InOut Labs’ Driver Qualification File Management Services

Proper management of Driver Qualification (DQ) files is crucial for FMCSA-regulated employers to ensure their drivers are qualified and compliant with federal regulations. We understand the challenges employers face in maintaining these files safely, confidentially, and in line with compliance standards. That’s why we offer a comprehensive, fully-managed, electronic driver management system that takes away the burden and streamlines the entire process for you.

Who Needs to Manage Driver Qualification Files?

Employers of drivers who operate Commercial Motor Vehicles (CMVs) with a GVWR of 10,001 lbs or more. Details

There are 13 Driver Qualification Files that need to be maintained on EVERY DRIVER.

Not 12 out of 13.

13 out of 13.

Yes, it’s a lot.

What are Driver Qualification Files?

The FMCSA requires that employers of CDLs maintain certain records. When an auditor comes knocking you’ll need to be able to produce the following:

  • Employment Application: The FMCSA requires an employment application be on file — even for Owner Operators. Yep. Owner Operators need to fill out a job app too! See 391.21

    • Three years of employment history (10 years for those applying for a job to operate a vehicle with a GVWR of 26,000+ pounds)
    • Nature and extent of the applicant’s experience operating a CMV
    • Record of moving violations over the past 3 years
    • Record of accidents over the past 3 years
    • Denial, revocation, or suspensions of license to operate a CMV

    Sample Employment Application Here

  • Medical Examiner’s Certificate: All drivers must be physically qualified to operate a CMV and must undergo a DOT medical evaluation at least every two years. But some are renewed at 12, 6, or 3-month intervals due to health conditions. See 391.43(g)

    A copy of the applicant’s medical card must be kept on file and employers must keep it up to date. The employer must verify the medical examiner’s status on the national registry and notate this in the file.

  • Copy of Driver’s License: The certificate of driver’s road test issued to the driver (391.31(e)), or a copy of the license or certificate, which the motor carrier accepted as equivalent to the driver’s road test pursuant to 391.33

  • Road Test Certificate: Drivers without CDL’s, or those driving larger vehicles must be tested. It’s good practice to conduct a road test with every new hire. Your vehicles may be totally different from anything the applicant has driven in the past. See 391.31

  • Motor Vehicle Records: The employer must obtain and maintain copies of MVRs for every state the driver has held a license or permit over the last 3 years. And you must perform an annual MVR check. See 391.25(a)

  • Annual Driver’s Certificate of Violations: Employer must maintain a list of any violations over the previous 12 months. See 391.27

  • Annual Driving Record Review: Employer must maintain documentation of annual driving record review. Check the MVR and keep a record that you checked it. See 391.25(c)(2)

  • Pre-Employment Drug Test Results: Keep a copy of the MRO’s verified negative result for the Federal pre-employment drug test. It is a requirement for CDLs that they not be put to work until employer has received a negative result. Best practice is to keep this result with your DQ files as it WILL come up in an audit.

  • Drug & Alcohol Testing Policy Acknowledgement: This is the page from the FMCSA drug policy that the driver signed when hired. Yes, you need to do that. It will likely be requested in the event of an audit, so it’s good practice to keep it with your DQ files.

  • Previous Employer Inquiry Records:Must obtain and maintain information from the previous 3 years of employment for all DOT-regulated positions and must include:

    • Written authorization from the applicant permitting the prior employer inquiry.
    • Documented attempts made to obtain records from previous employers, including those who do not respond.
    • Documented responses from previous DOT-regulated employers.
    • Documentation if the employee held no previous DOT-regulated positions.

    This requirement expires 1/6/2023

  • Clearinghouse Records:

    • Documentation of Limited Query
    • Signed Driver Consent for Annual FMCSA Clearinghouse Limited Query

  • Entry-Level Training: All drivers are required to receive training, with required certification by the motor carrier. All drivers with less than one year of commercial driving experience are required to complete training, which must be provided by the motor carrier covering four main topics:

    (a) Driver Qualification, Medical Examinations, Drug/Alcohol Testing
    (b) Hours of Service for Drivers
    (c) Driver Wellness
    (d) Whistleblower Protection.

  • FMCSA Evidence of Safety Training: FMCSA regulation 392 requires that drivers be trained prior to performing safety-sensitive functions. An auditor is likely to request this, so best to keep it with the DQ Files.

  • A Skill Performance Evaluation Certificate obtained from a Field Administrator, Division Administrator, or State Director issued in accordance with 391.49 or the Medical Exemption document, issued by a Federal medical program in accordance with Part 391