Most carriers that lose their operating authority don't do so because of a catastrophic event. They lose it incrementally — a pattern of preventable violations that accumulates in the FMCSA's safety measurement system until the agency has no choice but to act.

The compliance mistakes below are common, well-documented, and entirely avoidable. If any of them sound familiar, the time to fix them is now — before an audit, a roadside inspection, or a formal compliance review puts them on the record.

Mistake #1: Expired Medical Certificates

A CDL driver must have a current medical certificate (DOT physical) on file. The certificate is typically valid for 24 months, but drivers with certain conditions may receive shorter certifications — 12 months, 6 months, or even less.

The problem: Safety managers often track these in a spreadsheet or calendar. One missed reminder, one driver who doesn't mention their renewal is coming up, and suddenly you have a disqualified driver who has been operating commercially for months.

The fix: Automated expiration tracking with alerts at 30 and 7 days before expiry. Every carrier should know, at any moment, which drivers have certificates expiring in the next 60 days.

Mistake #2: Pulling MVRs Only at Hire

Federal regulations require you to review a driver's Motor Vehicle Record (MVR) within 30 days of hire. But they also require an annual MVR review for every driver, every year after that.

Many small carriers perform the initial MVR pull during onboarding and never do it again. A driver who accumulates violations after joining your company — speeding tickets, license suspensions — may be operating in your fleet without your knowledge.

The fix: Schedule annual MVR reviews for every driver. Set a recurring calendar alert and treat it as a hard deadline, not a suggestion.

Mistake #3: Incomplete Driver Files

A complete driver qualification file requires more than just a CDL and a medical certificate. For each driver, you must have on file:

  • Application for employment
  • Verification of previous employment (3 years)
  • List of prior traffic violations (signed by driver)
  • Road test certificate or equivalent
  • Pre-employment drug test result
  • Current CDL copy
  • Current medical certificate
  • Annual MVR review records

Auditors pull files at random. If yours are missing documents, it's a citable violation per driver file — which adds up fast.

Mistake #4: Skipping or Losing DVIRs

Drivers are required to complete a Driver Vehicle Inspection Report (DVIR) at the end of each day if they're operating vehicles over 10,001 lbs. The DVIR must be signed by the driver, reviewed by a qualified mechanic if defects are noted, and retained for at least 3 months.

Many carriers have drivers do verbal "no defects" reports over the phone, or collect paper DVIRs that get lost or thrown out. Both practices are non-compliant.

The fix: Collect DVIRs digitally through your driver app and store them centrally. Paper DVIRs should be filed and retained in a system you can produce during an audit.

Mistake #5: Inadequate Drug Testing Records

FMCSA requires carriers to maintain a drug and alcohol testing program and conduct testing at the required rates. For 2025, that's 50% of your average driver count for drug testing and 10% for alcohol testing annually.

Common errors include:

  • Not selecting drivers for random testing at the required rate
  • Failing to conduct post-accident testing when required
  • Not documenting refusals to test
  • Missing records of return-to-duty tests for drivers who tested positive

A single documented failure to conduct required post-accident drug testing — regardless of the accident outcome — is a serious violation that can affect your safety rating.

Mistake #6: Ignoring HOS Violations

Hours of Service violations are among the most common safety violation categories in FMCSA's data. With ELDs now mandatory for most carriers, violations are automatically logged and visible during roadside inspections.

Common HOS mistakes include pushing drivers to deliver before their clock runs out, misconfiguring ELD exemptions, and allowing drivers to edit logs without proper documentation. Each violation is a data point that raises your SMS score — and your audit risk.

Mistake #7: Not Updating Files After Violations or Accidents

When a driver receives a traffic citation, has an accident, or has a license suspension, the event must be documented in their driver file. Many carriers only find out about these events at the annual MVR review — by which point the driver may have been operating with a suspended license for months.

Require drivers to self-report any traffic citations or license events within 30 days. Have them sign an acknowledgment that this obligation exists as part of their onboarding paperwork.

The Common Thread

Every one of these mistakes has the same root cause: compliance treated as a periodic task rather than an ongoing system. Safety departments that chase documents and manually track expiration dates will always be behind. Safety departments with automated tracking, structured file requirements, and clear notification systems rarely have serious audit outcomes.

The difference between a compliant carrier and a vulnerable one usually isn't intention — it's process.