Ensuring compliance with federal regulations is crucial for motor carriers operating commercial motor vehicles (CMVs).
But too often companies receive violations during a DOT audit for the basics of driver file documentation.
Every year, government auditors find hundreds of violations when reviewing DQ files for compliance.
A well-organized DQF not only helps in adhering to legal requirements but also enhances your company’s safety and operational efficiency.
This guide provides a detailed checklist to help you complete and maintain each driver qualification file effectively.
What are driver qualification files?
Put simply, a driver qualification file is the driver’s personnel file and is required for anyone driving a Commercial Motor Vehicle as defined be the FMCSA in 49 CFR 390.5 or state authorities.
A DQ file is needed even if the driver is a mechanic quickly moving a vehicle, the company owner moving a vehicle, a part-time or temporary driver, or a driver who works for a private company.
Related: How to protect yourself from truck accident litigation with compliant driver files
After a job offer is extended to a driver, carriers need to build a driver file that includes:
- driver’s licenses
- employment application
- previous employer inquires
- motor vehicle records
- credit history and background checks
- drug test results
- FMCSA Clearinghouse queries
- medical certificates
- and more
What information needs to be gathered in driver qualification files (DQF)?
The difficult part of the DQ File is that companies must know the driver qualifications file requirements to pass a safety audit.
Most of the time, violations occur for a few reasons, including:
- Companies taking shortcuts in the hiring process
- Staff managing the driver files not being trained in DOT regulations, or
- Companies not realizing they must meet these stringent driver qualification file requirements if their fleet is not focused on trucking.
Here is what you need to consider:
Ongoing DQF Updates
Regular updates to your DQF are essential to ensure that all driver information remains current and compliant with regulations. The following outlines the necessary ongoing updates:
- Annual Inquiry to State Agencies for Driving Records
- Action: Contact state agencies each year to obtain an updated copy of each driver’s Motor Vehicle Record (MVR).
- Purpose: This ensures that you have the most recent information on each driver’s driving history.
- Retention: Documents are retained for three years from the date of execution.
- Annual Review of Driving Records
- Action: Collect and review the current MVR from the state that issued the driver’s license at least once every 12 months.
- Purpose: To verify that drivers still meet the minimum safe driving requirements and are not disqualified under 49 CFR 391.15.
- Documentation: Include a note with the reviewer’s name and the review date in the file.
- Retention: Documents are retained for three years from the date of execution.
- Medical Examination Report and Certificate
- Action: Ensure all commercial drivers pass a physical exam by a licensed medical examiner every 24 months.
- Purpose: To confirm drivers are medically fit to operate CMVs.
- Documentation: Retain a copy of the medical examiner’s certificate and the CDLIS motor vehicle record for CDL drivers.
- Retention: Documents are retained for three years from the date of execution.
- Verification of Medical Examiner’s Certification
- Action: Verify that the medical examiner is listed on the National Registry of Certified Medical Examiners.
- Purpose: Ensures the medical examiner is qualified and certified.
- Documentation: Include a note in the driver’s qualification file.
- Retention: Documents are retained for three years from the date of execution.
Initial Driver Qualification File Documents
When onboarding a new driver, certain initial documents must be collected and filed. The following outlines the initial documents and how long they need to be retained:
- Driver’s Application for Employment
- Action: Complete and sign an application for employment before the driver operates a CMV.
- Retention: Keep the document for the life of employment plus three years after termination.
- Driver’s Road Test Certificate or Equivalent
- Action: Ensure the driver has successfully completed a road test and received a certificate.
- Retention: Keep the document for the life of employment plus three years after termination.
- Inquiry to Previous Employers: Safety Performance History Records Request
- Action: Investigate the driver’s employment record over the past three years within 30 days of hire.
- Purpose: To assess the driver’s safety performance history.
- Retention: Keep all request and response documentation for the life of employment plus three years after termination.
- Safety Performance History Records: Driver Correction or Rebuttal (if applicable)
- Action: Maintain records of any corrections or rebuttals to safety performance history.
- Purpose: To address and document any inaccuracies in the driver’s history.
- Retention: Keep these records for the life of employment plus three years after termination.
- Inquiry to State Agencies: 3-Year Driving Record
- Action: Obtain the driver’s MVR for the past three years within 30 days of hire.
- Purpose: To ensure comprehensive driving history is reviewed and updated annually.
- Retention: Keep the MVR in the driver’s personnel file for the life of employment plus three years after termination.
- Pre-Employment Drug and Alcohol Documents
- Action: Conduct drug and alcohol testing for safety-sensitive functions unless exceptions apply.
- Purpose: To ensure drivers are free from controlled substances and alcohol abuse.
- Retention: Retain all documentation related to drug and alcohol testing as per regulatory requirements.
Additional Documents for Specific Situations
Certain drivers or situations may require additional documentation to comply with specific regulations:
- Longer Combination Vehicle (LCV) Driver Training Certificate
- Action: Ensure drivers operating LCVs have a valid LCV Driver Training Certificate or Certificate of Grandfathering.
- Retention: Keep the document for the life of employment plus three years after termination.
- Longer Combination Vehicle (LCV) Certificate of Grandfathering
- Action: Determine eligibility under the grandfather clause as per 49 CFR 380.111.
- Retention: Keep the document for the life of employment plus three years after termination.
- Multiple-Employer Drivers
- Action: Comply with all requirements in 49 CFR 391.63 for drivers employed by multiple carriers.
- Retention: Keep all relevant documents for the life of employment plus three years after termination.
- Skill Performance Evaluation (SPE) Certificate
- Action: Obtain an SPE certificate through a joint application by the driver and motor carrier.
- Retention: Keep the certificate for the life of employment plus three years after termination.
Too Complicated? Let CNS Do this for you!
Maintaining a comprehensive Driver Qualification File is not only a regulatory requirement but also a best practice for ensuring the safety and reliability of your fleet operations.
For more detailed guidance or assistance with your Driver Qualification Files, don’t hesitate to reach out to us at 1.888.260.9448 or visit DQF.CNSprotects.com.
Our experts are here to help you navigate the complexities of DQF maintenance and ensure your motor carrier operations remain compliant and efficient.