• Failing to maintain DQ files can have serious consequences for carriers.

Each year, the Federal Motor Carrier Safety Administration (FMCSA) identifies failing to maintain driver qualification (DQ) files on each driver as one of the most common critical violation found during compliance reviews of motor carriers. Violations sprinkled throughout the top acute and critical violations each year are associated with DQ files, such as:

• Previous employer inquiries;
• Medical certification; and
• Disqualification to operate a commercial motor vehicle (CMV).

Carriers should weigh these critical violations the same as they would weigh drivers failing to fill out their logbook properly. Both are violations with substantial penalties.

To prepare for a self-audit, carriers should review the general requirements for DQ files in 391.51 and create a checklist of items needed to comply with this critical regulation, such as a driver’s:

• Employment application
• Licensing requirements
• Driving record
• Medical reports and certificates
• Road tests

It is not enough to simply verify whether the required documents are in each driver’s file. It is equally important to check the dates of documents and replace those whose “shelf life” has expired. These requirements are addressed in 391.51 as well. Carriers should understand that something as uncomplicated as a missing signature or an illegible document can have as much consequence for them as a driver operating a CMV with a revoked license.