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The regulations do not specify where the files are to be stored, as long as they can be at the motor carrier’s principal place of business, or other specified location, within 48 hours of being notified of an audit.
It would be beneficial for a carrier to go above and beyond what is required; to implement something similar to the confidential requirements of a drug and alcohol program by choosing a secure location with limited access. Only certain personnel should be allowed to review the files. Consider choosing a filing system which is secure against just about anything — a crowbar, fire, or flood. If the DQ file is combined with the confidential drug and alcohol papers, any medical information, or the Driver Investigation History documentation, it will automatically default to the stricter of the recordkeeping requirements – a secure location with limited access.
If a carrier’s DQ files are stored electronically, they need to make sure that they have passwords set up; as with a physical file, only designated personnel should gain access. They need to be sure to back up data frequently, since electronic storage is not just vulnerable to theft or unauthorized access, but also to accidental loss.