If we've said it once, we've said it a thousand times: DOT driver qualification files can be difficult to create and maintain, especially as your business and driver count grows. It’s a process that many companies struggle to execute according to FMCSA regulations.
From using a physically unqualified driver to not keeping inquiries into a driver’s employment record in the DOT driver qualification file, several small mistakes often lead to big fines for companies with DOT-regulated drivers.
Here are a few of the most common driver qualification file mistakes and the steps you can take to avoid them.
#1. Using an Unqualified/Physically Unqualified Driver
The DOT has certain requirements for commercial vehicle drivers that employers must consider before putting them behind the wheel. These requirements include being at least 21 years old, able to speak and write English, and having the training needed to operate a commercial motor vehicle safely.
Drivers must also be in good medical health, as determined by a DOT medical examiner during a DOT physical exam.
✅ How to avoid this violation: Not only is the DOT job application a required part of each driver qualification file, but it will answer all the questions above. During the pre-hire process and then on an ongoing basis throughout each driver’s employment, you should also have an updated copy of their DOT medical card. In addition to having this in their possession while on the road, you should have 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 a common violation — accounting for 2,304 DOT violations in 2023. Before a driver is permitted to drive for a new company, the employer must contact the driver's prior employers regarding violations other than those found in the FMCSA Drug and Alcohol Clearinghouse, and keep records of either their attempts to make contact or the information found through this process. All of this information must be securely stored in the driver file as part of their Safety Performance History.
✅ How to avoid this violation: All of the information you’ll need to complete this investigation will be found on the driver’s DOT application, so make sure you’re having every prospective driver complete one before you begin onboarding. Once you’ve made the phone calls and collected the necessary information, make sure these employer inquiries are kept in the DOT driver file. Because of the sensitive nature of the information, it must be kept in a file that is accessible by only those who are involved in the hiring process.
#3: Not Having a Current DOT Medical Card in the Driver Qualification File
As we mentioned earlier, you must check each driver’s DOT medical card during the pre-hire process. But once that’s done, it’s also important that you make a copy of this document and keep it in their DOT driver file, too. This document must then be updated each time the driver’s medical card is renewed.
✅ How to avoid this violation: Having a system to track medical card expiration dates will ensure that you know when your drivers are due for their DOT physicals so that you can get a copy of the updated certificate as soon as it’s available. Any driver who doesn’t have a current medical card should not drive or perform safety-sensitive duties until it has been updated.
#4: Failing to Maintain a Driver Qualification File for Each Driver
If you hire and manage drivers, then you are responsible for creating and maintaining driver files for each of them — even if they don’t require a CDL. The FMCSA requires any driver who operates a CMV with a gross vehicle weight of 10,001 pounds or more to have a driver qualification file maintained throughout their employment.
✅ How to avoid this violation: Most of the information you need to create a DOT driver qualification file is collected through the pre-hire process — it’s simply a matter of organizing the files where they can be easily accessed and maintained throughout the driver’s employment. Tracking expiration dates is key, as CDLs, medical cards, and motor vehicle reports will need to be updated periodically.
For many employers who currently keep updated DOT driver files, the issue isn’t creating them — it’s keeping them updated on an ongoing basis. From monitoring DOT medical card expiration dates to running and filing away each driver’s annual motor vehicle report, there are a variety of dates that must be tracked during each driver’s employment to stay compliant.
Stay Violation-Free with DOT Driver Qualification File Software
At Foley, our driver file program manages all of these expiration dates for you and sends alerts when specific driver records need to be updated through our exclusive Dash Platform. All driver files are filed securely in a digital format, and they are available to view or download whenever you need them.
To learn more about our DOT driver file creation and management program, click here or give us a call at (860) 815-0764.
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