Staying compliant with Federal Motor Carrier Safety Administration (FMCSA) regulations is an ongoing process. It is important to be aware of the requirements for hiring drivers as well as what you need to keep on record throughout their employment. Driver qualification files, also called DQFs, include information about safety-sensitive employees. These files must be properly maintained and should be easily accessible in case of an audit.
Driver qualification files must include:
Initial Pre-Employment Documents
The following information must be collected and documented at the start of a driver’s employment:
Application for Employment
The driver’s application must be completed, signed, and kept on file. The FMCSA regulates what this application must include and this is outlined in 49 Code of Federal Regulations (CFR) 391.21.
Road Test Certificate
To drive a commercial vehicle, an individual must successfully complete a road test. You must keep a copy of this completion certificate on file. A valid commercial driver’s license (CDL) is an acceptable equivalent.
Inquiry to Previous Employers
You must investigate the previous three years of the driver’s employment by requesting documentation from previous employers. The driver qualification file must include a record of this request as well as the responses. Additionally, if the driver makes a rebuttal or correction due to inaccuracies in the information from employers, you must keep this on file as well.
Three-Year Driving Record
Motor carriers must contact agencies for any state where the driver has held a CDL to obtain the driver’s motor vehicle record (MVR) for the past three years.
Drug and Alcohol Testing Documents
Trucking companies must perform drug and alcohol testing at specific times. In addition to performing required pre-employment drug testing, you must investigate whether a new driver has any drug or alcohol violations on record for the past three years. The driver qualification file needs to include any violations as well as documentation of the return-to-duty process, if applicable.
Since January 6, 2020, it is necessary to query the FMCSA Clearinghouse and to conduct a traditional manual inquiry with previous employers. This is because the Clearinghouse does not yet cover the full three-year timeframe. After January 6, 2023, only the electronic query will be required. The Clearinghouse retains a record of queries, so it is not necessary to maintain a separate copy, although you may choose to do so.
Additional Documents
For some types of drivers, additional documentation is necessary. For example, drivers with less than one year of experience will need an entry-level driver training certificate.
Ongoing Updates
MVR Inquiry
Each year, motor carriers must request an updated MVR for each of their drivers.
MVR Review
In addition to keeping the annual MVR updates on record, it is necessary to document an annual review of this information. You must ensure that the CDL driver is not disqualified from operating a commercial motor vehicle (CMV). The list of disqualifying offenses is given in 49 CFR 391.15.
Driver’s Certification of Violations
Annually, drivers must submit a list of all motor vehicle law violations that they were convicted of in the past 12 months. Motor carriers must then compare this list with the annual MVR inquiry to ensure there are no discrepancies.
Medical Examination Report and Certificate
Every 24 months at a minimum, drivers must complete a Department of Transportation (DOT) physical with a qualified medical examiner. You need to keep a copy of the medical examiner’s certificate that states the driver is qualified to operate a CMV. In addition to the report and certificate, you must include a note verifying that the examiner is listed on the National Registry of Certified Medical Examiners.
Driver Qualification File Management
At HDS Safety Services, we understand that it can be difficult to keep track of the many FMCSA regulations and to maintain files for all of your drivers. Our driver qualification file management service makes it easy for you to stay compliant. We can organize your documents as well as optimize your hiring process.
