Driver Qualification & Hiring

Hiring the right drivers and ensuring they also comply with driver qualification regulations is critical for the successful—and safe—operation of any company.

Quality hires are the first step. Making sure they're qualified in accordance with Parts 383 and 391 of the FMCSRs is the second. (View the Driver Hiring Checklist.) Maintaining driver qualification then follows.

Whether you need to hire someone new, rehire a driver, or maintain the driver qualification file of an experienced, veteran driver, J. J. Keller can help with a wide variety of information, including:

  • Requirements for DQ files
  • Best practices for hiring
  • Dealing with rehires, owner-operators, temp drivers and others
  • Frequently asked questions
  • Pre-employment screening programs

Ensuring compliance with DQ requirements starts with good hiring practices and continues with ongoing maintenance of driver qualification files.

Shop Driver Qualification & Hiring Solutions

Stay compliant with the Safety Performance History recordkeeping requirements by using our wide assortment of driver qualification packets.

With J. J. Keller, setting up driver files is as easy as 1, 2, or 3.

As 1 File:

All DQ, alcohol and drug testing, and safety performance history are managed and filed in one area.

As 2 Files:

DQ is managed and filed in one area, while A & D testing and safety performance history are managed and filed by another area.

As 3 Files:

DQ, alcohol and drug testing, and safety performance history are all managed and filed in different areas.

Topics — What You Need to Know

Section 391.51 of the Federal Motor Carrier Safety Regulations details what a driver qualification file must contain.

The following documents are to be included for each regularly employed driver:

  1. Driver application for employment
  2. Motor vehicle record (MVR) from state(s), obtained at time of hire
  3. Road test form and certificate, or license or certificate accepted in lieu of road test
  4. Medical exam certificate or (for CDL/CLP drivers) MVR showing current medical certification status
  5. Verification that the medical examiner was listed on the National Registry of Certified Medical Examiners
  6. Annual motor vehicle record
  7. Annual review of driving record
  8. Annual list of violations

The following documents are also required, but are not applicable to all drivers:

  1. Documentation of any medical variance, exemption, or waiver
  2. Longer Combination Vehicle (LCV) Driver-Training Certificate
  3. Entry-level driver training certificate

Depending on the state you are operating in, additional items may be required.

Section 391.53 details additional information related to a driver’s three-year safety performance history, to be kept in a secure location with controlled access (these may be combined with the DQ file or kept separate):

  1. Driver’s written authorization to seek information about drug/alcohol testing history
  2. Response(s) received from previous employer(s) or documentation of efforts to obtain the information.

Rehires

When a driver leaves a company and then returns, whether after one week or one year, there may be some items in his/her original Driver Qualification (DQ) or Driver Investigation History (DIH) file that can be reused, even though the DOT considers him/her to be a new hire.

The following items can be recycled from old files:

  1. Road test/certificate - if completed less than three years ago (see §391.33(a)(2))
  2. Medical certificate (DOT Medical Card) - if still valid
  3. Information obtained from previous employers - if the information pertains to the three years that precede the rehire date and the inquiries sent to previous employers were in compliance with the current version of §391.23.

Items that need to be re-created:

  1. A new truck driver application needs to be completed using the rehire date as the point of reference.
  2. A motor vehicle report (MVR) needs to be requested to coincide with the rehire date.
  3. Previous employer checks must be requested on any employment during the absence, and existing previous-employer investigations that were not done in compliance with the rules in §391.23 must be re-done for all DOT-regulated employers for the past 3 years from the rehire date.

Documents from the original files that are not reused must be retained in the same manner as if he/she never returned. Other items from first employment period are retained in the original file same as above, but can be purged three years from document execution dates.

Owner-Operator’s compliance with the federal safety regulations

With owner-operators, there are two potential situations that can be encountered:

  1. An owner-operator is leased onto a motor carrier. The freight is hauled under the carrier’s authority, the truck displays the carrier’s U.S. DOT number, and the freight is covered by the carrier’s insurance. In this case, the carrier is responsible for the safe operation of that vehicle, including the owner-operator’s compliance with the federal safety regulations. This includes keeping a proper DQ file, ensuring hours of service compliance, drug and alcohol testing, vehicle maintenance, etc.
  2. An owner-operator is a motor carrier. The freight is hauled under the owner-operator’s authority, the truck displays the owner-operator’s U.S. DOT number, and the freight is covered by the owner-operator’s insurance. In this case, the owner-operator is the motor carrier. The carrier/owner-operator must ensure that all the federal safety requirements are followed.

Remember, the motor carrier is always responsible for compliance with the federal safety regulations. The real question is: who is the motor carrier?

Temporary Drivers

The occasional, seasonal or intermittent employee would be someone who is on your payroll to drive during those times when you need extra help.

Even though they are not permanent or full-time, they still need to be fully qualified in accordance to Part 391 before they can get behind the wheel of your CMV. If you are subject to Part 382, these employees need to be a part of your DOT random alcohol and drug testing program. This means the whole gamut: pre-employment drug screens, DOT drug and alcohol background requirements, issuance of educational materials and your company policy, and placement in your random testing pool.

Many carriers keep these employees "active" rather than consider it a termination of employments. They are considered to be on an extended leave of absence or layoff, and this avoids having to wait on a pre-employment drug screen or create new documents as a rehire in the file.

The hiring process is a key element in creating a successful fleet. Establishing hiring standards provides you with a baseline of what you find acceptable. Not having documented hiring standards implies to anyone reviewing your operation (insurance underwriters, investigators, auditors, attorneys, etc.) that you have no baseline; you will hire anyone.

Many carriers concentrate their hiring standards on the driving requirements. Typical standards include limits on the number of accidents, suspensions, and citations.

As well as the driving requirements, carriers also set hiring standards pertaining to previous employment. How many previous employers an applicant has had combined with the reasons for leaving the previous employers are employment issues typically considered when determining hiring standards.

View Driver Hiring Checklist and 10 Basic Rules of Driver Hiring for more information.

Documentation

You must also keep in mind that in addition to the usual employment procedures required by federal and state laws, the Department of Transportation (DOT) has its own set of hiring requirements.

Documentation required by DOT

Drug & Alcohol Documentation (if subject)

Other, Non-DOT Hiring Documentation

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