Understanding Driver Qualification: Common Questions Answered

Did You Know?

Maintaining compliance with driver qualification (DQ) requirements is crucial in commercial driving. However, did you know that not all records need to be physically stored? Some requirements are more flexible than they appear!

Let’s dive into some of the most commonly asked DQ file questions.

1. Who Needs a DQ File?

Any driver operating a commercial motor vehicle (CMV) that meets certain criteria must maintain a Driver Qualification (DQ) file. This includes full-time, part-time, and temporary CMV drivers.

A DQ file is required for drivers operating:

• A vehicle weighing 10,001 pounds or more, including both CDL and non-CDL vehicles.
  • CDL drivers: Operating vehicles over 26,001 pounds.
  • Non-CDL drivers: Operating vehicles between 10,001 and 26,000 pounds.
• A vehicle designed to transport more than 15 passengers, including the driver.
• A vehicle transporting hazardous materials in quantities requiring placards under federal hazardous materials regulations (49 CFR § 390.5).

2. Who Can Administer a Road Test?

A qualified and licensed individual can administer the road test. The test should assess the driver’s real-world driving abilities to ensure they can operate a commercial vehicle safely.

3. What’s Required in a DQ File, and How Long Should You Keep It?

A DQ file must contain a variety of records to ensure compliance including the driver’s application, driving history, medical certification, and proof of road test completion. Records must be kept for at least three years after the driver’s employment ends, though some documents may need to be kept longer depending on the regulation. Here is a list of what should be included: 

• Driver’s application
• Pre-employment questionnaire (if not included in the application)
• Initial MVR (Motor Vehicle Record)
• Certificate of road test (not required if the driver took a road test to obtain their CDL)
• MVR used for annual review
• Annual review documentation
• Medication documentation,if applicable:
  • Skill Performance Evaluation (SPE) certificate or medical exemption document (for drivers with medical exemptions)
  • Medical card and National Registry Note (until further notice)
• Drug testing results (can be stored securely in the DQ file or in a separate file)

Basic Retention Guidelines include: 

• DQ files must be kept for the duration of the driver’s employment and for 3 years thereafter.
• The following documents may be removed after 36 months.
  • MVRs associated with the annual review
  • Annual review of the MVR
  • Medical examiner’s certificate
  • National Registry Note
  • MVR associated with the medical card
• Drug Testing records retention:
  • Negative test results – 1 year
  • Positive test results – 5 years

4. Do We Need a DQ File for an Owner-Operator?

Yes, owner-operators are also required to maintain DQ files. Even if they aren’t employed by a company, they must comply with FMCSA regulations and keep necessary qualifications and medical records.

5. Can We Store DQ Files Electronically? And Can We Destroy the Original?

Yes, you can scan and store DQ files electronically and purge the originals. However, during an audit, you may be asked to print copies, so make sure the scanned documents are as clear as the originals before destroying them.

6. Can We Use E-Signatures on DQ Paperwork?

FMCSA allows e-signatures if they meet Section 390.5 requirements, which ensures the signature clearly identifies the person and shows consent. E-signatures can be created with a mouse, stylus, or touchscreen. While usernames and passwords can substitute for signatures on most forms, a script e-signature is needed for safety performance history inquiries to demonstrate written consent.

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There are many more questions regarding DQ files, but this gives you a solid start! If you have any compliance-related questions or concerns, we’re here to help. Schedule a demo today or call us at (816) 323-6196.