Driver Qualification Files: Key Facts for Business Owners
What is a driver qualification file?
A driver qualification (DQ) file is a set of documents employers must maintain for each employee who drives a commercial vehicle. DQ files are required by the Federal Motor Carrier Safety Administration (FMCSA). They are designed to ensure businesses only hire safe, qualified drivers. The files include data on each employee’s driving history.
For the most up-to-date, comprehensive resource on these federal guidelines get the eCFR data here.
Does my company need driver qualification files?
If you own any commercial vehicles (including certain pickup trucks), then yes, you need to keep DQ files. Keep in mind, a “commercial vehicle” doesn’t have to be an eighteen-wheeler or a giant piece of construction equipment. Any truck or van weighing more than 10,000 pounds is considered a commercial vehicle. Most landscapers, arborists, roofers, etc. own at least one qualifying vehicle (see full definition below). This means most companies need to keep DQ files.
Does my company need driver qualification files even if I only employ one or two people?
If either of them is driving your commercial vehicle(s), then yes. You need a DQ file for each one—including yourself as the business owner.
Wait, what? I need a DQ file for myself?
Yes, you do.
What if my company is strictly local (no out of state work)—do we still need DQ files?
Yes, you still need them. It does not matter if you are crossing state lines or only driving within Massachusetts.
What kind of truck is considered a “commercial vehicle”?
Basically, this means any vehicle with a Gross Vehicle Weight rating or Combined Gross Vehicle Weight Rating in excess of 10,000 pounds. Or, any vehicle with a commercial license plate. These vehicles are also required to display a USDOT Number. Here’s more info about US DOT numbers on trucks, including some new-ish rule (as of 2018) for Massachusetts companies.
Which records must be included in a driver qualification file?
There are roughly 9 items that must be included in each DQ file (with some exceptions), including the driver’s signed application for employment. For a detailed list of all the required documents, download our Guide to Driver Qualification Files. You can also review the FMCSA checklist.
Broadly speaking, employers need to gather and maintain a driver’s employment application, driving history files, medical exams, and records of all required training. Some of these files are collected only once. Others need to be updated every one or two years.
Where should I keep my drivers’ DQ files?
Ideally, these files should be stored in a locked cabinet.
What is the full definition of a commercial vehicle?
The FMCSA uses the following criteria to define a commercial vehicle. If any of these apply to your truck(s), then it is commercial:
- Has a gross vehicle weight rating or gross combination weight rating, or gross vehicle weight or gross combination weight, of 4,536 kg (10,001 pounds) or more, whichever is greater; or
- Is designed or used to transport more than 8 passengers (including the driver) for compensation; or
- Is designed or usedto transport more than 15 passengers, including the driver, and is not used to transport passengers for compensation; or
- Is used in transporting material found by the Secretary of Transportation to be hazardous under 49 U.S.C. 5103 and transported in a quantity requiring placarding under regulations prescribed by the Secretary under 49 CFR, subtitle B, chapter I, subchapter C
When are DQ files checked or requested? Who audits them and how often?
Files may be randomly checked or audited by an authorized commercial vehicle enforcement agency. In the Bay State, the job falls mainly to the “Truck Team,” formally known as the Massachusetts State Police, Commercial Vehicle Enforcement Section.
The Massachusetts Truck Team routinely performs roadside inspection of commercial vehicles, investigates commercial crashes, and practices local commercial vehicle law enforcement. In the course of performing any of these duties, they may seek a driver’s DQ file.
What’s the penalty for not having a DQ file?
Fines and penalties vary, depending on how many are missing and the severity of the review that is being conducted.
I still have questions. Who should I contact for specific answers?
Here are some links to FMCSA resources on this topic. The FMCSA answers most questions, but we understand their explanations aren’t exactly easy reading. If you’re still not sure how to compile the required files for your drivers, feel free to call our commercial auto insurance team: 508.339.2951.
We also work in tandem with Joe Mokrisky, a compliance and safety consultant for companies with sizeable fleets. Joe is a member of the National Safety Council; he holds leadership roles within the Transportation Safety Division including Secretary of the TSD and Chairman of the Commercial Fleet and Motor Vehicle Section. For questions about commercial vehicle compliance or driver training for your fleet of CMVs, you can contact Joe directly.