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Safety & Compliance Resources

J. J. Keller protects people and the businesses they run. You can trust our expertise across a wide range of subjects relating to labor, transportation, environmental, and worker safety. Our deep knowledge of federal and state agencies is built on a strong foundation of more than 100 editors and consultants and 70+ years of regulatory compliance experience.

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J. J. Keller protects people and the businesses they run. You can trust our expertise across a wide range of subjects relating to labor, transportation, environmental, and worker safety. Our deep knowledge of federal and state agencies is built on a strong foundation of more than 100 editors and consultants and 70+ years of regulatory compliance experience.

Six Key Steps to Qualifying New Drivers

The following steps must be taken when hiring someone to operate a โ€œcommercial motor vehicleโ€ as defined in 49 CFR ยง390.5. State requirements may vary. Note that this list does not cover all the steps normally taken when hiring a driver, but only DOT-regulated elements.

Step 1: Before a hiring decision is made

Notify applicant of his/her rights concerning the Safety Performance History. See 49 CFR ยง391.23(i).

Step 2: Before obtaining a driving record or any similar background report

Have the employee sign any required consent forms, such as those needed to obtain drug/alcohol testing history from previous employers or driving records from licensing authorities. Effective January 6, 2020, make sure drivers applying for a safety-sensitive position have a CDL Drug and Alcohol Clearinghouse account to give you consent for the pre-employment query.

Step 3: Before a new employee drives a CMV for the first time

(Note that many of these steps are typically completed before hire, but the U.S. DOT only requires that they be completed before an individual drives a CMV)

  • Verify that the driver is qualified under 49 CFR ยง391.11 and ยง391.13
  • Obtain a completed driverโ€™s application
  • Ask if the individual failed or refused a pre-employment drug or alcohol test for any company to which he/she applied but did not become employed in the past 2 years
  • Get a copy of the driver's valid medical card, or for CDL/CLP drivers who were medically certified more than 15 days ago, obtain a driving record showing the driver's medical certification status. If applicable, obtain a copy of any medical variance or waiver.
  • Obtain a verified negative drug test result for any CDL driver, or obtain documentation necessary to qualify for the exception from testing*
  • Request a pre-employment query of the CDL Drug and Alcohol Clearinghouse*
  • Perform a road test, or get a copy of the driver's CDL or current road test certificate. NOTE: A road test may be performed before a pre-employment drug test.
  • Obtain records of the driver's on-duty time for the previous 7 days and the time at which the driver last went off duty
  • Provide the new employee with educational materials concerning the companyโ€™s DOT drug/alcohol testing program before any testing is performed and obtain a receipt from the driver*
  • If applicable, get a copy of the Longer Combination Vehicle (LCV) Driver-Training Certificate, or issue one to the driver after training is performed*
  • If applicable, get a copy of the certificate of written training for the transportation of highway route-controlled Class 7 (radioactive) materials
  • CDL-vehicle drivers only - From all prior DOT-regulated employers: If the driver has a DOT drug or alcohol violation, obtain SAP plan information and follow-up testing information if that is not completed.*

Step 4: By the end of the employeeโ€™s first day of work

Have the employee complete at least Section 1 of the Form I-9, Employment Eligibility Verification (required, but outside the DOTโ€™s jurisdiction) by the end of the employeeโ€™s first day of work for pay. The rest of the Form I-9 must be completed within three days of the individual beginning work.

Step 5: Within 30 days of employment:

  • Obtain a driving record from the licensing authorities where the individual was licensed during the past 3 years
  • Obtain the driver's โ€œsafety performance historyโ€ from DOT-regulated employers for the past 3 years, including driver identity verification, recordable accident history
  • For CDL-vehicle drivers only*

Step 6: Within the first year of employment, and at least annually after that:

  • Obtain a driving record (MVR) covering the previous 12 months
  • Perform an annual review and document that review
  • Request an annual limited query of the CDL Drug and Alcohol Clearinghouse

*Applies to those hired to operate a CDL CMV