Truck maintenance records in Canada: building the vehicle file an NSC auditor asks for

Who sets the record rules for a Canadian carrier

Trucking safety in Canada is mostly provincial. Transport Canada explains that provincial and territorial regulations govern the commercial truck and bus industry, that Ottawa’s authority covers only extra-provincial carriers, and that exemptions under section 16 of the Motor Vehicle Transport Act let the provinces and territories regulate those carriers on its behalf. The common ground is the National Safety Code (NSC): 16 standards that every province and territory either adopts by reference or mirrors in its own law, published by the Canadian Council of Motor Transport Administrators (CCMTA).

Three of those standards decide what goes in your vehicle files:

• Standard 11, Part A, the commercial vehicle maintenance standard: the records every carrier keeps for each unit.
• Standard 13, trip inspections: the driver’s daily report and what the carrier does with it.
• Standard 15, facility audits: how the province checks all of it at your place of business.

Standard 11 is blunt about enforcement. Unlike the other inspection standards, the maintenance standard is not enforced on the road; transportation safety officials check it during the facility audit. The auditor randomly selects vehicles, asks for their files, and checks that each one is current, complete and covers the standard. A missing program or files that are not kept current are recorded as a violation on the carrier’s jurisdictional profile, and that profile feeds the safety rating. In Ontario, for example, the CVOR page says an audit examines vehicle inspection, maintenance and repair records, and that the results may affect the operator’s CVOR record.

What NSC Standard 11 puts in each vehicle file

Section 1(b) of the Part A general requirements lists five records every carrier keeps for each commercial vehicle:

1. Identification: licence plate number, unit or company number if marked, make, serial number, year and tire size, plus the name of the leasing company when the carrier does not own the unit.
2. A way to show what is due: the nature and due date of each inspection and maintenance operation. Your PM schedule is this record.
3. The work itself: every inspection, repair and maintenance job with its date and nature. The standard adds two reminders: retain all invoices, and mark measurements on your inspection forms.
4. A lubrication record.
5. Modifications: any change to axles or suspension that affects the maker’s gross vehicle weight rating or gross axle weight rating.

The procedures for compliance add the make, model, year and VIN, the parts replaced on each job, and the odometer reading at every servicing or repair. They also expect the file to be assembled and kept current for each vehicle at the principal place of business. A footnote warns that many jurisdictions want proof of maintenance, such as brake repair invoices, kept for four or five years, and that some want a written safety plan that includes a maintenance plan.

Brake measurements are worth the paperwork

Part B, the periodic inspection standard, requires brake measurements to be recorded on the inspection report: lining thickness and drum diameter on drum brakes, rotor and pad thickness on disc brakes. A unit whose last full brake inspection is properly documented can qualify for a limited inspection at the next periodic inspection instead of having its wheels pulled. The proof must show the date, the odometer reading (optional for trailers), the VIN, the technician’s name or number with a signature, and the name of the shop, in written or electronic form; a brake job done in between must be backed by purchase invoices or work orders.

Manufacturer defect notices

Standard 15 tells each jurisdiction to require, for every commercial vehicle, the maintenance and inspection records of Standards 11, 12 and 13 together with any Notices of Defect received from the manufacturer and proof that the defect was corrected. File each notice with the unit it covers, along with the work order that closed it.

Trip inspection reports under Standard 13

Trucks, tractors and trailers are inspected against Schedule 1 every 24 hours when operated, and the inspector prepares a report in written or equivalent electronic form. It must carry the plate or unit number, the carrier’s name, the date and time, the city, town or highway location, a signed statement that the vehicle was inspected, the inspector’s printed name and the odometer reading if the vehicle has one. When nothing is found, the report says so.

Two deadlines matter for the office. Drivers forward the original report to the carrier within 20 calendar days, and the carrier keeps the original report and the certification of repairs for at least six months from the date it was prepared. Between those dates the carrier must make sure every reported defect is corrected before the next required inspection, or within the time the jurisdiction allows. Our trip inspection guide walks through the full process.

Ontario writes the same idea into Ontario Regulation 199/07: a daily inspection is valid for 24 hours, the driver submits the completed report no later than 20 days after it stops being valid, and the operator keeps it at least six months. Defects found while driving go on the same report and to the operator quickly.

Provincial requirements: Ontario, British Columbia, Alberta and Quebec

Ontario

Section 16 of Ontario Regulation 199/07 lists the records an operator keeps for each commercial motor vehicle, trailer and converter dolly. Identification covers the unit number, year, make and VIN; for a unit someone else supplies, add that supplier’s name and the first and last dates you operated it. The service record names the work, the person who did each inspection or repair, the invoice from any outside shop, the invoice or receipt for any part, and the odometer reading at the end of the job. The file also holds the types and frequency of your scheduled inspections and maintenance, axle or suspension modifications, copies of safety standards certificates and annual or semi-annual inspection certificates (and their equivalents from other jurisdictions), and the roadside notices and inspection reports drivers hand in.

The operator keeps these records for at least two years or, for a unit it stops operating, six months after that, whichever period is shorter. They sit at the principal place of business or another terminal or business address of the operator.

British Columbia

CVSE’s Record Keeping At-a-Glance sheet for National Safety Code carriers gives these periods for vehicle records: maintenance and all repair records and receipts, three years; copies of current and past CVIPs, three years; manufacturer recall notices, current plus four years once corrected; trip inspection reports, collected within 20 days and kept three months; and the maintenance, repair and inspection reports of a unit you sell or dispose of, six months after disposal or handed to the new owner. The sheet is guidance only, and the Motor Vehicle Act and Regulations apply if they conflict.

Alberta

Alberta Transportation’s sample safety and maintenance program for provincial carriers (December 2016) shows the vehicle file it expects. Each unit has its unit number or serial number, make and year of manufacture; a record of its inspections under the Vehicle Inspection Regulation and of its repairs, lubrication and maintenance, each with the nature of the work, the date and the odometer or hubometer reading; notices of defect from the maker and the corrective work; and its trip inspection reports. Trip reports are kept for the month they are made plus six months, the other records for the year they are made plus four more, and everything for six months after a unit is retired or disposed of, at the principal place of business unless the Registrar authorizes another place.

Quebec

The SAAQ asks owners and operators of heavy vehicles (a gross vehicle weight rating of 4,500 kg or more, plus buses, minibuses and tow trucks) to keep a record for each vehicle at the place of business. The vehicle record holds the registration certificate copy, any lease, proof that manufacturer recalls were carried out, circle check reports (six months), the documents on mandatory maintenance (the previous two years, then 12 months after disposal), and proof that defects found were repaired (12 months from the repair date). The maintenance record holds the identification (VIN, plate, make, year, owner and long-term lessor), the schedule of upcoming inspections, the work done at each servicing and the maintenance sheets.

Mandatory mechanical maintenance is due at least every six months. Each maintenance sheet shows the VIN, the plate or unit number, the odometer, the date, each component checked as compliant or non-compliant, the repairs needed and the signature of the person who did the work. On vehicles rated 7,258 kg or more, brake measurements are taken every six months and entered in the SAAQ’s brake and tire measurement record (Registre de mesures de freins et de pneus); tire measurements on it are optional.

How long to keep each record, side by side

Keep each paper for the longest period that applies to the units in front of you: the province that plates them, and any province whose rules you also run under. Before you shred anything, read the current regulation; the SAAQ says the same about Quebec law.

Periodic inspection reports and decals

After a passed periodic inspection, Standard 11 has the inspector give the operator a report and fix a decal to the unit. The report should be carried in the vehicle (check with your jurisdiction), copies of every report, pass or fail, are kept at the carrier’s principal place of business and at the inspection facility, and another copy goes to the jurisdiction within 15 business days. The standard adds that proof of these inspections may have to be kept for up to four years, and that every repair invoice should be kept because auditors verify them and because the alternative brake inspection depends on them.

In Ontario the annual or semi-annual inspection is done at a DriveON Vehicle Inspection Centre, and the province says the digital inspection report can be found online through DriveON. Download it into the unit’s file anyway: the regulation still expects you to keep copies of the certificates. For intervals and decal rules in each province, see our CVIP and periodic inspection guide.

Keeping the file electronically

Paper is not required. Standard 13 accepts trip inspection reports and schedules in written or equivalent electronic form, and Standard 11 accepts the proof of a prior brake inspection in written or electronic form. The rules in each province decide the details:

• Ontario: section 18 of Regulation 199/07 lets any required record be made, kept or surrendered electronically if it meets every other requirement, though it need not carry a signature. An electronic record may be kept anywhere if it can be readily accessed from the principal place of business, and the operator must print a copy when an officer asks and has the means to do so. A driver with an electronic report must send it to an officer on request, or show it on a screen readable from outside the vehicle, or hand over a printed copy signed by the driver.
• Alberta: the sample program lets records be kept electronically or on paper, as long as they can be readily produced to a peace officer.
• Quebec: the SAAQ’s heavy vehicle record page does not address format, so ask the SAAQ before you retire the paper binder.

Whatever the format, Standard 15 expects the records to be preserved so they can be inspected and audited, made available during normal business hours, and never altered, defaced or falsified. A scan attached to the right unit number is easy to produce; a photo on a phone is not.

Selling, scrapping or returning a unit

The file does not end when the truck leaves the yard. Standard 11 keeps it for six months after the vehicle leaves the carrier’s control, and its compliance notes say the records of a vehicle that is sold, destroyed or returned to the lessor may be discarded after six months. Ontario uses six months after you stop operating the unit, BC’s guide six months after disposal or handing the records to the new owner, Alberta’s sample program six months after the unit is retired, and Quebec 12 months after disposal.

When a unit goes, write its disposal date on the file, export its service history, and note the date its file may be destroyed under each rule that applies. If you hand copies to a buyer, as BC allows, keep your own until the period runs out. For leased units, Ontario wants the first and last dates you operated each one and Quebec the lease contract until 12 months after the lease ends.

Getting ready for an NSC facility audit

Standard 15 leaves it to the auditor whether an audit is booked or unannounced, so assume you will get short notice. Every unit you control is in scope, including owner-operator and leased units. The records must be at your main place of business in the province where your vehicles are base-plated, or at another location the audit agency accepts; if they are not there when the auditor arrives, the matter can go to the agency that issues your operating authority, and to a hearing.

Appendix B of the standard sets the minimum number of vehicles an auditor samples. Jurisdictions have some flexibility, but the minimums are:

For each sampled unit the standard looks for trip inspection reports with evidence, such as dated work orders from your shop or an outside one, that the safety defects on them were repaired; periodic inspection reports showing the unit was inspected at the required interval and its defects fixed; and evidence of a reminder system that tells whoever runs maintenance when each inspection and PM service is due. It adds that each vehicle should have its own file.

Run your own audit first. Pick units at random, as the auditor will, and work through each file:

1. Does the identification match the unit, its plate and its registration?
2. Does the schedule show what is due next, and was the last service done when it said?
3. Does every job carry a date, an odometer reading, who did it and the invoice for outside work and parts?
4. Is every defect on the last six months of trip reports closed by a dated repair?
5. Is the periodic inspection current, with its report filed and its brake measurements recorded?
6. Are manufacturer defect notices filed with proof of the fix?

Fix what you find before the auditor does. Driver files, hours of service and training records sit beside the vehicle files in the same audit; TruckerPro’s fleet document management keeps those carrier documents in the TMS that RigMD runs on.