FMCSA Accident Register Requirements: Why You Need One Even With Zero Accidents

The accident register is one of the easiest FMCSA requirements to comply with -- and one of the most commonly missed. Even if you have never had an accident, you are still required to maintain a written register. The auditor will ask for it. If you cannot produce it, that is a finding regardless of your accident history.

What counts as a DOT-recordable accident

Under 49 CFR 390.5, an accident involving a commercial motor vehicle in operation on a public road is DOT-recordable if it results in any of the following:

• A fatality
• Bodily injury to a person who, as a result, immediately receives medical treatment away from the scene
• One or more vehicles incurring disabling damage and being transported away from the scene by tow or other vehicle

Minor fender-benders that do not meet any of the three thresholds are generally not DOT-recordable. But it is the carrier's responsibility to evaluate each event against the regulation and document the determination.

Required register fields

Under 49 CFR 390.15(b), the register must include the following for each accident:

1. Date of the accident

   Calendar date the accident occurred.

2. City or town and state

   Location where the accident occurred.

3. Driver name

   The driver of the commercial motor vehicle involved.

4. Number of injuries

   Persons injured requiring immediate medical treatment away from scene.

5. Number of fatalities

   Persons killed in the accident.

6. Whether hazardous materials were released

   Yes/no, with details if yes.

Most carriers attach copies of the police accident report and any insurance documentation to the register entry. This is not required but is best practice for both audit defense and insurance recordkeeping.

Carriers with zero accidents

If you have had no DOT-recordable accidents, you still maintain a written register stating that. A simple cover page that reads 'Accident Register -- ClearToHaul Trucking Inc. -- USDOT 1234567 -- Period covered: [start date] to present -- No DOT-recordable accidents during this period' satisfies the requirement. Update the period covered on an ongoing basis.

Retention

The accident register must cover the three most recent years. Records should be retained for one year after the period covered, so practically you keep four years of register data on file. Supporting documents like police reports should be retained for at least three years after the accident.

Common audit findings

• No accident register at all (most common)
• Register exists but missing required fields
• Accidents missing from the register that show up in FMCSA crash data
• No supporting documentation for listed accidents
• Register not signed or dated by a company official

Post-accident drug and alcohol testing

Any DOT-recordable accident may trigger post-accident drug and alcohol testing requirements under 49 CFR 382.303. Drug testing is required within 32 hours and alcohol testing within 8 hours when specific conditions are met. The post-accident testing documentation should be cross-referenced with the accident register entry.

How to set up your accident register today

1. Create a simple register document

   Spreadsheet or Word document with the six required fields as columns.

2. Add a zero-accident cover page

   State the period covered and that no recordable accidents have occurred.

3. Add an entry workflow

   When an accident happens, fill out the register within 24 hours and attach police report.

4. Cross-check FMCSA crash data quarterly

   Compare register entries to your DOT crash report to catch missing entries.

How ClearToHaul handles the accident register

The New Carrier Startup Package includes an accident register template pre-completed for zero-accident status so the audit binder has it from day one. The Done-For-You Compliance Package adds an entry workflow and cross-check with FMCSA crash data.