Trade guide · NAICS 484

Safety program requirements for logistics and trucking

What OSHA and FMCSA require of a logistics or trucking operation, in the order an auditor will ask for it. Written for the person who has to run the program.

15 min read Reviewed against current CFR text Sep 2026 By Chip Irek 6 obligation areas
OBLIGATION 01

What powered industrial truck and dock safety requirements apply?

What the rule requires

Logistics operations using forklifts, powered pallet jacks, or other industrial trucks at cross-docks, terminals, and distribution yards must train and evaluate every operator (1910.178). Trailers being loaded or unloaded must be secured against movement — wheel chocks, vehicle restraints, or equivalent means. Dock plates and boards must be secured in position and rated for the load being moved across them.

What a compliant program contains

A forklift training and evaluation program specific to the truck types and environments (yard, dock, cold storage) in the operation. Dock safety procedures covering trailer restraint, dock plate use, lighting requirements, and pedestrian-vehicle separation. Daily pre-shift inspection records for every powered industrial truck. Three-year operator evaluations with documented performance assessments.

Where companies slip

The most dangerous moment at a logistics dock is trailer departure during loading. A driver pulls away while a forklift is still inside the trailer — the forklift drives off the edge or the dock plate collapses. If your dock does not have vehicle restraints or a positive communication protocol (trailer pins, lock-out boards, key control) that prevents a driver from departing while loading is in progress, you have an uncontrolled fall-and-crush hazard at every dock door.

What your record has to show

Operator certification for each operator: name, date of training, evaluation date, trainer identity, and truck types covered. Daily truck inspection logs. Dock plate inspection records showing load ratings and maintenance history. Vehicle restraint or chocking verification records for each loading and unloading operation.

OBLIGATION 02

What hazard communication and hazmat handling is required?

What the rule requires

Logistics operations must implement a written Hazard Communication program covering all hazardous chemicals employees may be exposed to — including freight in transit (1910.1200). If the operation handles hazardous materials regulated under DOT (49 CFR), employees involved in those shipments also require HazMat training under FMCSA regulations (49 CFR 172.704). The OSHA HazCom standard and DOT HazMat requirements overlap but are separate obligations with separate training and documentation requirements.

What a compliant program contains

A written HazCom program addressing both operational chemicals (diesel, DEF, lubricants, cleaners) and in-transit hazardous freight. DOT HazMat training for employees who handle, load, or transport hazardous materials — with recertification every three years. SDS accessibility for all chemicals employees may encounter during normal operations and foreseeable emergencies. Spill response procedures for hazardous materials releases during loading, transit, or unloading.

Where companies slip

Confusing DOT HazMat training with OSHA HazCom training. They are different requirements enforced by different agencies. A driver with a CDL HazMat endorsement has met the licensing requirement, but that is not the same as the training record required by 49 CFR 172.704. FMCSA requires documented initial and recurrent training (every three years) covering recognition, handling, and emergency response — and the records must be kept for the duration of employment plus 90 days.

What your record has to show

Written Hazard Communication program, facility-specific and dated. HazMat training records (49 CFR 172.704) for each HazMat employee, retained for current employment plus 90 days. Chemical inventory and SDS system covering operational and in-transit chemicals. Spill response plan with training records for designated responders.

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OBLIGATION 03

What driver qualification and hours of service requirements apply?

What the rule requires

Motor carriers operating commercial motor vehicles must maintain a Driver Qualification (DQ) file for each driver (49 CFR 391). The DQ file includes the driver's application, motor vehicle record (MVR) pulled annually, current medical certificate, road test or equivalent, and annual review of driving record. Hours of service regulations limit driving time and require electronic logging devices (ELDs) for most CMV drivers (49 CFR 395). A drug and alcohol testing program is mandatory (49 CFR 382), along with FMCSA Clearinghouse queries.

What a compliant program contains

Complete DQ files with application, annual MVR, current medical certificate, road test certification, and annual driving record review. ELD compliance with properly registered devices, driver training, and six-month data retention. A drug and alcohol testing program covering pre-employment, random, post-accident, reasonable suspicion, return-to-duty, and follow-up testing. Pre-employment full queries and annual limited queries through the FMCSA Clearinghouse.

Where companies slip

The annual MVR pull and annual review of driving record are two separate requirements, and both are frequently missed. If a driver's MVR has not been pulled and reviewed in the last 12 months, the DQ file is deficient and the driver is technically unqualified. The same applies to expired medical certificates — a driver whose medical card has lapsed cannot legally operate a CMV, and operating them creates vicarious liability for the carrier.

What your record has to show

Complete DQ file for each driver with all required documents current. Annual MVR and driving record review dated within the last 12 months. ELD data retained for at least six months with supporting documents for edits and unassigned driving time. Drug and alcohol testing records and Clearinghouse query confirmations.

OBLIGATION 04

What vehicle inspection, repair, and maintenance is required?

What the rule requires

Motor carriers must systematically inspect, repair, and maintain all CMVs under their control (49 CFR 396). Drivers must complete a daily vehicle inspection report (DVIR) at the end of each driving day. Annual inspections must be performed by a qualified inspector meeting the criteria of Appendix G to 49 CFR 396. The carrier must maintain records of all inspections, repairs, and maintenance, and ensure no vehicle is operated in a condition likely to cause an accident or breakdown.

What a compliant program contains

A systematic maintenance program with scheduled service intervals for each vehicle. Daily Vehicle Inspection Reports completed by drivers, with documented carrier review and corrective action for defects. Annual inspections meeting 49 CFR 396 Appendix G criteria, with the report retained for 14 months and the inspection decal displayed. Repair and maintenance records retained for one year and for six months after the vehicle leaves the carrier's control.

Where companies slip

Drivers check "no defects" on the DVIR every day because reporting a defect means the truck goes out of service. Carriers tacitly tolerate this because it keeps trucks moving. A roadside inspection that finds defects contradicting a "no defects" DVIR creates evidence of both a vehicle maintenance violation and a falsified inspection report. The driver gets an out-of-service order. The carrier gets the maintenance violation on their safety record.

What your record has to show

DVIRs for each vehicle for each day of operation, retained for 90 days minimum. Carrier certification that defects reported on DVIRs were repaired or determined not to need repair. Annual inspection reports for each vehicle, retained for 14 months. Maintenance and repair records for each vehicle, retained for one year plus six months after disposal.

OBLIGATION 05

What emergency action and fire prevention planning is required?

What the rule requires

Logistics terminals, cross-docks, and yard facilities must maintain written emergency action and fire prevention plans (1910.38, 1910.39). The emergency action plan covers evacuation procedures, alarm systems, and employee responsibilities during emergencies. The fire prevention plan identifies fire hazards — fuel storage, battery charging, flammable freight — and the procedures to control them. Annual fire extinguisher training is required for employees expected to use them (1910.157).

What a compliant program contains

A written emergency action plan with evacuation routes, alarm descriptions, assembly points, and contact procedures for each facility. A written fire prevention plan identifying major fire hazards, storage procedures for flammables, and responsible personnel. Fire extinguisher inspection and training records. Spill containment procedures for fuel storage areas and hazardous materials handling zones.

Where companies slip

Multi-site logistics operations frequently have a corporate emergency plan that was never adapted to individual terminal layouts. An emergency action plan that doesn't match the building it's posted in — wrong exit locations, wrong assembly points, wrong alarm descriptions — is not a compliant plan. Each facility needs its own plan reflecting its actual layout, hazards, and alarm system.

What your record has to show

Site-specific emergency action and fire prevention plans for each terminal or facility. Fire extinguisher inspection tags showing monthly checks and annual professional service. Employee training records for emergency procedures and fire extinguisher use. Evacuation drill records with dates and participant counts.

OBLIGATION 06

What injury and illness recordkeeping is required?

What the rule requires

Trucking and logistics establishments with more than 10 employees must maintain OSHA 300, 300A, and 301 forms (29 CFR 1904). General freight trucking (NAICS 484) is on OSHA's high-hazard industry list, requiring electronic submission of 300A data for establishments with 20–249 employees. Trucking operations also have DOT accident reporting requirements (49 CFR 390.15) for crashes involving fatality, injury requiring transport, or vehicle tow-away — these are separate from OSHA recordkeeping.

What a compliant program contains

An OSHA 300 Log recording each recordable injury or illness within 7 calendar days. A DOT accident register for all DOT-reportable crashes, retained for three years. The OSHA 300A Summary posted February 1 through April 30, certified by a company executive. Five-year retention of OSHA forms and three-year retention of DOT accident records.

Where companies slip

Multi-establishment trucking companies often don't know which establishment to log an injury at. A driver injury is recorded on the 300 Log of the establishment the driver reports to — their home terminal — not the location where the injury occurred. If your drivers report to multiple terminals, you need to designate a home establishment for each driver for recordkeeping purposes.

What your record has to show

Current year 300 Log with all entries made within 7 calendar days, by establishment. DOT accident register with all reportable crashes recorded within 90 days. Five years of OSHA 300, 300A, and 301 forms and three years of DOT accident records. Electronic submission confirmation for 300A data if on OSHA's e-submission list.

Safety Sherpa is software, not a consultancy. Our tools walk you through the decisions the regulations require and record your reasoning. The determination is yours to make. We don't write your program for you, we don't certify a program, and no software should.

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