DQ Files- An Easy Breakdown
The Federal Motor Carrier Safety Administration (FMCSA) considers the driver hiring process and ongoing checks of your drivers to be a critical element in building and maintaining a safe carrier operation. Managing your driver requirements can be challenging and unfortunately, they can cause a lot of confusion, hefty fines per violation, and penalties for any size trucking organization.
Here are some key elements to help give you a little more piece of mind.
What is it?
A Driver Qualification File, also known as a DQ File, or DQF is a set of documents required by the FMSCA for all drivers as a record keeping document/”file” to be available to prove your drivers are safe enough AND healthy enough to drive a Commercial Motor Vehicle (CMV). You must always maintain these files and must have all the appropriate files in place to pass a safety audit.
Note– If you’re a new authority, you will be audited within your first year as part of your New Entrant Safety Assurance Program. A completed Driver Qualification File is one of the most tedious portions of the new entrant safety audit. So, it pays dividends to get things organized correctly upfront and once they are, keep them maintained that way.
Who Needs One?
A driver qualification file is required for anyone who operates a CMV as defined in 49 CFR 390.5. Even if that person only drove a vehicle one time, they are required to have a file. This includes vehicles that weigh or are rated at 10,001 pounds or more, are placarded for hazardous materials, or are designed or used to transport multiple (at least 9 or more) passengers. *Note that state requirements may vary for drivers who stay within a single state and do not get involved in interstate commerce.
Don’t forget if you are an owner operator, these requirements apply to you as well because are considered an employer and employee.
It is also important to note that if the above requirements are applicable to the driver, whether or not they are a CDL holder, they are still required to have a DQ file in place.
What should you include?
-DOT Employment Application- This is an easy one for most companies, however don’t forget as an owner-operator, as stated above, the FMCSA considers you an employee and employer so all the Driver Qualification documentation (including an employment application) must be completed.
- Make sure you include- Three years (or more-see below) of employment history. There cannot be any gaps in time and you must include any time spent unemployed, as a student or incarcerated. It is important to note, that if an applicant is applying for a job operating a vehicle with a GVWR/GCWR of 26,000 pounds or more, they must list 10 years of employment history.
- The driver must include the extent and nature of their experience operating any type of motor vehicle.
- Any and all moving violations received as well as any and all accidents over the previous three years. If no violations were received, they must indicate such.
- The applicant must indicate any circumstances that resulted in a denial, revocation or suspension of any license to operate a motor vehicle. If no none of those scenarios occurred, they indicate such.
-Medical Certification- This ensures the driver is physically qualified to operate a CMV.
The employer must obtain a copy of the applicant’s current valid medical certification. Drivers are required to undergo a DOT medical evaluation at least once every 24 months. It is the employer’s responsibility to keep track of certification expiration dates to ensure that drivers are consistently physically qualified to operate CMVs.
-Commercial Driver’s License (CDL) or Road Test Certification-
A copy of the applicant’s current and valid driver’s license must be obtained. If the applicant holds a Commercial Driver’s License (CDL), a copy of that will suffice. If no CDL is required, employers must retain evidence that the driver successfully completed a road test in the type of vehicle being operated. It is the employer’s responsibility to keep track of license expiration dates to ensure that drivers are consistently qualified to operate CMVs.
-Safety Performance History Investigation-
This investigation must be run on an applicant for the previous three years for all DOT- regulated positions the driver may have held, and must contain the following:
- a) Written authorization from the applicant allowing the investigation to be conducted.
- b) Responses from any DOT-regulated employers. If previous employers do not respond to the inquiry, documentation must be included that outlines what attempts were made to obtain the information.
- c) If the driver did not hold any DOT-regulated positions, documentation indicating such.
-MVRs (Motor Vehicle Reports) also known as “driving records”-
- a) The Initial MVRs- The MVR must be run on the driver for the previous three years in all states the applicant held a license. Remember, this must be kept the entire them the driver is employed as well as three years following.
- b) Annual MVRs- Pulling and placing this report in the DQF is a critical part of the Driver Qualification File. You must run these at least every 12months. Also, it is important to note for drivers who hold a commercial driver’s license, the motor carrier must obtain a new MVR) within 15 days after each new medical exam and place that in the DQ file as proof of medical certification.
-Annual Review of Driving Record and List of Violations-
Along with the annual MVRs, employers must require drivers to submit a list of any moving violations they received over the previous 12 months. If no violations occurred, you must document that the employee has indicated such. After reviewing the MVR and List of Violations, the employer must maintain documentation of this driving record review.
And don’t forget about the drug and alcohol results. Those results must also be included in a DQ File.
This stuff can be a pain, but it doesn’t have to be
We get it, compliance is tough and is easy to overlook because you’re busy running other parts of your business, however when you’re not in compliance things can go from a nuisance to worse. Filing inaccuracies, manual error, and unnecessary time-consuming record keeping practices are just the beginning. (See our blog about digital DQ Files) Beyond that, you risk incurring violations, fines or even worse costly litigation that can negatively impact your operations in the short-term or worse.
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