Here at Provident Commercial Finance our #1 goal is to support the trucking industry in as many ways as possible. One way we can help is provide answers to some of your most important driver qualification file questions.
Q: What is the hardest part of the New Entrant Safety Assurance Program?—– 0:32
Having a complete and organized Driver Qualification File is the most important step to take with the New Entrant Safety Assurance Program.The Department of Transportation and FMCSA have requirements of what files must be on record. Always make sure your files are kept as neat and orderly as possible. This will not only help you stay on top of things but help in the event of a future audit.
Q: What is a Driver Qualification File? —— 1:03
Your driver qualification file, or DQF for short, is a record-keeping requirement of the FMCSA. Trucking companies must meet this requirement for all of their employed drivers. Regardless of the size of your company all drivers will have to have a DQF. The DQF includes a plethora of different documents such as the driver’s application, background checks completed, and an employment verification form with the required previous years of employment shown. These are just a few of the many files required for the DQF. The most difficult part of the DQF is that in the event of a safety audit, trucking companies must display knowledge of all the driver qualifications file requirements. Due to the shear size of the list of requirements this can be overwhelming to most. To alleviate those feelings we explain each driver qualification form requirement.
Q: Where can I find a list of driver qualification file requirements?—— 1:36
To obtain a complete list of requirements for the DQF they can be found in the Federal Motor Carrier Safety Regulation (FMCSR) regulation book in Part 391. We also will have them explained below.
Q: What do I need to put in the DQF, and why? ——- 1:53
To make sure you have all necessary documents included in your DQF most trucking companies follow a checklist. This checklist includes the eight main requirements. The first five, provide proof of your truck driver’s background and their character. It is best practice to keep these records easily accessible in case an authorized enforcement agent needs to verify that your driver is authorized to operate a commercial motor vehicle (CMV). Also included, the driving history records in your DQR provides evidence that the driver has been driving safely and following traffic laws over the past three years.
Like most things these requirements are always adapting and changing. To stay on top of any future changes to these requirement you can always reference them at the FMCSA Website https://csa.fmcsa.dot.gov/safetyplanner/Default.aspx
- THE APPLICATION OF EMPLOYMENT
For each employee’s DQR you will need to include the employee’s application they submitted. These applications can be created by your own company as long as they contain all the required information listed in the Electronic Code of Federal Regulations. You can also use the new driver application form provided by the FMCSA .
- MOTOR VEHICLE RECORD (MVR) FROM EACH STATE LICENSING AGENCY ANNUALLY
It will be your trucking company’s responsibility to request a MVR for each of your truck drivers annually. These records must cover the prior 12 months for every state that your driver held a commercial motor vehicle operator’s license.
- MOTOR VEHICLE RECORDS (MVR) FOR PREVIOUS 3 YEARS
When bringing on new drivers, as the owner you must request and investigate all MVR’s your employee may possess from every state they may have held or holds a license/permit for. This will need to cover 3 years driving history.
- REVIEW OF MVR
Annually, your employees’ MVRs must be reviewed to determine if the driver met the requirements for safe driving. You also will need to evaluate the drivers driving qualifications.
This review must be properly documented and must include the name of the reviewing person and the date of the review. If there was evidence of FMSCA regulation violations they must be identified and disclosed in the report. As always take your time reviewing these records to avoid any errors in determining your drivers qualifications. This will help avoid putting your trucking company out of service.
- RECORD OF VIOLATIONS
In the past every trucking company was required to obtain a list or certificate from each driver showing any violations they had in the previous 12-months. This list included violations of motor vehicle traffic laws and other ordinances. Effective May 9, 2022 the FMCSA no longer requires the annual list of violations to be included with your DQR. This ruling eliminated the duplicative nature of the Record of Violation file. Instead MVR monitoring and annual reviews will be more important than ever in evaluating your drivers safe driving and qualifications.
- COPY OF COMMERCIAL DRIVER’S LICENSE
For each driver a copy of their CDL is necessary to prove they are qualified to operate a truck. In the DQR your company should have any of the following showing they are qualified.
- Copy of License
- Completed Driver Road Test Certificate
- Equivalent Certificate that is accepted as the driver’s road test.
Make sure all CDLs are updated in your employee files to provide the necessary documentation that your drivers are indeed qualified to operate a commercial motor vehicle.
- MEDICAL EXAMINER’S CERTIFICATE OR LEGIBLE COPY
When applying for or renewing a CDL a Department of Transportation (DOT) physical exam must be conducted. These exams must be performed by a licensed medical examiner listed on the FMCSA National Registry. Generally the DOT physical exam is valid for up to 24 months. However, the medical examiner may issue a certificate valid for less than 24 months if there are concerns for the drivers medical status. This completed examination report, paper or digital is kept on file at the medical examiner’s office for a minimum of 3 years. It is also required for the medical examiner to provide these records to any authorized representative of the FMCSA or a state, federal or local law enforcement agency representative withing 48 hours of the request. Lastly if the FMCSA issues a medical variance to obtain the medical examiner’s certificate the medical variance document must be added to the drivers DQF.
- NOTE REGARDING MEDICAL EXAMINERS CERTIFICATE
As the FMCSA states, for your driver qualification file all carriers must provide a note that verifies that the medical examiner utilized is listed on the National Registry of Certified Medical Examiners.
Q: Does my driver need to have their medical Examiners Certificate with them all the time? ——3:40
In the past drivers were required to have their medical examiners certificate with them at all times. Most states today now have drivers self-certify at their DMV once they renew and complete their DOT Physical. This self-certification attaches then to their CDL. This allows law enforcement agent to pull up their certification when they run their CDL and they can then verify if the driver is medically qualified to operate a CMV. An important note, the self-certification has to be completed in a time-frame of 30 days or less after completing your DOT physical. If the driver fails to self-certify then their license will be deemed unqualified to operate. If your CDL is marked as unqualified, it generally is a fast and easy fix. As soon as the DMV or state licensing agency receives the copy of the drivers medical examination the hold will be lifted.
When in doubt it is never a bad idea for a truck driver to keep a legible copy of the medical examination certificate on themselves when driving.
Q: How long do I need to keep the records for the medical examiner certificate?—— 5:37
The Medical examiner certificate will be updated every 1-2 years. 2 years is the maximum amount of time drivers can wait before they renew DOT physical and their medical examiner certificate. Some drivers may have a shorter period of 1 year or less depending on their medical history. It is important to keep the most updated physicals on file in your DQR. Like most documents the FMCSA requires that these records for the DQF need to be kept for the preceding 3 years for all drivers.