Heavy Duty Trucking Logo
MenuMENU
SearchSEARCH

How to Set up a Maintenance Program that Will Keep FMCSA Happy

Whether you have one truck or 20,000, the FMCSA's maintenance regulations apply to you. The safety and compliance experts at J.J. Keller have tips for owner-operators and small fleets on how to develop a maintenance program that will meet federal standards.

by Thomas Bray, Editor, J.J. Keller & Associates
February 12, 2013
How to Set up a Maintenance Program that Will Keep FMCSA Happy

 

4 min to read


Many people are puzzled by what the Federal Motor Carrier Safety Administration is talking about in the maintenance regulations. In §396.3 it simply states that a carrier must have a program to “systematically inspect, repair, and maintain, or cause to be systematically inspected, repaired, and maintained, all motor vehicles and intermodal equipment subject to its control.”

This applies to all carriers, whether you have one truck or 20,000.

Ad Loading...

As far as actually establishing the specifics of the maintenance program, that is up to the carrier.

The only other guidance the FMCSA provides is that parts and accessories (the ones required in the regulations) “shall be in safe and proper operating condition at all times.” The specifics about what “safe and proper” means are scattered throughout the regulations, but they are mostly found in Part 393 and Appendix G.

The effectiveness of a carrier’s maintenance program is “officially judged” during roadside inspections. This judging is especially important if you have just gotten your DOT number. All “new-entrant carriers” (carriers that have just gotten a DOT number) are subjected to a “new-entrant safety audit” after 6 to 18 months of operation. One component of this audit is calculating the new carrier’s out-of-service rate (what percentage of the time the carrier’s vehicles “fail” a roadside inspection). If it is too high, it will lower the carrier’s chances of getting lifted off new-entrant status.

Where do you start?

The first step is determining how often you should do maintenance inspections and preventive maintenance on your vehicle(s).

To get started, you can contact the original equipment manufacturer that built the vehicle. Most OEMs have inspection and preventive maintenance (PM) “schedules” available for the vehicles they build. These include recommended intervals (based on miles, hours run, and/or dates) and checklists (items that should be checked).

Ad Loading...

You should also establish “cut-off points” for major components that wear out. This is the point at which a part or component will be repaired or replaced. The starting point for these decisions needs to be the limits established in Part 393 of the FMCSA regulations, as well as Appendix G. If the regulations do not establish a cut-off point for a part or component, the OEM can usually provide this information.

Tires, brake adjusters, brake linings, fuel filters, and clutches are examples of parts and components that can have cut-off points assigned to them. The idea is to repair or remove the part or component before it creates a problem on the road. This may sound complicated, but it is much better than breaking down (or worse, causing a crash).

Next, set up the records

One key to compliance in this area is maintenance records. If you are audited, these records will be an important part of the audit as they show that you are “taking care” of your vehicle(s).

Carriers — here again, no matter how big or small — must have an “informational record” for each vehicle that includes:

  • Fleet number (if one is assigned)

  • Make, model, and year

  • VIN

  • Tire size

  • Owner (if not the carrier)

  • A maintenance schedule for the unit (a means to indicate when maintenance was last done and is to be done again)

Ad Loading...

The regulations also require that records of all inspection, maintenance, lubrication, repairs, and upcoming maintenance be kept for one year while the unit is in service, and for six months after the unit leaves service. So far all of this is covered in §396.3. The records can take any form the carrier wants; there are no “required forms” for documenting normal maintenance and repairs. A handwritten note describing what was done or a receipt from a truck shop would qualify as “maintenance records.”

The one exception is periodic (annual) inspections reports. They must contain specific information and be kept for 14 months, rather than 12.

You will want to set up and maintain maintenance records not just because they are required by the regulations, but because they can help you decide if your maintenance program is working. The records can also help you determine where you are having vehicle problems and how much it is really costing you to operate a specific piece of equipment.

Thomas Bray is an editor in the Transportation Publishing Department of the Editorial Resource Unit at J. J. Keller & Associates, Inc., specializing in motor carrier safety and operations management. Contact Tom at transporteditors@jjkeller.com.

Subscribe to Our Newsletter

More Drivers

SponsoredFebruary 1, 2026

Stop Watching Footage, Start Driving Results

6 intelligent dashcam tactics to improve safety and boost ROI

Read More →
DriversJanuary 23, 2026

What FMCSA’s New Enforcement Push Means for Fleets in 2026 [Podcast]

Listen as transportation attorney and TruckSafe Consulting President Brandon Wiseman joins the HDT Talks Trucking podcast to unpack the “regulatory turbulence” of last year and what it means for trucking fleets in 2026.

Read More →
DriversJanuary 20, 2026

How Pilot Is Using AI in Truck Maintenance

A practical look at how artificial intelligence is helping Pilot's trucking fleet move from reactive maintenance to a more proactive approach.

Read More →
Ad Loading...
SponsoredJanuary 19, 2026

3 New Ways Fleet Software Pays: ROI opportunities for modern fleet managers

Safety, uptime, and insurance costs directly impact profitability. This eBook looks at how fleet software is evolving to deliver real ROI through proactive maintenance, AI-powered video telematics, and real-time driver coaching. Learn how fleets are reducing crashes, defending claims, and using integrated data to make smarter operational decisions.

Read More →
SponsoredJanuary 19, 2026

Basic Tracking vs Next Generation Fleet Technology

Fleet software is getting more sophisticated and effective than ever, tying big data models together to transform maintenance, safety, and the value of your existing tech stack. Fleet technology upgrades are undoubtedly an investment, but updated technology can offer a much higher return. Read how upgrading your fleet technology can increase the return on your investment.

Read More →
Graphic showing smart truck parking technology with a highway sign reading “Spaces Available” and the Streetline logo.
Driversby News/Media ReleaseJanuary 16, 2026

Streetline Expands Smart Truck Parking System on West Coast

Streetline is expanding smart truck parking tools, including a new I-5 deployment in Washington and a no-upfront-cost pilot model for state DOTs.

Read More →
Ad Loading...
Truck parked at night
Driversby Deborah LockridgeJanuary 15, 2026

Third 'Jason's Law' Truck Parking Survey Under Way

The Federal Highway Administration is asking motor carriers and truck drivers to give input on where and when drivers have difficulty finding truck parking, and on how drivers prefer to get information on available parking.

Read More →
Driversby StaffJanuary 8, 2026

FMCSA Continues Focus on State Issuance of Non-Domiciled CDLs

The Federal Motor Carrier Safety Administration continues a crackdown on an increasing number of states it says have been issuing non-domiciled CDLs improperly.

Read More →
Driversby Deborah LockridgeDecember 30, 2025

Will FMCSA’s Driver-Oriented Enforcement Initiatives Affect Capacity?

The Department of Transportation and the Federal Motor Carrier Safety Administration took several actions in 2025 to tighten enforcement of regulations for commercial drivers. Will those affect trucking capacity in 2026?

Read More →
Ad Loading...
Driversby Deborah LockridgeDecember 15, 2025

Q&A: Lisa Kelly Explains Ice Road Trucking, Reality TV Editing, and Life as a Female Driver

Lisa Kelly talks to HDT about the return of the show Ice Road Truckers, what really happens on the ice roads, how reality TV shapes drivers’ stories, and the career she’s built beyond the show.

Read More →