Understanding the Driver Vehicle Inspection Report (DVIR) process

Although commercial drivers have been performing and documenting pre- and post-trip inspections for decades, the Driver Vehicle Inspection Report (DVIR) process continues to be a pain-point for many motor carriers and their drivers that can lead to a number of regulatory violations. In this article, we'll tackle the DVIR process to get a better understanding of what exactly it entails.

What is a DVIR?

Luckily, this is a pretty easy one…a DVIR is simply a written report prepared by commercial drivers that documents their vehicle inspections and any defects discovered during those inspections. These have historically been prepared as paper reports; however, more recently, many carriers and drivers have transitioned to an electronic DVIR process, often through the driver’s electronic logging device. The primary purpose of the DVIR requirement is for drivers to alert their motor carriers to any defects that are likely to impact the safety of the operation of the CMV so that the defect can be fixed prior to the CMV being operated again by that same driver or a different one.

When are DVIRs required?

Historically, the Section 396.11 of the federal safety regulations required commercial drivers to complete DVIRs to their carriers at the end of every day they operated, regardless of whether they discovered any defects with their vehicles throughout the day. This was a paperwork nightmare, so the requirement changed for property carriers in 2014 and for passenger carriers in 2020, such that drivers are now only technically required to prepare and submit DVIRs to their carriers at the end of any day when they have discovered or been made aware of a defect during a vehicle inspection that would affect the safety of the CMV’s operation. So, in other words, if during the course of a routine inspection, whether performed by the driver him/herself or by law enforcement during a roadside inspection, the driver becomes aware of a vehicle defect that is likely to affect the safety of its operation, he/she should prepare a DVIR and submit it to the carrier that day. This is true even if the defect was corrected on the spot, for example, if the driver him/herself replaced a headlight. Now, we’ll discuss below the procedures for preparing and submitting DVIRs, but the takeaway here is that commercial drivers need only complete and submit to their carrier a DVIR on days where they become aware of a vehicle defect. If they do not discover any defects on a particular day, then no DVIR is required.

With that said, some carriers choose to continue requiring their drivers to prepare and submit DVIRs every single day as a way to ensure drivers remain in the habit of doing so. This is less of a burden for carriers that rely on electronic DVIRs. Is it a good practice to do this? In our opinion, it really just comes down to whether your drivers are taking it seriously or not. Having drivers voluntarily complete DVIRs every day can, in some sense, "get them in the habit" of doing their pre- and/or post-trip inspections each day. But it also runs the risk of them "pencil-whipping" these reports and downplaying situations that really warrant a DVIR. So, if you're going to require drivers to submit DVIRs every day, you need to be self-auditing the process to make sure drivers are, indeed, catching the situations that truly warrant a DVIR.

The DVIR process

Whether you’re a property- or passenger-carrying driver, the regulations establish a specific process that drivers and carriers must follow when it comes to preparing and submitting DVIRs. The first step, obviously, is that the driver prepares the DVIR, identifying the CMV that was inspected, including any attached trailers, and listing any defects discovered or reported to the driver. Again, this would include situations where a driver became aware of a defect from a third-party such as an officer during a roadside inspection. Note also that if a driver operates more than one CMV during a day, he/she would need to prepare a separate DVIR after finishing operating each CMV, if a DVIR is required.

Once the driver prepares the DVIR, he/she must sign it and submit it to the operating motor carrier. Again, this has historically been done on paper, but can also be accomplished electronically. Some of the electronic systems are even set up so that the DVIRs are automatically transmitted to the carrier’s maintenance department, which can help facilitate a quicker turnaround on vehicle repairs. For its part, once a carrier receives a DVIR from a driver that lists a defect likely to affect the safety of the CMV’s operation, it must not allow the CMV to operate again until the defect is corrected. Once it is corrected, then the carrier or its agent (for example, a mechanic) must sign off on the DVIR to certify that the repairs have been made. And carriers should retain copies of the DVIRs and the repair records in the vehicle’s maintenance file. Once the repair is made and certified, then its important that drivers review the prior day’s DVIR, if any, before operating for the day to ensure any such defects have been corrected. Carriers have an obligation under the regulations to retain DVIRs for a period of 3 months from the date they were generated.

Here's a visualization of the DVIR process:

Conclusion

So we'll wrap this article up by emphasizing the important of understanding and utilizing the DVIR process. We've personally helped motor carriers through a number of DOT audits over the years and can say that DVIRs are often a fairly substantial part of those audits. FMCSA investigators will be looking at instances where a vehicle defect has been noted, typically by referencing recent roadside inspections with maintenance-related violations, and will expect to see a DVIR in the vehicle file for that day. If the DVIR is missing, this will be written up as a violation and can lead to civil penalties and other enforcement. So it’s important that carriers and drivers are conducting their routine inspections and submitting DVIRs when required.

If you're in need of a sample DVIR for use by your drivers, we have them available in our library of compliance documents at this link. Also, if you're interested in more in-depth discussions of the federal safety regulations, be sure to check out our innovative compliance training courses through Trucksafe Academy.

About Trucksafe Consulting, LLC: Trucksafe Consulting is a full-service DOT regulatory compliance consulting and training service. We help carriers develop, implement, and improve their safety programs, through personalized services, industry-leading training, and a library of educational content. Trucksafe also hosts a monthly live show on its various social media channels called Trucksafe LIVE! to discuss hot-button issues impacting highway transportation. Trucksafe is owned and operated by Brandon Wiseman and Jerad Childress, transportation attorneys who have assisted some of the nation’s leading fleets to develop and maintain cutting-edge safety programs. You can learn more about Trucksafe online at www.trucksafe.com and by following Trucksafe on LinkedIn, Facebook, Twitter, and YouTube.