DOT & ELD Guidance Blog

Common DQ Violations & How to Avoid Them

Focus your efforts on avoiding these common DQ violations.
J.J. Keller Editor Kathy Close

Kathy Close - DOT Editor - J. J. Keller & Associates, Inc.

April 12 , 2019

Driver qualification (DQ) compliance not only results in some of the highest fines levied by the FMCSA, it causes a great deal of concern and confusion for safety professionals. In recent years, non-compliance with DQ regulatory requirements has proven particularly troublesome for carriers.

Some of the most common DQ violations include:

  • Having a valid or current medical certification in the driver’s possession and DQ file
  • Driver reading or speaking the English language
  • Driver possessing a valid license for the commercial motor vehicle (CMV) being operated
  • Having a new hire MVR in the DQ file
  • Having a DQ file maintained for each driver
  • Using a qualified driver

To avoid the potentially detrimental risks that come with noncompliance, focus your efforts on understanding the following DQ requirements:

Onboarding and Safety Performance History

Before your driver operates a CMV, you must ensure the driver’s application is complete, perform a road test, verify medical certification, and complete any necessary investigations and inquiries within 30 days of hire. The road test should be conducted by a competent examiner, last long enough to determine the driver’s skills, reflect normal operations, and document the route used. All files should be secured in a location with controlled access and retained for the length of employment plus 3 years.

Driver Qualification Files

As a starting point, you should use the following guidelines for building and maintaining DQ files:



Driver's Application Duration of employment
Driving Record (MVR) Duration of employment
Safety Performance History Duration of employment
Certificate of Road Test or copy of CDL Duration of employment
Annual MVR and Review Notes 3 years
Medical Card and National Registry Verification 3 years
Annual List of Driver Convictions 3 years


Additional best practices include acknowledging when something is missing from the file and showing good faith effort to comply, using the same requirements for rehires as for new hires, and establishing policies for reexamination in cases of illness or injury.

Ongoing DQ Requirements

You are required to perform an annual inquiry and review of each driver’s record to determine whether that driver meets minimum requirements for safe driving or is disqualified to drive a CMV. Additionally, each driver must furnish a list of all motor vehicle traffic and ordinance violations of which they’ve been convicted. Both required documents should be retained in the driver’s file for 3 years.

Staying Ahead of the Game

Taking a proactive approach to driver qualification can help you stay on top of the requirements and avoid potential acute and critical violations that could negatively impact your CSA scores and overall safety rating, not to mention, your bottom line. Determine if you have the appropriate DQ safety management controls in place with J. J. Keller’s FREE DOT Audit Workbook: Assessing Your Risk in the 7 CSA BASICS.


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