One of the many obligations required of motor carriers is to ensure drivers are qualified to operate the commercial motor vehicle they operate. The purpose of commercial drivers’ qualification is to protect the traveling community which shares the roads with professional drivers.
The Driver Qualification File serves as the foundation of proof of qualification of a driver. To comply with the regulatory requirements of qualifying drivers, it is incumbent on motor carriers to understand the components necessary to serve as evidence of qualification.
Driver Qualification File Requirements
- Application for Employment
- The application must include 3 years verifiable employment history. In addition, drivers with commercial driving experience must provide the last 7 years of commercial vehicle driving history or any driving history if less than the required 7 years. When the driver has no driving experience, it should be clearly noted.
- Motor Vehicle Record
- Records of all states in which the driver has held a license or permit in the previous 3 years.
- Annual review of MVR along with notes.
- Annual Statement of Violations by Driver
- Previous Employer Safety Performance History Inquiry
- Employee’s consent to provide information.
- Alcohol and drug violations.
- Accidents.
- Road Test or Equivalent
- Medical Certificate
- National Registry Verification.
Records Retention
A good business practice is to ensure procedures are in place to verify records are maintained for the length of time required by regulation and jettisoning documents when no longer required unless there is a compelling reason to maintain items longer than required by regulation.
- The file must be maintained for 3 years after employee separation from the firm.
- Documents allowed to be discarded after 3 years:
- Annual statement of violations
- Medical certificates
- National registry verifications
- MVRs except for the first one
File Deficiencies
Transparency and honesty are solid qualities in general. They are also important in the event of a deficiency found in an employee’s file. Notes explaining why the mistake occurred and documentation of corrective action will not correct a violation. However, it has been my experience that they certainly help in an auditor’s understanding of the situation which typically leads to the best of possible outcomes.
Understanding the Environment
Regulations can seem overly burdensome at times. However, it is important to remember the purpose behind their existence; to keep the roads safe for all.
Each of us shares the roads with one another. Motor carriers and professional drivers are obligated to ensure qualified drivers are in control of the more complex vehicles they operate which are surrounded by less experienced drivers using our public roadways.
For more information, see https://www.complianceassuranceservices.com/Services/company-regulations.
Are you considering a self-insured retention? Read this.