In 2018, FMCSA told the trucking world it was planning to strike from the truck safety rulebook the old driver “Record of Violations” requirement (in Sec. 391.27 of the FMCSRs). This is the rule requiring carriers to have each driver submit an annual list of their convictions for traffic violations. This requirement may have been a decent idea in 1970 when it was first included in the rule book, but that was before State licensing agencies could track and record interstate CMV driver violations and convictions no matter where they occurred. For as long as we at STC can remember (decades…), carriers have also been required to make an annual inquiry to obtain the MVR for each driver it employs. The driver-completed record of violations is:
- duplicative of the longstanding annual MVR check rule;
- prone to error due to human recall/memory challenges; and,
- an annual compliance-related paper chase for carrier personnel.
This rule has far outlived its usefulness. Technology has made it moot. Its elimination will reduce a small but annoying burden on fleets with little or no redeeming safety value 50 years after it was first required.