DOT Compliance¶
Last Updated: February 2026 Target Audience: Drivers, Operations Manager, Fleet Manager, Management
This guide covers Department of Transportation (DOT) and Federal Motor Carrier Safety Administration (FMCSA) regulations that apply to Scott Recycling's driver fleet. Our 5 box truck drivers operate across 10 states, making DOT compliance essential for legal operation and employee safety.
Overview¶
Scott Recycling operates a fleet of box trucks for e-waste collection pickups. Depending on vehicle weight ratings and cargo type, various DOT/FMCSA regulations apply. This guide covers the key compliance areas: CDL requirements, Hours of Service, vehicle inspections, driver qualifications, drug testing, and more.
CDL Requirements¶
When a CDL Is Required¶
A Commercial Driver's License (CDL) is required based on the vehicle's Gross Vehicle Weight Rating (GVWR) or Gross Combination Weight Rating (GCWR):
| Vehicle Class | GVWR | CDL Required? | CDL Class |
|---|---|---|---|
| Light-duty truck | Under 10,001 lbs | No | Standard driver's license |
| Medium-duty truck | 10,001 - 26,000 lbs | No (but DOT regulations may still apply) | Standard license (DOT medical card may be required) |
| Heavy-duty truck | Over 26,001 lbs | Yes | Class B (single vehicle) or Class A (with trailer over 10,000 lbs) |
| Any vehicle carrying hazmat requiring placards | Any weight | Yes | Requires Hazmat endorsement (H) |
Scott Recycling's Fleet¶
- Our box trucks are typically in the medium-duty range (10,001 - 26,000 lbs GVWR)
- If any truck exceeds 26,001 lbs GVWR, the driver must hold a CDL
- If a truck tows a trailer that brings the combined weight over 26,001 lbs, a CDL is required
- Check the GVWR on the driver's side door jamb sticker of each vehicle
DOT Medical Card
Even if a CDL is not required, drivers operating commercial motor vehicles (CMVs) over 10,001 lbs GVWR in interstate commerce must hold a valid DOT medical examiner's certificate (medical card). The medical card must be renewed every 2 years (or more frequently if the examiner specifies).
CDL Endorsements¶
| Endorsement | Code | When Needed |
|---|---|---|
| Air Brakes | None (restriction removal) | Vehicles with air brake systems |
| Hazardous Materials | H | Transporting hazmat requiring placards |
| Combination | T | Tractor-trailer combinations |
Hours of Service (HOS)¶
Hours of Service regulations limit how long a driver can operate a commercial motor vehicle to prevent fatigue-related accidents.
HOS Applicability¶
HOS rules apply to drivers of CMVs that are:
- Over 10,001 lbs GVWR, OR
- Used in interstate commerce (crossing state lines), OR
- Transporting hazardous materials requiring placards
Interstate Commerce
Scott Recycling operates across 10 states. Any driver who crosses state lines or is part of a shipment that crosses state lines is engaged in interstate commerce and must comply with federal HOS rules, even if the vehicle is under 26,001 lbs.
HOS Rules (Property-Carrying Vehicles)¶
| Rule | Limit | Details |
|---|---|---|
| 14-Hour Window | 14 consecutive hours | After coming on duty, a driver has a 14-hour window to complete driving; this window cannot be extended by off-duty time |
| 11-Hour Driving Limit | 11 hours maximum | A driver may drive a maximum of 11 hours within the 14-hour window |
| 30-Minute Break | Required after 8 hours of driving | Must take a 30-minute break (off-duty or sleeper berth) before driving if 8 consecutive hours have passed since the last break |
| 10-Hour Off-Duty | 10 consecutive hours | Must have 10 consecutive hours off-duty before the next on-duty period |
| 60/70-Hour Limit | 60 hours in 7 days or 70 hours in 8 days | Total on-duty time limit over a rolling period; can be reset with a 34-hour restart |
Short-Haul Exemption¶
Drivers who meet ALL of the following criteria may qualify for the short-haul exemption (no Electronic Logging Device required):
- Operate within a 150 air-mile radius of their normal work reporting location
- Return to the work reporting location at the end of each day
- Do not drive after the 14th hour after coming on duty
- Company maintains time records showing the driver's start time, end time, and total hours
Short-Haul Applicability
Most of Scott Recycling's daily route operations likely qualify for the short-haul exemption, since drivers typically return to the facility each day. However, longer-distance pickups (e.g., Arizona, Arkansas) may exceed the 150 air-mile radius and require full HOS compliance with an ELD.
Record Keeping¶
- Short-haul drivers: Time records (start time, end time, total hours) maintained by the company
- Non-exempt drivers: Must use an Electronic Logging Device (ELD) or maintain paper logs
- Retain HOS records for a minimum of 6 months
Vehicle Inspections¶
Pre-Trip Inspection¶
Every driver must perform a pre-trip inspection before operating the vehicle each day. This is both an FMCSA requirement and a critical safety practice.
Pre-Trip Inspection Checklist:
| System | Check |
|---|---|
| Tires | Proper inflation, tread depth, no damage or bulges, lug nuts tight |
| Lights | Headlights, taillights, brake lights, turn signals, clearance lights, hazard flashers -- all functional |
| Mirrors | Both side mirrors clean, properly adjusted, not cracked |
| Brakes | Brake pedal firm (not spongy), parking brake holds, no unusual sounds |
| Steering | No excessive play, power steering fluid adequate |
| Horn | Functional |
| Windshield / wipers | No major cracks, wipers functional, washer fluid filled |
| Fluid levels | Engine oil, coolant, power steering, transmission, washer fluid |
| Exhaust | No excessive smoke, no leaks |
| Cargo area | Roll-up door functional, load secured, no loose items |
| Safety equipment | Fire extinguisher charged, reflective triangles present, first aid kit |
| Seatbelt | Functional |
| Backup camera / alarm | Functional (if equipped) |
Post-Trip Inspection¶
At the end of each day, the driver must inspect the vehicle and note any defects or issues:
- Walk around the vehicle and check for new damage
- Note any mechanical issues that developed during the day
- Check fluid levels and tire condition
- Complete the Driver Vehicle Inspection Report (DVIR)
DVIR (Driver Vehicle Inspection Report)¶
- A written DVIR must be completed at the end of each driving day
- The report must note any defects or deficiencies discovered during operation or inspection
- If defects are noted, the vehicle must not be operated until defects affecting safe operation are repaired
- The motor carrier (Scott Recycling) must review and sign the DVIR, certifying repairs have been made or are not needed
- Retain DVIRs for a minimum of 3 months
Do Not Operate an Unsafe Vehicle
If a pre-trip inspection reveals a defect that could affect safe operation (bad brakes, tire damage, steering issues, non-functional lights), do not drive the vehicle. Report the defect immediately and use an alternate vehicle or wait for repair.
Vehicle Maintenance Records¶
FMCSA requires motor carriers to maintain systematic vehicle maintenance records.
Required Records¶
| Record | Content | Retention |
|---|---|---|
| Vehicle identification | Unit number, make, model, year, VIN, license plate, GVWR | Duration of ownership + 1 year |
| Maintenance schedule | Scheduled service intervals (oil changes, brake inspections, tire rotation) | Duration of ownership + 1 year |
| Maintenance and repair records | Date, description of work, who performed it, mileage | Duration of ownership + 1 year |
| Annual inspection | Annual vehicle inspection by a qualified inspector (DOT annual inspection) | 14 months (must have a current inspection at all times) |
| DVIRs | Daily post-trip inspection reports | 3 months |
Annual DOT Inspection¶
- Every CMV must pass an annual inspection by a qualified inspector
- The inspection covers all major vehicle systems (brakes, steering, suspension, tires, lights, etc.)
- A passing inspection results in a sticker/decal placed on the vehicle
- Inspection records must be retained for 14 months
- Schedule annual inspections through the fleet maintenance vendor or a certified inspection station
Fleet Management in Odoo
Vehicle maintenance records, service schedules, and mileage tracking are managed through the Fleet Management module in Odoo. Keep this system updated with every service event.
Driver Qualification Files (DQ Files)¶
FMCSA requires motor carriers to maintain a Driver Qualification (DQ) file for every driver who operates a CMV.
Required DQ File Contents¶
| Document | Requirement | Renewal |
|---|---|---|
| Employment application | Completed application with 3-year employment history | At hire |
| Motor Vehicle Record (MVR) | Driving record from each state where the driver held a license in the past 3 years | Annual review |
| Road test certificate (or equivalent) | Documentation that the driver can safely operate the assigned vehicle | At hire |
| DOT medical examiner's certificate | Valid medical card from a National Registry examiner | Every 2 years (or as specified) |
| Driver's license copy | Copy of current, valid driver's license | Annual verification |
| Annual review of driving record | Employer's review and certification of the driver's MVR | Annual |
| Previous employer safety performance history | Request from prior DOT-regulated employers (past 3 years) | At hire (within 30 days) |
| Certificate of violations | Driver's annual certification of traffic violations in the past 12 months | Annual |
DQ File Maintenance¶
- The Operations Manager (or designated file keeper) is responsible for maintaining DQ files
- Files must be reviewed at least annually to verify all documents are current
- Expired medical cards or licenses mean the driver cannot legally operate until renewed
- Retain DQ files for 3 years after the driver leaves the company
Expired Documents
A driver with an expired DOT medical card or expired driver's license may not operate a CMV. Monitor expiration dates proactively and ensure renewals are completed before documents expire.
Drug and Alcohol Testing Program¶
FMCSA requires drug and alcohol testing for drivers of CMVs over 26,001 lbs GVWR or those requiring a CDL. Even for drivers below the CDL threshold, Scott Recycling may implement a drug and alcohol testing program as a best practice and for insurance purposes.
Testing Types¶
| Test Type | When | Details |
|---|---|---|
| Pre-employment | Before the driver's first trip | Drug test required; alcohol test optional but recommended |
| Random | Throughout the year | DOT random testing rates: 50% of drivers for drugs, 10% for alcohol (rates set annually by FMCSA) |
| Post-accident | After a DOT-recordable accident | Required if the accident resulted in a fatality, a citation with bodily injury, or a citation with a towed vehicle |
| Reasonable suspicion | When a supervisor observes signs of impairment | Supervisor must be trained in recognizing signs of drug/alcohol use |
| Return-to-duty | Before returning to safety-sensitive duties after a violation | Required after a positive test or refusal |
| Follow-up | After return-to-duty | Minimum 6 tests in the first 12 months |
Testing Program Requirements¶
- Designate a Designated Employer Representative (DER) to manage the testing program
- Use a SAMHSA-certified laboratory for drug testing
- Use a DOT-qualified Breath Alcohol Technician (BAT) for alcohol testing
- Maintain a drug and alcohol testing policy that is distributed to all covered drivers
- Retain testing records per DOT requirements (5 years for positive results, 1 year for negative results)
Substances Tested¶
DOT drug testing tests for:
- Marijuana (THC)
- Cocaine
- Amphetamines (including methamphetamine, MDMA)
- Opioids (including codeine, morphine, heroin, hydrocodone, hydromorphone, oxycodone, oxymorphone)
- Phencyclidine (PCP)
Marijuana
Marijuana remains a Schedule I controlled substance under federal law. Even in states where marijuana is legal for recreational or medical use, a positive DOT drug test for marijuana is a violation. There is no exception for state marijuana laws under DOT testing regulations.
Accident Reporting¶
What Constitutes a DOT-Recordable Accident¶
A DOT-recordable accident is any occurrence involving a CMV on a public road that results in:
- A fatality (any person)
- Bodily injury requiring immediate medical treatment away from the scene
- Disabling damage to any vehicle requiring towing
Accident Reporting Procedure¶
- Ensure safety first -- check for injuries, move to a safe location if possible
- Call 911 if there are injuries, significant vehicle damage, or hazardous material release
- Do not admit fault -- cooperate with law enforcement but do not make statements about fault
- Exchange information with the other parties (name, insurance, license, vehicle info)
- Document the scene -- take photos of all vehicles, the scene, road conditions, and any damage
- Contact the Operations Manager as soon as possible
- Complete an accident report -- document all details while they are fresh
- Post-accident drug/alcohol testing -- may be required (see testing section above); do not consume alcohol for 8 hours after the accident or until tested
Accident Record Retention¶
- Maintain accident records for 3 years from the date of the accident
- Records must include: date, location, driver name, injuries, fatalities, hazmat release, and all related documentation
Weight Limits and Load Securement¶
Weight Limits¶
| Limit Type | Maximum | Notes |
|---|---|---|
| Federal gross weight limit | 80,000 lbs (truck + cargo) | Applies to interstate highways |
| Single axle | 20,000 lbs | Per axle |
| Tandem axle | 34,000 lbs | Per tandem set |
| Bridge formula | Varies | Limits weight based on axle spacing |
| State limits | Varies by state | Some states have lower limits on certain roads |
Know Your Truck's Capacity
Check the GVWR on the driver's door jamb sticker. Never load the truck beyond its rated capacity. If you are unsure whether a load is too heavy, weigh the truck at a certified scale before proceeding.
Load Securement¶
Cargo must be secured to prevent shifting during transit:
- Heavy items (servers, CRT monitors, balers) must be placed on the floor, against the front wall of the cargo area
- Stack carefully -- heavier items on the bottom, lighter items on top
- Use straps, bars, or nets to secure loads that could shift
- Fill gaps between items to prevent lateral movement
- Close and secure the roll-up door before moving the vehicle
- Re-check the load after the first stop and periodically during the route
Hazardous Materials Transportation¶
When E-Waste Becomes Hazmat¶
Most e-waste collected by Scott Recycling is not classified as hazardous material for transportation purposes. However, certain items may trigger DOT hazmat regulations:
| Material | Hazmat? | Condition |
|---|---|---|
| Intact computers, laptops, printers | No | Standard cargo |
| CRT monitors (intact) | No | Not regulated for transport when intact and handled as Universal Waste |
| Lithium batteries (installed in devices) | Generally exempt | Exempt when contained in equipment; follow packaging guidance |
| Lithium batteries (loose, removed from devices) | May be regulated | Loose lithium batteries in bulk may require hazmat packaging and labeling |
| Lead-acid batteries | Yes | DOT Class 8 (Corrosive); requires proper packaging and labeling |
| Broken CRTs with exposed lead glass | May be regulated | Depends on quantity and state regulations |
| Mercury-containing components (loose) | Yes | DOT Class 6.1 (Toxic); requires proper packaging |
| Toner (loose/spilled) | Generally not regulated | Check SDS for specific product |
When in Doubt, Ask
If you are unsure whether a material requires hazmat handling for transportation, do not load it onto the truck. Contact the Operations Manager for guidance. Improper transportation of hazardous materials carries severe penalties.
Hazmat Training¶
If any Scott Recycling driver transports hazardous materials:
- General awareness training -- understanding of hazmat regulations (required every 3 years)
- Function-specific training -- specific to the hazmat functions performed
- Safety training -- emergency response information
- Security awareness training -- awareness of security risks associated with hazmat transportation
Hazmat Documentation¶
When transporting regulated hazardous materials:
- Shipping papers must accompany the shipment (proper shipping name, hazard class, UN number, quantity)
- Emergency response information must be immediately accessible
- Placards may be required on the vehicle depending on the type and quantity of hazmat
Record Retention Summary¶
| Record Type | Retention Period |
|---|---|
| Driver Qualification files | 3 years after driver leaves company |
| MVR (Motor Vehicle Records) | 3 years |
| Drug/alcohol test results (positive) | 5 years |
| Drug/alcohol test results (negative) | 1 year |
| DVIRs (Daily Vehicle Inspection Reports) | 3 months |
| HOS records (logs/time records) | 6 months |
| Vehicle maintenance records | Duration of ownership + 1 year |
| Annual DOT inspection records | 14 months |
| Accident reports | 3 years |
Questions? Contact your supervisor or refer to the Getting Started guide.