COMPLIANCE
One-Touch DVIR was built to the FMCSA eDVIR Final Rule effective March 23, 2026, and to the underlying authority that makes an electronic signature lawful in the first place — 49 CFR § 390.32. This page publishes the full citation chain, our attestation text, and how each rule is implemented in the product. If your auditor wants a one-link answer to "is this legitimate," send them here.
THE FOUR CITATIONS, NAMED TOGETHER, EVERY TIME
Most "FMCSA compliant" claims in this category cite only one or two of the rules below — usually just § 396.11. That leaves the question of whether the electronic signature is lawful at all answered by silence. We cite all four together, because that's what the regulatory record actually requires:
- 49 CFR § 390.32 — Electronic Documents and Signatures. The rule that makes a PIN-as-signature lawful on any FMCSA-required document. Without § 390.32, no DVIR app on the market would be legitimate. This is the foundation of the chain.
- 49 CFR § 396.11 — Driver vehicle inspection report (DVIR) content requirements. Specifies what must appear on every DVIR: driver name, vehicle identification, defects (or "no defects"), driver signature, mechanic certification when repairs are made.
- 49 CFR § 396.13 — Driver inspection. Requires the driver to review the prior DVIR before operating the vehicle, and to sign acknowledging that any reported defects have been certified as repaired or are not safety-critical.
- FMCSA eDVIR Final Rule, effective March 23, 2026. The Federal Motor Carrier Safety Administration's rulemaking that authorizes electronic DVIRs and cross-references § 390.32 for signature lawfulness. This is the rule whose effective date drove our March 2026 deployment cycle.
Washington State operators: WAC 392-145 (school bus operations) and WAC 446-65 (commercial vehicle inspection) apply additionally. Both are consistent with the federal chain above.
WHAT THE RULE SAYS, AND WHERE YOU CAN SEE IT WORKING
This is the part most marketing pages skip. Here's how each citation maps to a specific behavior in the app.
§ 390.32 — Electronic signatures
What the rule requires: an electronic signature on an FMCSA document must be (a) uniquely identifiable to the signer, (b) under the sole control of the signer, (c) attached to or logically associated with the record, and (d) accompanied by a record of consent.
How One-Touch DVIR implements it:
- Every driver is issued a 4-digit PIN by their Transportation Supervisor. PINs are unique per driver, are not chosen by the driver, and are stored in a supervisor-managed sheet.
- Submission of a DVIR requires the PIN. The PIN is the signature.
- Every submission is timestamped server-side (not by the driver's phone clock), logged in a write-only compliance ledger, and stamped with the driver's name resolved from the PIN.
- The first time a driver signs into the app — and every time the legal attestation text changes — the driver is shown the attestation and must accept it before they can submit. Acceptance is recorded in a separate consent log with the agreement version, timestamp, bus, district, and a UUID.
§ 396.11 — DVIR content requirements
What the rule requires: the DVIR must identify the vehicle, list defects affecting safety or "no defects," include the driver's name, and be signed.
How One-Touch DVIR implements it:
- Every inspection log row contains: server timestamp, driver name (resolved from PIN), PIN itself, bus identifier, district, inspection type (pre-trip or post-trip), result ("No New Defects Found" or "Defect"), defect list (when applicable), notes, GPS coordinates with accuracy, attestation duration, and user-agent string.
- Defect submissions enumerate the specific defects checked. "No New Defects Found" submissions explicitly record the no-defects outcome.
- The driver's name appears on every row. The PIN is the signature attached to the row.
§ 396.13 — Driver review of last DVIR
What the rule requires: the next driver must review the prior DVIR before operating the vehicle and must sign acknowledging that any reported defects are repaired or are not safety-critical.
How One-Touch DVIR implements it:
- The driver-facing screen for any bus with an open defect shows the open items inline — what was reported, when, by whom, and the mechanic's status. The driver cannot pretend they didn't see it.
- Any bus marked Out-of-Service triggers a full-screen lockout: "Do not operate." The driver cannot dismiss this screen to start a pre-trip.
- The attestation the driver signs at submission includes review of prior open items. The text is versioned and re-signed when it changes.
March 23, 2026 FMCSA eDVIR Final Rule
What the rule does: authorizes electronic DVIRs across the FMCSA-regulated fleet universe, cross-referencing § 390.32 for signature lawfulness and § 396.11/396.13 for content and review.
How One-Touch DVIR was prepared for it: the product was architected to the Final Rule before the effective date. We deployed to our first production garage in May 2026 on infrastructure that already met the rule. Districts coming on board now are inheriting a system that was built to the new rule, not retrofitted to it.
THE EXACT WORDS ON THE DRIVER'S SCREEN
This is the text every driver accepts at first sign-in and re-accepts whenever it changes. Current version: v1.1, updated May 2026. Prior versions are retained in the consent log; no driver's history is rewritten when the text changes.
By entering your PIN, you are giving your affirmative consent to create, sign, and retain all Pre-Trip, Post-Trip, No New Defects Found, and Defect reports in electronic form only.
Your PIN is your legal electronic signature. It uniquely identifies you as the driver of record. You agree to keep your PIN confidential; any report submitted with your PIN is your act and is legally binding.
Important ESIGN Disclosures (required before you consent):
- You have the right to receive a paper copy of any record at any time at no charge. Paper copies are available from your supervisor.
- You may withdraw your consent to electronic records at any time by notifying your supervisor in writing. Withdrawal will not affect the validity of any records already created. However, after withdrawal, future inspections must be completed on paper until a new agreement is signed. There is no fee for withdrawal. There are no other conditions or consequences other than the need to use paper forms going forward.
- You can update your electronic contact information (email or phone) at any time in the app or by notifying your supervisor.
- To use this application you need only a modern web browser on a smartphone, tablet, or computer with reliable internet. You can print or save any record as a PDF at any time.
- This consent applies to all Pre-Trip, Post-Trip, No New Defects Found, and Defect reports you submit through this application for the entire time your driver profile is active on this device.
By entering your PIN and tapping "I Agree & Sign" you certify that:
- You have personally performed a complete physical pretrip or posttrip walk-around inspection of the vehicle as required by WAC 392-145-041.
- You have reported (or will report) any defects or deficiencies discovered.
- When you select "No New Defects Found," you are making an explicit, legally binding certification that no defects or deficiencies were discovered during this inspection.
This electronic signature and record are made pursuant to the federal ESIGN Act (15 U.S.C. § 7001), FMCSA regulations (49 CFR §§ 390.32, 396.11, and 396.13 as updated by the March 2026 final rule), the Washington Uniform Electronic Transactions Act (RCW Chapter 1.80), and applicable pupil-transportation law (WAC 392-145-041 and RCW 46.61.380).
All records are retained by the school district or carrier in accordance with applicable records-retention requirements, independent of your profile status. This agreement remains in effect for all sessions on this device until your driver profile is modified, at which point you will be asked to re-confirm.
How we handle changes to this text: every driver in the system is required to re-accept any new version before their next submission. We don't quietly update legal text under your drivers' feet. When v1.2 lands, every driver sees v1.2 on their next sign-in and acknowledges it. The change history lives in the consent log forever.
IF YOUR DISTRICT IS AUDITED, HERE'S EXACTLY WHAT WE HAND YOU
Each district's data lives in a Google Sheet owned by the district. The supervisor has full read access to every tab. Here's what's in there:
- Inspection_Logs — write-only ledger of every inspection ever submitted. One row per submission. Fourteen columns covering identity, timestamp, location, content, and submission environment. This is the primary compliance record.
- Bus_Status — current state of every bus's open defects. Auditors typically want this to confirm defect lifecycle hygiene.
- Driver_PINs — the identity register. Supervisor-managed, two columns. Auditors typically want to see PIN assignment dates.
- Consent_Log — every legal attestation acceptance event, with agreement version, timestamp, and UUID. This is what proves a driver consented to the version of the attestation in effect at the time of their inspection.
- Submission_IDs — UUID ledger that prevents duplicate submissions. Auditors typically don't ask, but it's there to demonstrate dedup integrity.
- DEBUG_LOGS — operational diagnostic log. Not a compliance record, but useful when reconstructing a specific submission.
In addition, on the 1st of every month an automated dossier is emailed to the Transportation Supervisor with that district's prior-month inspection history per bus. That dossier is generated by an Apps Script time trigger — not a person — which means it fires whether anyone is paying attention or not. That's the kind of detail an auditor likes to verify.
COMPLIANCE FAQ
Yes. The product was built to the FMCSA eDVIR Final Rule effective March 23, 2026, and operates under 49 CFR §§ 390.32 (electronic signatures), 396.11 (DVIR content), and 396.13 (driver review). All four citations appear on every compliance reference we publish.
49 CFR § 390.32. The rule authorizes electronic signatures on FMCSA-required documents provided the signature is unique to the signer, under their sole control, attached to the record, and accompanied by a record of consent. Our PIN-and-attestation flow meets all four conditions. The ESIGN Act provides the broader federal authority underneath that.
The Transportation Supervisor can look it up or assign a new one from the Driver_PINs sheet. PINs are supervisor-managed, not driver-chosen, by design — that's what keeps them unique and under controlled distribution.
Doing so would violate § 390.32(b)'s "under the sole control of the signer" requirement and would expose the sharing driver to falsified-record liability. The legal attestation a driver accepts at sign-in includes acknowledgment that the PIN is theirs alone. The same enforcement question applies to any electronic signature system — the supervisor's policy and the attestation language carry the load.
The inspection is held locally on the driver's phone, marked as unsubmitted, and the driver sees a Retry button. The same UUID is used on retry, so re-submitting the same inspection cannot create a duplicate log row. (Note: there is currently no automatic background retry — retry is manual. This is documented in our internal backlog and applies in rural low-signal environments.)
Yes. The Google Sheet is provisioned in your district's Google Workspace or under a district-controlled Google account. You can revoke our access at any time. If you leave, the sheet stays with you with every row of every inspection log preserved.
WAC 392-145 (school bus operations) and WAC 446-65 (commercial vehicle inspection) apply additionally for Washington operators. Both are consistent with the federal chain. The same submission flow satisfies both.
Your inspection records are in a Google Sheet that your district owns. Going forward, your district would need a new vehicle inspection workflow — but every prior inspection record is preserved, signed, timestamped, and exportable. The compliance ledger does not depend on our continued operation.
TRUST, BUT VERIFY. HERE ARE THE PUBLIC SOURCES.
- 49 CFR § 390.32 — Electronic Documents and Signatures: ecfr.gov / Title 49 → Part 390 → § 390.32
- 49 CFR § 396.11 — Driver Vehicle Inspection Report: ecfr.gov / Title 49 → Part 396 → § 396.11
- 49 CFR § 396.13 — Driver Inspection: ecfr.gov / Title 49 → Part 396 → § 396.13
- FMCSA eDVIR Final Rule (March 23, 2026): FMCSA eDVIR Final Rule
- Washington Administrative Code: WAC 392-145 and WAC 446-65 at app.leg.wa.gov
QUESTIONS ABOUT COMPLIANCE SPECIFICS? WE ANSWER THEM DIRECTLY.
If your district's auditor, attorney, or transportation director has a specific question about how One-Touch DVIR satisfies a particular subsection or sub-clause, email bob@ramventuresolutions.com with the citation and the question. You'll get a response from Bob — not a support ticket — usually within a business day.
For the regulatory record itself, follow the ecfr.gov and federalregister.gov links above. We don't summarize the rules — we cite them and implement them.
Email Bob