Zero Inspections in SAFER Doesn't Mean Clean. It Means Nobody Has Looked.

I once looked at a carrier's SAFER snapshot and saw the cleanest profile I'd ever seen. No crashes. No violations. No BASIC alerts — not a single one in the red or even the yellow. Zero OOS rate. I was about to send the load confirmation when something made me scroll past the percentile bars. Every single BASIC said the same thing: "Insufficient Data."

Zero inspections in the prior 24 months.

The carrier had been operating for 14 months. One truck. Active authority, insurance filed on time, no complaints in the system. Nothing wrong, technically. But nobody — not a weigh station officer, not a roadside enforcement trooper, nobody — had ever looked at that truck or that driver. Not once.

I didn't tender the load. I called the carrier, asked a few questions, and what I heard didn't sit right: the driver had been running mostly local exempt deliveries, just got into interstate commerce, didn't know what a Form MCS-150 was. Turned out the carrier principal had gotten authority on the cheap through an online filing service, bought a used truck at auction, hired a nephew with a CDL, and started hauling. Legally, they'd done enough to check the boxes. Operationally, they were as unvetted as a carrier can be.

That's what "Insufficient Data" actually looks like.

What FMCSA's SMS Is Telling You — and What It Isn't

FMCSA's Safety Measurement System scores carriers on seven BASICs: Unsafe Driving, Crash Indicator, HOS Compliance, Vehicle Maintenance, Controlled Substances/Alcohol, Driver Fitness, and Hazardous Materials Compliance. Each BASIC generates a percentile score based on inspections, violations, and crash data over the previous 24 months. But there's a floor. If a carrier doesn't have enough data points — for most BASICs, that's fewer than three or five inspections with relevant violations in the window — FMCSA doesn't generate a score at all. The system returns "Insufficient Data."

That flag doesn't mean the carrier passed. It means there wasn't enough data to evaluate them. The distinction is everything.

Most brokers treat an empty SAFER record like a clean one. "No alerts, no violations, nothing in the system" gets read as "safe carrier." What they're actually looking at is a carrier that hasn't had enough contact with enforcement to score on anything. That could mean they're clean. It could also mean they're running short exempt hauls, local routes, or infrequent interstate trips. It could mean the truck never gets near a weigh station. It could mean the driver is competent, experienced, and careful. Or it could mean nobody has ever checked.

In a post-Montgomery v. Caribe Transport II world, that ambiguity lands on you.

Why the Inspection Count Is the Metric You're Not Looking At

When I screen a carrier, the first thing I look at after authority age isn't the BASIC percentiles — it's the inspection count. How many Level I through Level V inspections does this carrier have in the last two years? One thousand miles of roadside history tells you more than a clean SAFER dashboard ever could.

A carrier with 40 inspections and a 4% OOS rate has been looked at. You know something. The equipment gets checked, the logs are reviewed, the driver is scrutinized. Even an imperfect inspection record is a record.

A carrier with zero inspections has given you nothing to evaluate. You don't know if the truck is road-legal. You don't know if the driver's qualification file exists. You don't know if the hours-of-service records are real or invented. You're flying entirely on credentials — the MC number, the insurance filing, the certificate — and those credentials tell you the carrier is authorized. They don't tell you anything about what they're actually doing.

There's a specific provision of 49 CFR Part 385 that covers how FMCSA evaluates carriers for safety fitness. The methodology is built on inspection and crash data. FMCSA knows that a carrier with no inspection history can't be rated, which is why "Unrated" exists as a separate safety fitness status. But the SMS BASIC system goes further than the rating: it tries to give you granular signals even for carriers that haven't been formally rated. When the SMS can't generate those signals because there's no data, it's not a green light. It's a transparency gap.

The same section, 49 CFR Part 385 Appendix B, makes clear that FMCSA uses a carrier's record over the prior 12 months (for safety ratings) or 24 months (for SMS) to evaluate safety fitness. A carrier with nothing in that window hasn't demonstrated safe operation. They just haven't been observed.

The Legal Frame After Montgomery

After Montgomery v. Caribe Transport II, the standard for broker carrier selection has been brought into state-court negligence analysis. FMCSA preemption is off the table. What remains is a reasonable-care question: did you take the steps a reasonably prudent broker would take before putting this carrier on your freight?

A plaintiff's lawyer looking at your carrier file for a zero-inspection carrier is going to ask two questions. First, did you know the carrier had no inspection history? Second, if you knew — or should have known, given how easy this information is to pull — what additional diligence did you do?

The "should have known" part is what gets brokers. SAFER is public. DOT inspection data is public. The fact that a carrier has zero inspections is right there on the screen. If you tendered a load to a carrier with no inspections, a 9-month-old authority, and no discernible operating history, and then something went wrong, you're going to need a very good answer for why that profile looked acceptable to you.

"The BASICs were all green" won't cut it. An attorney who knows this space will immediately ask: were those scores, or were they flags for insufficient data? The answer is flags. And a flag for insufficient data isn't a clean score — it's the absence of a score.

What I Actually Do With a Zero-Inspection Carrier

I don't have an automatic rule that bans carriers with zero inspections. New carriers exist. Small operators who run regional freight legitimately never pile up inspections. I've moved loads on two-truck carriers with six months of authority and had zero problems.

But I treat the inspection count as a multiplier on every other signal I look at.

If authority is under 18 months AND inspection count is zero AND power unit count is one or two — that combination triggers a longer call, not just a form pull. I want to hear the carrier's voice. I want to know how long the driver has been CDL-licensed (not just whether they have one), whether they've run this lane before, where they're coming from, and whether they can tell me anything about the truck — the year, the last service, the DOT number. I want to hear if they know what a pre-trip inspection is supposed to look like and whether it actually happens.

I also run verification. If I'm going to tender freight on a carrier with no enforcement history, I want independent proof that the truck exists, the driver exists, and they're at the right location before I send a load. That's exactly what Verifi was built for. Text the driver a link, get back GPS-tagged photos of the truck and trailer — VIN, plate, cab — before the load. That gives me something to document that SAFER can't.

If a carrier pushes back on Verifi or refuses the pre-tender check, the call is easy. A carrier with zero inspections who also won't let me confirm who's picking up my load is a carrier I don't use.

How I Document This

When I move freight on a carrier with fewer than five inspections in the past 24 months, I note it explicitly in the carrier selection record. It doesn't sink the carrier automatically — but it changes what I document.

What goes in the file:

• Screenshot of the SAFER snapshot, including the inspection count and the "Insufficient Data" flags across the BASICs
• Date and summary of the verification call — who I spoke to, what I asked, what they said
• Verifi record if applicable: the GPS-tagged photo set with timestamp and VIN confirmation
• My written selection rationale, noting that I was aware of the limited inspection history, what I relied on in lieu of enforcement data (call, references, Verifi), and why the combination met my threshold

The written rationale is the part most brokers skip. It's also the part a plaintiff's attorney can't attack if it exists. If your selection record says "MC-2147893, DOT-4013829, zero inspections in last 24 months, low OOS threshold unscored — verified driver identity and truck condition via Verifi on [date] prior to dispatch, driver confirmed 7 years CDL experience on dry van interstate," you've created a record that shows you saw the gap, assessed it, and documented your response.

That's what due diligence actually is. Not a checkbox. Not a SAFER screenshot. A record of the judgment call you made and why.

The Hardest Part of This Conversation

Most brokers I talk to already know the inspection count matters. The problem isn't awareness. The problem is that pulling carrier snapshots and reading past the BASIC percentiles takes time, and time on a spot load is the one thing you don't have.

That's why I built DOTScreener the way I did: the inspection count, the authority age, and the BASIC data surface together in one screen, and the system tells you when the combination looks like something you should be careful about. You still make the call. But you can't accidentally ignore the inspection count if the platform puts it in front of you every time.

A carrier with zero inspections and "Insufficient Data" across every BASIC isn't automatically a bad carrier. But they're an unverified one. And after Montgomery, the difference between those two categories is yours to explain. When someone asks whether you knew — and they will ask — your carrier selection record is how you answer that question.

— Mason Lavallet

Founder, DOTScreener.com