How to Manage Driver File Recordkeeping Requirements

Drivers are critical to your business as a Department of Transportation-regulated motor carrier—they, after all, literally keep your fleet running.

In line with this, the Department of Transportation wants to ensure that you have the safest, most qualified drivers taking to the roads with your freight. So federal law requires that you keep Driver Qualification Files (DQFs) on all of your drivers.

Here’s what you need to know to maintain compliance.

DQF Overview

The Federal Motor Carrier Safety Administration’s (FMCSA) regulation 391 outlines the minimum qualifications for commercial motor vehicle drivers. It helps to ensure that all federally-regulated drivers are qualified to be on the road based on their physical health, professional experience, and motor vehicle record (MVR).

All businesses regulated by the FMCSA must maintain records for their safety, compliance and insurance programs. Furthermore, these files must be ready to be turned over to the agency, when requested, within 48 hours.

Required files have to be organized into two categories: DQFs and Safety Performance History.

DQFs must be kept on all drivers operating CMVs in interstate commerce and that weigh 10,001 or more pounds; transport hazardous materials; or carry 10 or more passengers.

A driver’s DQF must include the following:

• Application for employment (To be maintained throughout employment, plus 3 years).
• MVR/Annual review of driving record (The MVR must be maintained throughout employment, plus 3 years; the annual review for 3 years).
• Annual list of violations (To be maintained for 3 years).
• Road test certificate (To be maintained throughout employment, plus 3 years).
• Medical examination certificate, along with any exemptions/waivers (These must be updated at least every 24 months, include any variances, and maintained for 3 years).
• Skill performance evaluation certificate application (For drivers with missing or impaired limbs and valid for 2 years).

Additionally, the medical examiner’s National Registry verification must be compiled with all of the above, and maintained throughout employment, and for 3 years thereafter.

The Safety Performance History file, meanwhile, must include:

• Record of previous employers that have been contacted.
• The driver’s written authorization to release safety-sensitive information.

Critically, Safety Performance History files have to be kept in a secure location (under lock and key or areas with limited access) to protect sensitive personal information.

All DQF and Safety Performance History files must be kept in digital format, must be legible, and must be maintained for the minimum amounts of time outlined above.

The Benefits of Digital

It’s critical to note that 20% of FMCSA violations in 2020 were due to incomplete or outdated driver files. This indicates that many carriers simply aren’t aware of, or neglect, their DQF requirements.

But to operate compliantly, this simply isn’t an option. Particularly with the FMCSA requiring digital files with 48-hour turnarounds, you don’t want to be stuck unprepared or having to scramble to upload paper files to a digital format. Paper files may not be complete, and there is greater risk for clerical errors.

Failing audits can result in significant infractions, including:

• Fines of up to $5,000 per violation.
• DOT # deactivation.
• Out-of-service orders.
• Corrective action plans.

One way to stay apprised, and compliant, is to switch to a digital solution. This can help you to be offsite audit ready—as offsite audits are up 400%—while also providing greater security and organization, ultimately saving you valuable time and resources.

Foley’s portal can help automate your processes by converting existing driver files, then managing those files in a secure, online environment with limited access. We track due dates for medical certificates and CDL renewals—as expired CDLs are one of the top annual FMCSA infractions—and alert you when they are approaching. We also perform annual driving records, violation reviews, and comprehensive monitoring that immediately alerts you when there is any change in a driver’s MVR.

Remember, not all digital solutions are created equal. To learn more about Foley’s compliance programs, contact us today!