The annual DOT inspection: what it covers and who may do it

Which vehicles need one

Every commercial motor vehicle subject to the motor carrier's control (396.17(a) and (b)). The definition of a commercial motor vehicle is in 49 CFR 390.5: 10,001 pounds or more gross weight rating or actual weight, passenger vehicles above the 8- and 15-passenger thresholds, or vehicles carrying placarded hazardous materials, operated in interstate commerce.

The rule counts each vehicle in a combination separately. For a tractor pulling a semitrailer and a full trailer, the tractor, the semitrailer and the full trailer (including the converter dolly) must each be inspected (396.17(a)). A fleet with 10 tractors and 25 trailers has 35 annual inspections to track, not 10.

Part 396 does not apply to covered farm vehicles or pipeline welding trucks (49 CFR 396.1).

The 12-month rule

A carrier must not use a commercial motor vehicle unless each component in the minimum standard has passed an inspection at least once during the preceding 12 months, and documentation of that inspection is on the vehicle (396.17(c)). An expired inspection is a violation even if nothing is wrong with the vehicle. Failing to perform the annual inspection properly exposes the carrier to the penalty provisions of 49 U.S.C. 521(b) (396.17(h)).

What the inspection covers

The minimum standard is Appendix A to Part 396, Minimum Periodic Inspection Standards. Older forms and guidance call it Appendix G; it was redesignated in FMCSA's 2021 technical amendments (86 FR 57060). A vehicle does not pass if it has any of the defects the appendix lists under these headings:

The examples are a summary. Inspect against the appendix text itself, which gives the measurements, such as the brake readjustment limits by chamber type.

Who may do the inspection

The carrier may inspect its own vehicles (396.17(d)), or have a commercial garage, fleet leasing company, truck stop or similar business do it as its agent, provided that business has facilities suited to commercial vehicle inspections and employs qualified inspectors (396.17(e)). Either way, the inspector must meet 49 CFR 396.19:

• understands the inspection criteria in Part 393 and Appendix A and can identify defective components;
• knows and has mastered the methods, procedures, tools and equipment of an inspection;
• is capable by experience, training or both: a Federal- or State-sponsored training program or a State or Canadian Province certificate, or at least one year of combined training or experience, such as a manufacturer-sponsored or similar commercial training program, or work as a mechanic or inspector in a carrier maintenance program, a commercial garage or fleet leasing company, or a government inspection role.

The carrier must keep evidence of each inspector's qualifications for as long as that person performs its annual inspections and for one year after (396.19(b)).

State inspection programs

A vehicle that passes a State periodic inspection (or one in a Canadian Province, the Yukon Territory or Mexico) meeting the Appendix A minimum counts as its annual inspection for 12 months, starting from the last day of the month in which it was performed (396.17(f)). If a vehicle is subject to a mandatory state program that FMCSA has found as effective as 396.17, the carrier must meet the requirement through that program (49 CFR 396.23). Carriers do not have to keep inspector qualification records for inspections done under a State periodic inspection program (396.19(b)).

The report and the decal

The inspector prepares a report that, under 49 CFR 396.21(a), identifies:

1. the individual who performed the inspection;
2. the motor carrier operating the vehicle;
3. the date of the inspection;
4. the vehicle inspected;
5. the components inspected and the results, including any not meeting Appendix A;
6. a certification that the inspection is accurate and complete.

The documentation carried on the vehicle can be the report itself or a sticker or decal based on it that shows the inspection date, the name and address of the entity where the report is kept, information uniquely identifying the vehicle if it is not clearly marked, and a certification that the vehicle passed an inspection under 396.17 (396.17(c)).

How long to keep the report

The original or a copy is kept for fourteen months from the date of the inspection report, where the vehicle is housed or maintained, and must be available on demand to an authorized Federal, State or local official (396.21(b)). If someone else performed the vehicle's last annual inspection, for example a lessor, the carrier operating it is responsible for obtaining the report when an official asks. See fleet maintenance records for how this fits with the rest of the file.

Annual inspection tracker

Schedule the next inspection a month before it is due, so a failed item can be repaired without parking the unit. In Cargovate, an inspection can be set as a maintenance task due on time, and each asset shows what is due, overdue or not yet due.

Related: DVIR requirements · preventive maintenance schedules · roadside inspections.