintenance schedules and records
Drug and Alcohol Testing Program
- Written substance abuse policy
- Pre-employment, random, post-accident, and reasonable suspicion testing records
- MIS (Management Information System) reports
- Clearinghouse query records
- SAP referral and return-to-duty records (if applicable)
Insurance and Authority
- Current proof of insurance
- Valid operating authority
- BOC-3 designation
Crash Records
- Accident register (all DOT-recordable crashes for past 12 months)
- Copies of crash reports
Safety Ratings
Based on the compliance review findings, FMCSA assigns one of three safety ratings:
- Satisfactory: The carrier has adequate safety management controls in place. This is the best rating.
- Conditional: The carrier has deficiencies in safety management controls. The carrier must take corrective action. Carriers may continue operating with a conditional rating but will face a follow-up review.
- Unsatisfactory: The carrier does not have adequate safety management controls. The carrier is given notice and must take corrective action. Failure to improve to at least conditional within the specified period results in an operations out-of-service order.
How to Prepare
- Organize all records: Have DQ files, HOS records, maintenance files, drug testing records, and crash reports organized and readily accessible
- Self-audit: Review your own records against the compliance review factors before the investigator arrives. Fix deficiencies now.
- Review your SMS scores: Understand which BASICs are elevated and be prepared to discuss corrective actions
- Designate a contact person: Have a knowledgeable person available to work with the investigator and answer questions
- Be cooperative and professional: Provide requested records promptly and answer questions honestly
After the Review
After the review, you will receive a report of findings. If deficiencies are identified:
- Develop a corrective action plan addressing each finding
- Implement changes promptly and document everything
- If you receive a conditional or unsatisfactory rating, you may request an administrative review within the specified timeframe
- Prepare for a potential follow-up review to verify corrections
Sources & Citations
Related records
More in Safety & Compliance
Federal Motor Vehicle Safety Standards (FMVSS) Overview
explainerAn overview of the Federal Motor Vehicle Safety Standards that apply to commercial motor vehicles, including how FMVSS differ from FMCSRs, key standards for trucks and buses, and their role in vehicle safety and compliance.
Rear Impact Guards and Underride Protection Standards
articleAn overview of rear impact guard requirements and underride protection standards for trailers and semitrailers, including FMVSS 223/224 compliance, inspection criteria, and common violations.
Understanding the Safety Measurement System (SMS) Methodology
explainerA detailed explanation of how the FMCSA Safety Measurement System calculates carrier safety scores, including data sources, time and severity weighting, peer grouping, and percentile rankings.
Post-Crash Drug and Alcohol Testing Rules
guideUnderstand FMCSA post-crash drug and alcohol testing requirements under 49 CFR Part 382, including which accidents trigger mandatory testing, testing timeframes, and consequences of non-compliance.