Within any line of business, employee files are a vital part of record keeping and the trucking industry is no exception to this. In fact, the federal motor carrier safety regulations are quite a bit more strict in this process regarding records for motor carrier drivers holding a commercial driver’s license. The requirements in place here go a little deeper than most other lines of business.
A DQ file, or better known as a driver qualification file goes beyond just keeping an MVR or motor vehicle record and is actually a detailed file compiling the full history over the drivers employment keeping track of safety and certification records of each and every driver that you employ. This file is required by the DOT and FMCSA for all drivers operating a commercial motor vehicle.
Below is a list of items that you will want to make sure to include in your files but be aware that the FMCSA can amend this list at any time so it is always wise to check the FMCSA regulations 49 CFR 391.51for the most current information.
- Driver’s application for employment – to find out what is required on the application see 49 CFR 391.21 Application for Employment
- Copy of the Motor Vehicle Report – Must have MVR of each state where the driver held or holds a motor vehicle operator’s license or permit during the preceding 3 years
- Certificate of driver’s road test issued to the driver or a copy of the license or certificate which the motor carrier accepted as equivalent to the driver’s road test
- Annual review of driver’s driving record (must be conducted annually after driver starts with company)
- List or certificate relations to violations of motor vehicle laws and ordinances
- Medical examiner’s certificate – must maintain current copies
- Note relating to the verification of medical examiner listing on the National Registry of Certified Medical Examiners
- Any medical variance issued by the FMCSA, including a Skills Performance Evaluation (SPE) or Medical Exemption letter
Other records that are required to be kept in a location where access is limited to those involved in hiring decision or who control access to this data:
- Records relating to the investigation in the safety performance history of a new or prospective driver.
- Includes copies of the responses or documentation of good faith effort to contact previous employers.
- Driver’s written authorization for the motor carrier to seek information about a driver’s alcohol and controlled substance history as required.
Simply enough, all CDL drivers of a commercial motor vehicle, without exemption, are required to have a driver qualification file. This is not just a detailed motor vehicle record or preferred method of record keeping for truckers either. This is actually a set of recordkeeping requirements regulated by the federal motor carrier safety administration (FMCSA) to maintain operating authority. A new driver or even an owner-operator also needs to maintain a driver qualification file on himself even if he is the only motor vehicle operator employed under that company.
The minimum requirements are that the drivers qualification file should be updated at least during an annual review, but it is always better to update the file on an ongoing basis. Every pertinent update of things like safety performance history, a driver’s road test, general driving record, report from the medical examiner’s certificate, etc. should be kept for the driver to keep this information up to date.
It is wise to keep a driver qualification file checklist to ensure that your drivers files have all the information they are required to contain. This checklist may detail important items from the start of their employment throughout the life of their time with your company such as the test results from an employment drug test as well as continued drug testing for controlled substances, alcohol testing results, as well as a record of rebuttal for any positive tests that the driver did not agree with the results of that testing.
Your checklist would also include documentation such as records of a physical exam or medical examination from a certified physician registered with the national registry of certified medical examiners. This medical certification for drivers along with a record of safe driving and a skill performance evaluation certificate can play into your ability to haul specialized loads suchs as loads containing hazardous materials. Without meeting these standards a driver may be disqualified from hauling such loads.
Past that, all driver qualification files for your trucking company need to be easily available for access if and when requested by an FMCSA agent, operating under the authority of the Department of Transportation (DOT) or officials of state agencies. If they wish to review these documents such as a driver’s medical card or the driver’s certifications, they should be readily accessible for them to do so.
A driver qualification file must be maintained for each year for every driver you employ; as well as for three years after employment for previous employees. When a driver has been with you for less than three years, you’ll need to obtain the appropriate records from their previous employers to put together their driver qualification file.
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