Prevention FAQ — FMCSR 387.31(f)

Inspectors verify that your carrier maintains the specific record or documentation requirement outlined in 387.31(f). During roadside inspections, they will request to see the required document or evidence of compliance. Across our 13 million inspection records, 387.31(f) has generated only 30 citations all-time—making it the #1799 most-cited code nationally—which suggests inspectors encounter it infrequently but flag it when the required item is missing or improperly maintained. The 0.0% out-of-service rate on this code indicates inspectors typically issue a citation without removing the vehicle from service, meaning you have time to cure the deficiency before the next inspection. Focus your audit on the specific document or log entry required by the regulation so drivers know exactly what to carry.

Add a line item to your standard pre-trip form that requires the driver to verify the presence and legibility of the required record or documentation before departing the yard. Make the item location-specific: for example, 'Confirm [document name] is present in vehicle and legible.' Have drivers initial and date this line every trip. Post a laminated reference card in the cab listing what must be carried and where it should be stored. Train new hires on this checklist item during orientation. Since 387.31(f) citations are rare (0 in the last 90 days across our database), this preventive measure costs little but closes a compliance gap that affects your safety record if cited.

Drivers must carry the specific record or document required by 387.31(f) in the vehicle during all operations. The fleet should retain copies of all issued documents and a log confirming each vehicle received and acknowledged the requirement. Establish a document control process: assign a responsible party to issue replacements if a driver reports loss or damage, and maintain a retrieval log. Drivers should photograph or scan the document for their own records. Fleet retention should include: (1) the original issued document, (2) driver acknowledgment signature, (3) date issued, and (4) any replacement records. This paper trail protects the carrier if a citation is later challenged and demonstrates your intent to comply.

Because this code carries an all-time citation count of 30, no statistically significant co-occurring violation pattern exists in our data to identify systemic root causes. However, the rarity of citations (0 in the last 90 days, 0 in the last 12 months) suggests that when violations occur, they are usually isolated omissions rather than fleet-wide procedural breakdowns. Focus your root-cause analysis on the driver or trip level: Was the document lost, forgotten, or never issued? Was it unclear that the document must remain in the vehicle? Interview the cited driver to understand whether the failure was training-related, process-related, or accidental loss. Use this single-incident approach to refine your checklist and documentation procedures rather than overhauling the entire compliance program.

After an 387.31(f) citation, verify compliance through a pre-return inspection: confirm the required document is present, legible, and correctly stored in the vehicle. Have a supervisor or compliance officer sign off on this verification before the vehicle is released for road operations. Document the date, time, and inspector name on a repair or correction log. If the document was lost, issue a replacement and have the driver sign acknowledgment that they received it and understand it must remain in the vehicle. For your fleet management system, flag the vehicle for a follow-up inspection within 5–10 days to confirm the document is still present and properly maintained. This verification step takes minutes but demonstrates remediation to auditors and prevents repeat citations.

Schedule a debrief meeting with the cited driver, the safety manager, and the driver's supervisor within 48 hours of the citation. Document the meeting notes. Ask: (1) Was the driver aware the document must be carried? (2) Did the driver have access to the document at the time of inspection? (3) Is the current checklist clear? (4) Are there barriers to compliance (e.g., unclear storage location, frequent loss)? Review the vehicle's inspection history to check whether similar items were previously flagged. Update your pre-trip checklist or training materials if the debrief reveals a gap. Send a fleet-wide email reminder about the requirement so other drivers reinforce their own compliance. Since 387.31(f) citations are extremely rare in our data, treat each one as a learning opportunity rather than evidence of systemic failure, but document it thoroughly to satisfy CSA audits.

An 387.31(f) citation carries a non-hazardous weight classification and is categorized as General/Admin. It does not place vehicles out of service (0.0% OOS rate across all instances in our data). This means a single citation will have minimal impact on your CSA Vehicle Maintenance BASIC compared to safety-critical violations like brake or tire defects. However, repeated violations—or clustering of administrative failures—can signal to auditors that your compliance management system is weak. The citation will appear on your CSA profile and may be noted during compliance reviews. The best strategy is to prevent the citation in the first place through the checklist and documentation controls outlined above. A single, promptly corrected citation is unlikely to trigger CSA intervention, but it should still prompt an internal review to prevent recurrence.

Include 387.31(f) compliance in your new-hire orientation and annual refresher training. Training topics should include: (1) what the specific required document is and why it matters, (2) where the document must be stored in the vehicle, (3) what to do if the document is lost or damaged during a trip (e.g., contact dispatch, get a replacement at the next terminal), and (4) what to expect during a roadside inspection. Use a brief video or demonstration to show drivers exactly where the document should be kept and how to verify it is legible before departure. Make the training interactive: have each driver sign a training roster or pass a quick knowledge check. Since the top vehicle makes cited include KW and Freightlin (2 citations each), consider whether cab layout or storage visibility differs between makes and adjust instructions accordingly. Reinforce the training message quarterly through safety bulletins or driver meetings.

File a DataQs challenge if: (1) the driver can provide photographic or documentary evidence that the required document was present and legible at the time of inspection, (2) the citation was issued in error (e.g., inspector did not request the document, or misidentified which document was required), or (3) the inspection report contains factual inaccuracies regarding what the driver presented. Gather supporting evidence before filing: driver statement, photographs of the document, communication logs, trip records, and any witness accounts. Submit the challenge through FMCSA's DataQs portal within 90 days of the citation. Because 387.31(f) citations are rare (only 30 all-time in our database), and your citation is likely factually sound if issued, a successful challenge is possible only if you have clear evidence of inspector error or misrepresentation. Consult your carrier's legal or compliance team to assess the strength of your evidence before filing.

Conduct a self-audit quarterly (every 90 days) as a routine preventive check. Your audit should sample 5–10% of active revenue vehicles and verify that the required document is present and legible. Since our data shows 0 citations in the last 90 days and 0 in the last 12 months, the citation risk is very low—but quarterly audits cost little and demonstrate due diligence to CSA auditors. If an audit reveals a missing or illegible document, issue a replacement immediately and document the correction. After an audit, share results with your safety team and drivers via a brief report: "Q1 Audit: 50 vehicles checked, 49 compliant, 1 corrected." This communication reinforces the importance of the requirement and shows drivers that compliance matters. Use the low frequency of violations in our national database as evidence that your prevention program is working—and maintain the audit cadence to keep it that way.