Prevention FAQ — FMCSR 387.31(a)

Our inspection records show 22 all-time citations for this code, making it rank #1898 of 3,036 FMCSR codes—one of the least frequently cited violations. When inspectors do flag this code, they are examining whether carriers and drivers meet a specific administrative or documentation requirement tied to vehicle operation or maintenance records. The fact that 0 citations have been issued in the last 90 days suggests this violation is either rare or that fleets have largely corrected the underlying issues. Focus your audit on the carriers in our database who have been cited—Classic Elegance Coaches LLC and Drivergent Inc each had 2 citations—to identify what triggered enforcement in those operations.

Build your pre-trip checklist to include verification of all required documentation being present in or on the vehicle before departure. Ensure drivers confirm that all necessary records, certificates, or operational logs mandated under this regulation are complete, legible, and accessible to inspectors without delay. Train drivers to keep these documents organized in a consistent location—typically the cab or a designated pouch—so they can produce them quickly during a roadside inspection. Include a box on your daily pre-trip form where the driver initials that documentation is present and correct. This simple checkpoint prevents the most common cause of citations: drivers discovering during inspection that required paperwork was left behind or incomplete. Weekly spotchecks of 10–15% of vehicles will reinforce compliance and catch gaps before an inspector does.

Drivers must carry all documents required under 387.31(a) in the vehicle at all times during operation. The fleet should maintain copies—both digital and paper—of the same documentation at the company office for at least the period specified by FMCSR retention rules, typically one year or longer depending on the specific record type. Establish a tracking system (spreadsheet or fleet management software) that logs when each document was issued to a driver, the vehicle to which it applies, and when it was returned or updated. Photograph or scan driver acknowledgments showing they received the required documentation before the first trip. This dual-custody approach—driver carries original, fleet retains copy—protects both parties during inspection and provides clear evidence of compliance for CSA audits.

With only 22 all-time citations and 0 in the last 90 days, this code occurs so infrequently in our 13 million+ inspection database that no dominant co-occurrence pattern emerges. However, administrative and documentation violations typically cluster with operational oversights—drivers rushing pre-trip, insufficient training on what documents are required, or vehicles cycling through rapid ownership changes where documentation chains break. The peers in the General/Admin category (like USDOT number display violations, which have 74,663 citations) show that compliance gaps often trace to inadequate onboarding and lack of standardized checklists. If your fleet receives a citation for 387.31(a), treat it as a red flag that your documentation systems need tightening, even if the citation count is low.

For a documentation-based violation like 387.31(a), "repair" means restoring compliance with the documentation requirement. After a citation, have a supervisor review the exact deficiency noted by the inspector—whether it was a missing form, expired record, or inaccessible file. Verify that the driver has obtained the correct, current document and that it is physically present in the vehicle. Conduct a secondary inspection of the vehicle yourself before it returns to service, specifically checking that the document is in the location specified in your pre-trip checklist. Obtain a written acknowledgment from the driver (dated and signed) confirming they now have the required documentation and understand the consequence of losing it again. Document this verification step in your maintenance management system with a note linking it to the citation—this evidence strengthens your CSA defense if challenged.

Within 48 hours of receiving a citation for 387.31(a), pull together the driver, the compliance officer, and the operations supervisor. Review the inspector's report to understand exactly what was missing or incorrect. Cross-check your fleet's current pre-trip checklist and documentation procedures—did your existing process fail to catch it, or did the driver bypass it? Audit all vehicles in that driver's regular rotation to confirm they have the required documentation. Finally, review whether other drivers at the same carrier location might have the same gap. Document your findings and corrective actions in a brief incident report, noting the date, vehicle(s) affected, corrective measure taken, and responsible party. Use this report as a training case study in your next safety meeting to reinforce the requirement across the entire fleet.

FMCSR 387.31(a) is categorized as a General/Admin violation and is not eligible for out-of-service status—the inspection records show 0 out-of-service placements across all 22 citations. While this low severity means it has minimal immediate impact on a roadside OOS decision, it still appears on the carrier's inspection history and contributes to the CSA scoring domain. Because this code ranks #1898 of 3,036 FMCSR codes by volume, a single citation is unlikely to materially move the needle on your Vehicle Maintenance BASIC unless you accumulate multiple violations. However, clusters of administrative violations—including this one—signal poor compliance culture. Fleet managers should treat even low-volume code citations as canaries: they indicate systems gaps that, if ignored, can lead to higher-severity defects.

Incorporate mandatory training on documentation requirements into onboarding and annual refresher sessions. Cover the specific forms or records required under 387.31(a), where they must be stored in the vehicle, and how to organize them for quick inspector access. Include a hands-on component: walk new drivers through a mock roadside inspection scenario and have them produce the required documents from the vehicle in under one minute. Emphasize accountability: make clear that if a document is missing, the driver is responsible for obtaining a replacement before the next trip, not relying on the fleet to intervene. Use your citation data to reinforce the message—share that 22 citations have been issued nationally for this violation, but zero in the last 90 days—and explain that this low rate reflects carriers who have strong documentation culture. Tie compensation or safety bonuses to perfect documentation audits to increase driver engagement.

DataQs challenges are appropriate if the inspector's cite was factually incorrect—for example, if the driver did have the required document but the inspector overlooked it, or if the cited regulation does not actually apply to your vehicle or operation. Review the citation details carefully: inspect photos, inspector notes, and your own vehicle log for that date. If your records show the document was present and properly stored, and the inspection report does not clearly explain why it was deemed non-compliant, a DataQs challenge is justified. Document your evidence (photos of the document in the vehicle, driver logs, pre-trip attestations) and submit within the regulatory window. However, if the document was genuinely missing or incomplete, accept the citation, correct the issue, and focus on prevention rather than disputing the fact.

Conduct self-audits monthly for all vehicles, focusing on a rotating sample of 25–33% of your fleet each month to audit the full population within a quarter. This cadence is justified by the inspection data: 0 citations in the last 90 days and 0 in the last 12 months indicate that either the violation is rare or carriers with strong audit programs catch and fix the issue before inspectors arrive. A monthly self-audit gives you visibility into any drift in driver compliance and documentation practices before a roadside inspection happens. Use a standardized form that mirrors your pre-trip checklist, with a yes/no confirmation for each required document. Spot-check a few vehicles each week at random to supplement the monthly audit. Track trends in your audit data—if you see a rising rate of missing or incomplete documentation, escalate training and coaching before a citation occurs.