MARCH 9, 2019 – Are you sure your driver files are compliant?
To maintain files that are compliant with Regulation Part 391, there are a few key items you must track and update for the duration of each driver’s employment:
- Medical Certificates: All drivers must have a DOT medical evaluation at least once every 24 months (or as often as the medical examiner deems necessary) to ensure they are physically able to drive a commercial motor vehicle. Once this physical is complete, the updated medical certificate must be kept in the Driver Qualification File.
- License Expiration Dates: In order to legally operate a motor vehicle, drivers must have a valid license and all required endorsement and/or classes must be active. How long a CDL is valid for will depend on where it was issued, with each state having its own licensing laws. In Connecticut, for example, CDLs must be renewed every 4 years. In Ohio, CDLs are renewed every 8 years.
- Annual Driving Records: You must obtain an updated Motor Vehicle Report (MVR) for each driver annually to ensure they are qualified to drive a commercial motor vehicle. This annual MVR must be placed in the Driver Qualification File along with a note showing the name of the person who performed the review and the date it occurred.
- Annual Review of Driving Violations: Each year, drivers are required to submit an annual list of moving violations to you. This list should include all violations (with the exception of parking) that occurred in the past 12 months. If there were no violations that occurred in this time period, the driver must certify that no violations exist. Once this process is complete, the written documentation must be kept on record with the updated MVR in the Driver Qualification File.
The Cost of Getting it Wrong
Although many of the above tasks may seem basic, they are some of the most common driver and carrier violations. In 2017, over 70,000 drivers were cited for not having a valid medical certificate. According to information in the FMCSA database, a single violation for a missing, altered or falsified medical certificate often exceeds $2,000. Similar fines were issued for drivers caught operating a commercial motor vehicle without a valid CDL – another top violation that results not only in hefty fines, but out-of-service orders.
Reducing Risk Through Automation
The more drivers you employ, the more time and resources it consumes to manage the above tasks (as well as your other compliance activities). In an effort to streamline these processes, and ensure that the business is always audit ready, many carriers are choosing to work with a third-party compliance partner to automate these tasks. In the Foley Portal, for example, we’ll set up each driver with a fully-compliant file and will then keep track of important expiration dates and alerts on an ongoing basis so that you always know when a DOT physical or CDL renewal is due. We’ll also automatically run a Motor Vehicle Report to ensure compliance with the annual review process.
As DOT off-site audits become more common, these electronic driver files have another benefit: they can be immediately downloaded and sent to the DOT officer upon request.
To learn more about the Foley Portal, and how it helps employers create and maintain compliant driver files, click here or call (860) 815-0764.
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