Answer: No. If Sue is never expected to operate a CMV (as defined in 390.5, which includes both CDL and non-CDL vehicle types) for the motor carrier, the motor carrier can treat Sue as someone who has left the company. Sue should not appear on the driver roster, and her DQ file is not kept up to date and can be purged within three years of her change in positions. However, had Sue been expected to operate a CMV, she needs to be treated as a driver. Operation of the CMV, even if on rare occasions, requires that the driver be completely qualified. This includes emergency back-up drivers, seasonal fill-in drivers, and those who move CMVs around a company lot that is open to public travel.