It’s difficult for motor carriers to remain on top of qualification recordkeeping requirements on your truck drivers. Multiple regulatory areas include driver investigation, drug and alcohol testing, MVRs, and more. Additionally, your drivers may operate different classes of vehicles, which impacts their qualification requirements.
To help you stay current, compliance experts J.J. Keller developed a DQ Inventory to help you identify which requirements apply to your drivers. The DQ Inventory covers the following areas:
Initial Driver Qualification Requirements
These documents are required before a driver can operate a commercial motor vehicle:
- Driver Application for Employment
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- Must include all required elements and be signed by the driver.
- Retention: Employment + 3 years
- Road Test Certificate or Commercial Driver’s License (CDL) Exception
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- A motor carrier must conduct a road test unless the driver provides a valid CDL (except for doubles, triples, tankers, or vision exemptions).
- Retention: As long as the driver is employed
- Motor Vehicle Record (MVR) Check
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- Obtain an original MVR from all states where the driver has been licensed in the past 3 years.
- Retention: Employment + 3 years
- Safety Performance History Request (SPHR) & Drug/Alcohol Violation Checks
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- Required for DOT-regulated employers for the past 3 years.
- Must include Drug & Alcohol Clearinghouse verification.
- Retention: At least 3 years from date of hire
Drug & Alcohol Testing Program Compliance
- Drug & Alcohol Policy Receipt
- Must be signed by the driver, confirming receipt of the employer’s drug and alcohol policy.
- Retention: Employment + 2 years
- Pre-Employment Drug Test Results
- Motor carriers must have negative pre-employment drug test results before a driver performs safety-sensitive functions.
- Retention: 1 year from result date
- Full Clearinghouse Query & Driver Consent
- A full query must be performed before hiring a driver, requiring driver consent.
- Retention: Stored in the Clearinghouse
- Failed Pre-Employment Drug Test Reporting
- If a driver failed a pre-employment drug test and was denied employment, the employer must maintain a record.
- Retention: Employment + 3 years
Recurring Driver Qualification Requirements
- Medical Examiner’s Certificate & Variance Documentation
- Must be kept current and included in the driver’s DQ file.
- Retention: 3 years from the exam date
- Annual MVR Review & Compliance
- Carriers must conduct an annual review of the driver’s MVR and document the review process.
- Retention: As long as the driver is employed
- Annual Drug & Alcohol Clearinghouse Query
- A limited query must be conducted at least once per year for each CDL driver.
- Retention: Stored in the Clearinghouse
- Annual Limited Query Consent Form
- Drivers must provide written consent for annual Clearinghouse queries.
- Retention: 3 years from last query
Documents Required for Certain Drivers
- Medical Waiver Documentation (if applicable)
- If a driver has a medical variance, exemption, or waiver, documentation must be included in the DQ file.
- Retention: 3 years from document date
- Longer Combination Vehicle (LCV) Driver Training Certificate
- Required for drivers operating double or triple trailer combinations.
- Retention: Employment + 3 years
- Entry-Level Driver Training (ELDT) Certificate
- Required for drivers who received a CDL less than one year before hiring (ELDT requirements changed in 2022).
- Retention: 3 years from document date
- Multiple-Employer Driver Records (if the driver works for more than one DOT-numbered carrier)
- Carriers must keep a “mini” DQ file including:
- Medical certificate
- Road test form or CDL copy
- Driver’s name, SSN, and license details
- Retention: Employment + 3 years
- Carriers must keep a “mini” DQ file including:
The DQ Inventory checklist ensures motor carriers stay compliant with FMCSA regulations and maintain qualified, safety-compliant drivers in their fleet.
About Western Truck
Western Truck Insurance Services is an insurance brokerage specializing in commercial truck insurance. We know this stuff and want to make sure you do, too. Our clients appreciate our dedication to finding competitive rates and offering unparalleled service beyond excellent insurance options. They also value how our state-of-the-art automation provides lightning-fast truck insurance quotes, customer service, insurance certificates, and coverage changes. Contact us today at (800) 937-8785 to learn more.