There are many steps that go into the creation and maintenance of DOT driver qualification files. And if the FMCSA violation data is any indicator, it’s a process that many carriers are struggling with in the course of their operation.
Here are 4 of the most common Driver Qualification violations – and the steps you can take to avoid them.
#1: Unqualified/Physically Unfit Driver
The DOT has certain requirements of CMV drivers that carriers must consider before putting a driver onto the road. These include being at least 21 years old, having the ability to speak and write English, and having the training needed to operate a commercial motor vehicle safely.
Driver’s must also be in good medical health, as determined by a DOT-certified medical examiner.
Avoiding a Violation: Not only is the DOT application a required part of each driver’s file, but it will provide the answers to all of the questions above. During the pre-hire process, and then on a continual basis throughout each driver’s employment, you’ll also want to make sure you have an updated copy of their medical card. They will need to keep this in the vehicle while on the road, and you should also maintain a copy on record in their DOT driver file.
#2: Not Keeping Inquiries into a Driver’s Employment Record in the Driver Qualification File
This is an all-too-common violation – accounting for nearly 10% of all critical violations in 2019. Before a driver is permitted to drive for a new company, the carrier must contact their prior employers and keep records of the information obtained, or their attempts to make contact. All of this information must be securely stored in the driver file at all times.
Avoiding a Violation: All of the information you’ll need to complete this investigation will be found on the driver’s Driver Qualification file – so make sure you’re having every prospective driver fill one out before you begin onboarding. Once you’ve reached out and collected the necessary information, make sure these inquiries are kept in the driver’s file. Because of the sensitive nature of the information, it must be kept in a secure area that is accessible by only those who are involved in the hiring process.
#3: Not Having a Current Medical Certificate on File
It’s critical that you’re checking each driver’s DOT medical card during the pre-hire process. You must also make a copy of this document and keep it in their driver file at your place of business. Each time the driver’s medical card is renewed, you must update the corresponding document on file.
Avoiding a Violation: Have a system in place to track medical card expiration dates. This will ensure that you know when your drivers are due for their DOT physicals so that you can be proactive and get a copy of the updated medical certificate. No driver should be allowed to operate without a current medical examiner certificate, both in the vehicle and on file at the place of employment.
#4: Failing to Maintain a Qualification File for Each Driver
You are responsible for creating and maintaining driver files for each of your drivers – even if they don’t require a Commercial Drivers License to operate. The FMCSA requires that any driver who operates a Commercial Motor Vehicle with a GVW of 10,001+ pounds has a driver qualification file that is maintained regularly throughout their employment.
Avoiding a Violation: Most of the information you will need to create a DOT-certified driver qualification file is collected through the pre-hire process – it’s simply a matter of putting it all together in an organized way where it can be easily accessed and maintained. Tracking expiration dates will be key here as CDLs, medical cards and MVRs will need to be updated regularly.
For many carriers who currently have DQ files in place, the issue isn’t necessarily creating them – it’s keeping them up-to-date. There are several important dates that must be tracked during each driver’s tenure to stay compliant under FMCSA and DOT laws and regulations.
If you need any assistance with your Driver Qualification files, please feel free give us a call at 877-352-1996.