Common DQ Violations & How to Avoid Them

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 found in compliance reviews include:

• Not having current proof of medical certification in the DQ file
• An incomplete or missing driver employment application
• Allowing a driver to drive with suspended/revoked/etc. CDL
• Not having a new hire and annual MVRs in the DQ file
• Failing to maintain a driver qualification file on each driver
• Using an unqualified driver (prohibited status due to a positive test or expired medical certification)

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

Before your driver operates a CMV, you must ensure the driver’s application is complete, perform a road test, verify medical certification and that the certified medical examiner is on the National Registry, and complete a review of MVRs and prior DOT-regulated employer investigations in the prior three years 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 properly secured and retained for the length of employment plus 3 years.

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

Additional best practices include documenting 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 maintaining drivers' medical and licensing qualifications.

You are required to perform an annual inquiry and review of each driver’s MVR to determine whether that driver meets minimum requirements for safe driving or is disqualified to drive a CMV. The MVRs and annual review documentation should be retained in the driver’s file for 3 years. Carriers should also verify that the drivers still meet their hiring criteria which may be above regulatory and licensing minimums.

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.