IRP Mileage Records

Who This Applies To

• Motor carriers building or updating mileage tracking systems to support IRP renewal and possible audit.
• Fleet managers reviewing whether GPS exports, ELD data, or dispatch records can substitute for paper trip logs in an IRP audit.
• Owner-operators preparing annual mileage summaries for IRP renewal from dispatch paperwork or logbook entries.
• Carriers who received an IRP audit notice and need to locate distance records for registration periods already filed.

What To Verify

• The retention period required by the base jurisdiction. The IRP Agreement commonly references four years, but some jurisdictions require longer — verify with the base jurisdiction before discarding records.
• Whether the base jurisdiction accepts electronic records — GPS exports, ELD data, or electronic dispatch records — as primary mileage documentation, and what detail level is required.
• That records capture what IRP auditors look for: vehicle unit, date, origin, destination, route or GPS track, and jurisdiction-level miles for every trip that crossed a state or provincial line.
• How border crossings, deadhead miles, and off-road or non-IRP-jurisdiction miles are handled in the mileage summary — verify treatment with the base jurisdiction.

Step-by-Step Overview

1. Set up a records system organized by vehicle and registration year from the start. Retroactive reconstruction from summary sheets is time-consuming and often incomplete.
2. Collect trip records throughout the year — weekly at minimum. Drivers who submit trip logs daily or at each state-line crossing produce records that survive IRP audits better than summaries assembled at renewal.
3. Summarize jurisdiction miles per vehicle for the registration year only after trip-level records are complete. Build the summary from the trips, not the other way around.
4. At renewal, reconcile the jurisdiction mileage summary against trip-level records before submitting. Discrepancies found during renewal are easier to correct than ones found during an audit.
5. Retain filed registrations, distance summaries, and the underlying trip records together, organized by registration year.

Common Mistakes

• Keeping annual distance summaries but not the trip-level records that built them. IRP auditors ask for both — the summary shows what was reported; the trips prove it.
• Using estimated or average distance figures at renewal when actual trip records exist. Estimated figures that diverge from actual records are a primary audit finding.
• Combining all vehicles in the fleet into a single mileage total without vehicle-level support. Each vehicle must have its own distance record showing jurisdiction-by-jurisdiction miles.
• Disposing of records before the retention window closes. Check the base jurisdiction's published rule — four years from the registration year is the common baseline, but it may be longer.