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Time to review your drivers’ files

Concern about drivers’ qualification (DQ) files is on the rise, according to a recent survey of fleet managers by the J. J. Keller Center for Market Insights.

Among those surveyed, 34 percent said having accurate and organized DQ files was the second-most important challenge when it comes to FMCSA compliance, up 11 percent since last year. Taking the top spot: “staying up to date” on regulation changes.

With recent DQ rule changes — and audits on the rise — it’s a good time to take stock of your driver files and make sure they’re compliant.

A typical DQ file, whether paper or electronic, contains a mix of the following (not including drug/alcohol testing records):

  • “Permanent” items that cannot be thrown away until three years after the driver leaves your employment,
  • “Rotating” items that you can discard only after you’ve held them for three years, and
  • “Nice to have” items that are not required by the DOT but are useful nonetheless.

If you can relate to the fleet managers in our survey, take some time to review your files and ease your concerns.

Permanent

  • A driver’s application for employment.
  • An initial motor vehicle record (MVR) obtained from the driver’s licensing authority at the time of hire. This now includes MVRs from other countries, when applicable.
  • A road test form and road test certificate (note that the certificate no longer needs to include the driver’s Social Security or license numbers).
    • A copy of the driver’s CDL may be accepted in place of doing a road test (but not for a tank vehicle or double/ triple trailer), then the file must contain that copy obtained at the time of hire.
    • A road-test certificate issued by another carrier may be accepted if the test was within the prior three years.
  • Previous-employer inquiries.
    • A copy of the driver’s written authorization to get information about his or her drug/alcohol testing history from prior employers.
    • A copy of the response(s) received from each previous DOT-regulated employer, or documentation of your “good faith effort” to get a response, or a document explaining why you did not contact a previous employer.
  • Signed authorization from the driver to obtain his/her Pre‑employment Screening Program record, if applicable.
  • Proof of any required training:
    • Longer-combination vehicle (LCV) driver-training certificate.
    • Entry-level driver training certificate for drivers with less than one year of experience hired prior to Feb. 7, 2022.

Rotating

  • MVRs obtained annually (starting one year after hire).
  • MVRs obtained to verify that a CDL holder is medically certified.
  • Notes concerning annual MVR reviews.
  • Annual lists of traffic convictions provided by drivers prior to May 9, 2022 (new lists are no longer required as of that date).
  • Medical examiner’s certificates.
  • Documentation of any medical variances or waivers.
  • Documentation showing that the medical examiner was listed on the National Registry of Certified Medical Examiners at the time of each exam.

Nice to have

  • Qualification checklists.
  • Documents “certifying” that the driver understands and complies with licensing rules, cell phone and texting restrictions, company policies, etc.
  • Statements of on-duty time (must be kept six months for hours-of-service compliance only).
  • Training records for non-required training.
  • “Receipts” for regulation books.

Key to remember: A new survey reveals that driver qualification files are a top concern. With recent rule changes, it may be time for a DQ file audit to make sure you’re in compliance.