Guides / Driver qualification files
The driver qualification file checklist
Every motor carrier must keep a driver qualification (DQ) file for each driver it employs. When FMCSA audits a carrier, DQ files are one of the first things an investigator asks for, and missing or expired documents are among the most common findings. This checklist covers what belongs in the file under 49 CFR Part 391.
What goes in the file
| Document | Rule | When |
|---|---|---|
| Driver's employment application | 391.21 | At hire |
| Driving record (MVR) from every state where the driver held a license in the past 3 years | 391.23(a)(1) | Within 30 days of hire |
| Safety performance history from DOT-regulated employers in the past 3 years, including drug and alcohol history | 391.23(a)(2) | Within 30 days of hire |
| Road test certificate, or an accepted equivalent such as a valid CDL | 391.31, 391.33 | Before driving |
| Medical certification. For a CDL holder: the driving record from the current licensing state showing current medical certification status (a paper card alone is not enough). For a driver without a CDL: the medical examiner's certificate. In both cases, a note that the examiner is listed on FMCSA's National Registry. | 391.43, 391.51(b) | At hire and every time the certification renews (at most every 2 years) |
| Annual review of the driver's record, with a new MVR | 391.25 | At least every 12 months |
The Clearinghouse queries
Carriers employing CDL drivers must also query FMCSA's Drug and Alcohol Clearinghouse: a full query before a driver first performs safety-sensitive work, and at least a limited query of every driver once a year. Keep a record of each query. (49 CFR 382.701)
How long to keep it
Keep the DQ file for as long as the driver works for you and for three years after. Some time-limited documents, such as old MVRs, annual reviews and medical certificates, may be removed three years after their date. (49 CFR 391.51(c) and (d))
Where files fail an audit
- Expired medical certification, a CDL driver's file holding only the paper card instead of the state record showing medical status, or no record that the examiner was checked against the National Registry.
- A missed annual MVR review, often for long-tenured drivers nobody thinks to check.
- Previous employer inquiries that were never sent, or sent with no record of the attempt.
- A driver who started driving before the file was complete.