Compliance is the name of the game in trucking. As an owner-operator or fleet manager, you need to be good (or get good) at keeping up-to-date records for everything including driver qualification. In this article, we’ll share everything you need to know about driver qualification files and share tips on how to manage them
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What is a Driver Qualification File?
A driver qualification file (DQ file) is a collection of documents the US Department of Transportation requires all carriers to keep on all CDL and non-CDL drivers employed by the business, including owner-operators. It’s meant to be a record-keeping system to ensure all drivers comply with USDOT regulations and to update files regarding any violations and how they were addressed.
What’s Included In A Driver Qualification File?
A complete checklist from the FMCSA can be found owner-operator. Most documents for establishing a DQ File must be requested within the first 30 days of employment and kept on record during the entire time the driver is employed and an additional three years later.
The initial DQ file documents are as follows:
Driver’s Application for Employment
Yes, even if you’re an owner-operator, you have to fill out an employment application. It’ll be the fastest job interview of your life – congratulations, you’re hired! Now sign it and file it away for your DQ File.
Drivers’ Licenses And Road Test Certificates
This is a pretty simple requirement: you must have all your driver’s licenses on record, be they CDL or non-CDL.
For non-CDL drivers or drivers operating doubles, triples, or tankers, you’ll need a valid certificate of a driver’s road test issued within the last three years.
Driver Employment History
For every driver, including owner-operators, you’ll need to conduct an employment history of at least the last three years to find out why they left their last employer and verify all previous jobs they’ve had and any safety violations or accidents they’ve accumulated.
Keep all records of communications with previous employers, such as making phone calls, emails, text messages, etc. to save in the DQ File.
If you’re requesting this information for someone other than yourself, have the driver fill out a release form authorizing you to request their information from previous employers.
Safety Performance History Records
This is any and all documentation related to drivers’ safety record for the last three years and any violations that have occurred. Drivers can dispute any claims of violations from previous employers by submitting a Safety Performance History Information Driver/Applicant Rebuttal form.
Inquiry To State Agencies For 3-Year Driving Record
You’ll need to pull a Motor Vehicle Record from your state’s Department of Motor Vehicles which contains information about the driver’s history for the last three years. This requirement has to be updated on an annual basis.
Pre-Employment Drug And Alcohol Documents
All drivers are required to inform their employer of any positive drug test or have refused to test in the last three years. If they have, they need to complete a return-to-duty process. Drivers are required to clear a drug test before starting employment and be tested randomly on an annual basis. All the results from these tests must be kept in their driver qualification file.
This is also where the FMCSA’s Drug and Alcohol Clearinghouse comes in. The Clearinghouse is a database holding records of violations of FMCSA’s drug and alcohol testing program, as well as return-to-duty processes after violations. All CDL and CLP drivers and employers are required to use the Clearinghouse. This is where drivers can give you consent to look up their records.
Entry-Level Driver Training Certificate
This is only a requirement for drivers with less than one year of experience. After changing the regulation for CDL requirements in February 2022 to a national standard for obtaining a CDL, new CDL drivers are required to present the certificate from their FMCSA-approved training program.
Longer Combination Vehicle (LCV) Driver Training Certificate
This applies only to those drivers that will operate an LCV. They must show proof of having gone through a certified training program, involving a written knowledge test and a skills test. The official certificate can be found on the FMCSA’s website and has to be filled out by the driver’s instructor.
Longer Combination Vehicle (LCV) Certificate of Grandfathering
If you or any of your drivers will operate an LCV and were eligible to operate one before the above LCV Driver Training Certificate requirement went into effect, you can be “grandfathered” in. However, this requires you to meet certain guidelines laid out in federal regulations. You can find these on the Code of Federal Regulations website here.
A multiple-employer driver is someone used as a driver by more than one carrier. Different rules apply to a driver’s DQ File if they’re working for more than one employer. Be sure to read up on these differences in the regulations here.
Skill Performance Evaluation Certificate
This only applies if the employee has certain disabilities or health conditions such as the loss or impairment of an arm, foot, or leg, or a diagnosis of diabetes mellitus treated with insulin.
How Often Do I Need To Update DQ Files?
Once you establish the initial DQ File Documents for yourself and/or any drivers you’re hiring, there are ongoing updates required as well. All of the following documents have to be updated on a regular basis.
- Inquiry To State Agencies For Driving Record – Annual
- Review Of Driving Record – Annual
- Driver’s Certification of Violations – Annual
- Medical Examination Report and Medical Examiner’s Certificate – Every 24 Months
- A note verifying that the medical examiner from the above certificate is listed on the National Registry of Certified Medical Examiners. – Every 24 months alongside the above report and certificate.
What Happens If I Don’t Have DQ Files?
Not having DQ Files or not having up-to-date records for DQ Files poses an enormous risk to your business. The FMCSA regularly conducts audits and investigations into carriers and driver qualification violations are some of the more critical.
Fines for violations in 2019 averaged $6,600 per company. However, audits and investigations should be the least of your worries.
Maintaining DQ Files on drivers is an important risk management tool when it comes to safety and liability. No matter how safe and responsible a driver is, accidents (hopefully minor ones) will happen. When they do, if their driver qualification file is not complete or outdated, this can serve as evidence for a plaintiff in a legal case against your company who can argue that the person should have never been driving in the first place.
What’s The Best Way To Organize DQ Files?
File organization can be overwhelming for many business owners. However, since 2018, the FMCSA changed regulations to allow carriers to keep records electronically. While some business owners may prefer to still keep everything on hand physically, a secure cloud storage solution like DropBox or Google Drive is ideal for the more technologically-inclined owner-operators. As a tech company, of course, we prefer this method, but whatever is most comfortable for you.
More important than where you store documents is how often you update them. We recommend you set up two processes in your business for driver qualification files:
- A checklist to complete when hiring a new driver to set up a new DQ File (we used this FMCSA checklist to write much of this article.)
- Schedule an annual audit of DQ Files on your calendar – and stick to it!
There are third-party services that you can hire to manage DQ Files, but these services are generally designed for larger carriers. As an owner-operator or small carrier, we recommend you organize an internal system to ensure compliance.