In the Know: Driver qualification

In the Know is a monthly partnership between LP Gas and Propane Resources. This month, Shawn Treat outlines what information propane company owners need to track for driver qualification.

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QUESTION: What are the requirements related to driver qualification files? 

ANSWER: Every commercial motor vehicle driver must have a complete and accurate driver qualification (DQ) file on record with their employer.

Your company is responsible for creating and maintaining a DQ file for each driver. The file consists of several individual documents. The first step in creating and maintaining a DQ file for each of your drivers is to understand the Department of Transportation (DOT) requirements. These requirements are outlined in Part 391 of the Federal Motor Carrier Safety Regulations (FMCSRs) and cover various aspects, such as driver qualifications, medical fitness, driving history and employment records.

What forms and information should you keep in the DQ file? Here’s a checklist:

• Your driver’s employment application
• A medical examiner’s certificate (or legible copy)
• Document the verification of the medical examiner who performed the examination is listed on the national registry for all CDL drivers.
• CDL holders can use the copy of their medical card for 15 days as proof; after 15 days, there must be a new motor vehicle record showing the current medical certification.
• Copy of the driver’s license/CDL
• Motor vehicle records from the state agency
• Copy of the annual motor vehicle record
• Copy of the annual review of the driving record
• Inquiry to previous employers for safety performance history
• Keep documentation for all attempts to contact your driver’s previous employer.
• Pre-employment drug and alcohol testing results
• Written authorization from the driver to request information regarding their controlled substances and alcohol history
• Drug and alcohol clearinghouse
• Drug and alcohol testing policy
• Road test certificate/results
• I-9 verification proof of citizenship documentation

Driver qualification files

There are third-party companies to assist you in maintaining accurate DQ files. Another option is to keep paper files that must be accessible and up to date if you intend to pass a new entrant audit or in the event there is a compliance investigation. Once you have gathered the necessary documents, organize them systematically within each driver’s file. Do not commingle your documents. Build a master DQ file for each driver with subfiles for each document within the master. Ensure all documents are complete, within date and compliant with DOT regulations. It is essential to conduct periodic internal audits of DQ files to identify any discrepancies or expiring certifications that need attention and ensure compliance with DOT regulations and your company policies.

Medical certifications

One crucial aspect of maintaining DQ files is staying current with driver medical certifications. Commercial drivers must undergo regular medical examinations conducted by certified medical examiners. Monitor the expiration dates of medical certificates and schedule examinations in advance to prevent lapses in certification.

Monitor driving records

Annually monitor the driving records of all commercial drivers in your fleet. Any violations or incidents must be promptly addressed and documented in the driver’s DQ file. If your employee’s driving record reflects patterns of unsafe behavior, take appropriate corrective action.

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Shawn Treat is director of operations and safety at Propane Resources. He can be reached at shawn@propaneresources.com or 417-631-8595.

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