Driver Qualification Simplified

4 CMV Fleet Solutions compliance series is about helping fleets comply and stay in compliance with the DOT regulations. Below are the requirements for driver qualification files. These regulations apply to all drivers who meet your state or federal definition of a commercial driver. The regulations outlined below include non-CDL commercial drivers, specifically if they operate in interstate commerce (across state lines or haul freight that crosses state lines) or your state considers a commercial driver. (state exceptions may apply) and commercial drivers license holders.

All trucking companies that operate commercial vehicles (GVWR over 10,001 lbs) in interstate or intrastate commerce (subject to state regulations) must have driver qualification files for every commercial driver per FMCSR’s 391.51

All motor carriers should have three types of files, electronic or paper are acceptable to the FMCSA during audits or compliance reviews. 

1.Driver Qualification file 

2. Drug and Alcohol file

3. Personnel file

Driver Qualification Files

Retain for the length of driver employment plus three (3) years. 

  • A driver application 
  • Investigation and responses for verification of employment at previous motor carriers last three (3) years for all work, previous ten years of commercial driving experience. Document date requested, how you asked for the information (email, phone), and who you sent the request. Request previous employer information at least twice. This documentation will meet DOT requirements during an audit if the previous employer does not respond. 
  • Must start the verification of employment and safety history within 30 days of the date of hire.
  • A copy of the driver license at new hire
  • A copy of renewed driver license if applicable
  • A copy of the new hire medical card (certificate) (preferred if CDL) required if the non-CDL commercial driver.
  • A copy of renewed medical card (certificate) if applicable
  • A motor vehicle report dated 30 days within the hire date from each state the driver has had a license.
  • Medical examiners registry note confirming medical card examiners is certified at the time of hire.
  • CDLIS report at the time of hire. 
  • Road test are required to be on file if a the driver is a non-CDL commercial driver. Road tests are not required for CDL drivers. However, it is a best practice and highly recommended. 
  • Many fleets have their commercial drivers license holders (CDL) sign a document stating the driver understands he must not hold more than one commercial drivers license at any time. This is recommended for the file, but in all the DOT compliance reviews that I have sat through in the last ten years, it has never been requested.

The following items can be removed from the driver qualification file three (3) years from the date of execution:

  • Annual motor vehicle report (MVR) (must be dated within 12 months of last MVR)
  • Annual record of violation (list of citations or tickets the driver received in last 12 months) completed and signed by the commercial driver and signed by motor carrier representative (dated within 12 months of the previous record of violations)
  • Renewed medical cards Medical examiners registry note confirming medical card examiners is certified.
  • Medical variance (due to Skills Assessment) provided by FMCSA

Drug and Alcohol File (commercial drivers license holders only)

A separate drug and alcohol file should be maintained with the following: 

Personnel File

Your commercial driver personnel file should include.

  • Sign off sheets for
    • Employee handbooks
    • Policies
    • Corrective action or disciplinary issues
    • Documentation of truck assignments, logins for electronic logging devices, timecards information, and other asset documentation like computers if assigned.
  • Emergency contact information
  • Healthcare, 401K, or other documents as required by the employer.
  • Road test for CDL drivers
  • Training documentation
  • Anything that is not required in the drug and alcohol file or the drive qualification file. 
  • All drug and alcohol testing that is NOT conducted with a DOT chain of custody. 

We hope this helps your fleet get in compliance and stay in compliance.

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