Monthly DOT Focus | September 2026
Good Morning,
August was about the violations that look too small to matter. September's theme is a close cousin: the difference between what looks compliant and what actually is.
A medical certificate sitting in a driver qualification file. A light that technically works but can't be seen through the dirt. An inspector who's "qualified" because a form says so. A pretrip inspection drivers assume covers everything riding in the trailer.
Each one can pass a glance and still leave you exposed.
Here are a few topics worth paying attention to this month.
🔋 HazMat Geek: Your Pretrip Checklist Doesn't Mention HazMat Paperwork. Comply Anyway.
392.7, 392.8, and 396.13 govern pretrip inspections, and 392.7 and 396.13 specifically require a driver to be "satisfied" the vehicle is safe before and after a trip. Neither one spells out what that means for a HazMat load specifically.
But 177.800 still requires carriers to follow the Hazardous Materials Regulations, and 177.804 still requires drivers to follow the safety regs — pre and post trip inspections included.
Nothing in the rule stitches those two requirements together into a HazMat-specific checklist. That gap doesn't remove the obligation. It just means carriers have to build the connection themselves.
Takeaway
If you're hauling HazMat, the BOL, the ERG, the placards, and the markings should get the same eyes as the brakes and the lights during pre and post trip inspections. It's not a separate inspection. It's one more thing to confirm while you're already out there.
🛞 OOS Corner: A Light That Works Isn't the Same as a Light That's Visible
An inoperative light is an obvious violation. A light buried under road dirt, mud, or snow is a less obvious one — but it's still a violation, and it can still put a vehicle out of service.
If the obscured light is a rear stop lamp, tail lamp, or turn signal, it's treated the same as if it never worked at all.
✅ Mud or road grime covering a lens counts
✅ Snow and ice buildup during winter counts
✅ Reflective tape that's too dirty or faded to be seen counts
Takeaway
Required lights are already a pre/post trip item. During bad weather, they need more than a glance at the start of a shift — they need to stay clean and visible throughout the day.
🧯 Driver Focus: A Medical Certificate in the File Isn't Always Enough
This one catches more carriers than you'd expect.
Part 391.51 lists what has to be in a driver qualification file, and a medical certificate is one of them — but for CDL holders, 391.51(b)(6)(ii) adds a second requirement: if the CDLIS motor vehicle record contains medical certification status information, the carrier has to obtain that CDLIS record from the driver's current licensing state and place it in the file.
In other words, for an interstate CDL driver, the medical certificate alone doesn't satisfy the file requirement. You need the driving record behind it.
Action Item
After your CDL driver's medical exam is renewed, pull the CDLIS MVR from the licensing state and file it in place of — not in addition to — the paper certificate.
💡 Vehicle Talk: What the 2026 CVSA Roadcheck Numbers Actually Show
CVSA announces its 72-hour Roadcheck inspection blitz every year, well ahead of time, through every trade outlet that covers this industry. Everyone knows it's coming.
And yet the national OOS rate during this year's event still landed at 22.26%. The top five vehicle violation categories:
✅ Brake Systems — 2,816 OOS violations, 23.6% OOS rate
✅ Tires — 2,269 OOS violations, 22.3% OOS rate
✅ 20% or Defective Brakes — 1,846 OOS violations, 15.4% OOS rate
✅ Lights — 1,514 OOS violations, 12.7% OOS rate
✅ Cargo Securement — 1,438 OOS violations, 12% OOS rate
Combine the two brake categories and you get a 39% OOS rate for brake-related issues alone. Four out of every ten commercial vehicles inspected that week had a brake problem serious enough to be placed out of service.
Takeaway
Advance notice didn't move the needle much. Consistent pre/post trip inspections are what actually would.
📱 National Focus: Is Your Annual Inspector Actually Qualified — or Just Paperwork Qualified?
Appendix A to Part 396 sets the minimum standards for a periodic (annual) inspection, and it's worth a second look if you use in-house mechanics to perform them.
Two examples worth checking directly with your inspectors:
Lighting: Appendix A item #5 requires all lighting devices and reflectors required by Part 393 to be operable — including retro-reflective sheeting. Do your inspectors know the full required list, or just the obvious ones?
Windshields: the damage allowance has specific exceptions — cracks under 1/4 inch not intersected by another crack, damaged areas under 3/4 inch that aren't within 3 inches of another damaged area, and factory-applied tinting or coloring (see 393.60 for the full exceptions). Miss the exception and a passable windshield gets failed, or a bad one gets passed.
Action Item
Completing the "Inspector Qualification" paperwork proves someone is on file. It doesn't prove they know the standard. Pull a sample of recent inspection reports and, where you can, watch an inspection get done.
🚦 Final Thought: Compliant on Paper Isn't the Same as Compliant
Every topic this month has the same shape.
A medical certificate in the file looks right, until you check whether the CDLIS record is there too.
A light that lights up looks fine, until it's buried under enough road dirt that nobody behind you can see it.
An inspector who completed the qualification paperwork looks qualified, until you check what they actually catch on an inspection.
A Roadcheck everyone sees coming still catches 4 in 10 trucks on brakes alone.
None of these are hidden problems. They're the ones sitting in plain sight, technically checked off, that turn out not to hold up when someone looks closer.
The fleets that do best under scrutiny aren't the ones with the cleanest-looking files. They're the ones who periodically check whether "looks compliant" and "is compliant" are actually the same thing.
Need Help?
If you'd like to review your fleet's CSA trends, discuss compliance exposures, or understand how safety performance impacts your insurance program, I'd be happy to help.
Stay Safe and God Bless,
Zach Kuder, TRS
Roark & Sutton, LLC
📞 417-830-0466
📱 417-397-4670
✉️ Zach@roarkandsutton.com
