We have been getting tons of questions on drive files so we
thought we would take a moment and explain exactly what you need and how long
you need to keep it. The federal
government did a great job when they wrote the regulations for Commercial Motor
Vehicles (CMV’s). We are going to make it super clear.
Here’s what you need in every driver file:
ü
Driver application 391.21
o
See the notes below
ü
Annual Driver Review 391.25(a)
o
Must be completed within first year
o
Completed annually
o
Keep the original
o
Last 3 years
ü
Certificate of Violations
o
Must be completed within first year
o
Completed annually
o
Keep the original
o
Last 3 years
ü
Driver License
o
Keep original
o
Last 3 years
ü
Medical Card
o
The National registry number needs to be
verified and documented
o
Keep original
o
Last 3 years
ü
Motor Vehicle Report
o
Must be pulled within 30 days of employment
o
Pulled Annually
o
Also must be pulled within 15 days of medical
card being renewed
o
Keep original
o
Last 3 years
ü
Previous Employment verification (last 3 years)
o
Best practice is to pull for every employer for
last 3 years even if they marked non DOT position
ü
Road Test
o
CDL can be used as road test except when
§
Required when employee will be operating tankers
§
Required when employee will be operating doubles
or triples
o
All NON CDL drivers must have a road test
ü
Entry Level Driver Training
o
Required for all drivers that come to your
company with no experience
o
Best practice is to cover with all employees
ü Drug
and Alcohol clearing house results effective 1/6/2020
o
Must be pulled prior to allowing driver to
operate CDL vehicle
o
Pulled annually
o
Keep original
o
Keep last 3 years
There you go that’s all you need right? Not quite it’s a bit more complicated than
that, but don’t stress we aren’t done yet.
The driver application needs to contain:
ü
Name and address of employer
ü
Date the application was completed
ü
Applicant name
ü
Applicant address for the past 3 years
ü
Applicant Date of Birth
ü
Applicant social security number
ü
Applicant driver license number
ü
Applicant driver license state
ü
Applicant driver license expiration
ü
Applicant previous experience
ü
Applicant accidents for the past 3 years
ü
Applicant traffic citations for the past 3 years
ü
Applicant driver license requirements page
ü
Most applications contain a fair credit
reporting act
ü
Previous employment (10 years CDL applicants) (3
years non CDL applicants)
o
Each previous employer must include
§
Dates of employment (Month and Year)
§
Company name
§
Address (City and State)
§
Reason for leaving
§
Was this a DOT sensitive position
§
Was the employee subject to FMCSR’s
For all documents, it is best to keep the original and the
past 3 years. We suggest only keeping
the necessary documents in the driver qualification file. If you keep, more you might think that you
are doing what is best and having more information is better. During an audit or lawsuit, they can analyze
your company on the information provided.
Let’s say that you messed up and didn’t pull an MVR soon enough 5 years
ago and you give that to the auditor, they can issue a fine based on the documentation
you give them. We look it as you have to
give the gun to the auditor when the walk through the door, you don’t have to
give them the ammunition though. Make
them look for it.
There are many different ways that you can store your Driver
Qualification (DQ) files. We endorse keeping
them digitally. They are easier to
navigate through and you can easily audit your files. The other suggestion that we have for all
companies no matter what size they are is to have your documents completed
digitally. This eliminates many issues
with not being able to read someone’s hand writing. This also makes it extremely easy on the
auditor because they don’t have to struggle to find all of the
information. If you have questions about
fallible forms or would like us to look at your DOT processes please reach out
to us. We are here to help make your
life easier.
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