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How to Maintain Compliant Driver Files
3 mins read

Note: This article is an excerpt from our ebook, “The Complete Driver Qualification Handbook: Your Step-by-Step Guide to Complying with Regulation Part 391 (Part 2).” To download and read the full ebook for free, click here.

JANUARY 10, 2019 – To maintain files that are compliant with Regulation Part 391, there are a few key items you must track and update for the duration of each driver’s employment.

Medical Certificates

All drivers must have a DOT medical evaluation at least once every 24 months (or as often as the medical examiner deems necessary) to ensure they are physically able to drive a  commercial motor vehicle. Once this physical is complete, the updated medical certificate must be kept in the Driver Qualification File.

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Conditions that require more frequent medical examinations include hypertension, heart disease, diabetes and sleep apnea.

Variance Renewals

If your driver has a physical impairment that affects their ability to operate a commercial motor vehicle safely, they must have a state-issued “variance” that needs to be carried with them whenever they’re driving a CMV. If a driver has impaired or missing limbs, they must have a special type of variance, known as a Skill Performance Evaluation (SPE).

All variances (including SPEs) need to be renewed periodically and expiration dates must be tracked right along with the driver’s medical certificate.

Medical Certificate Violations

In 2017, over 70,000 drivers were cited for not having a valid medical certificate during roadside inspections – making it one of the most common driver violations that year. Based on data from 2015 (the most recent year it’s available), a single violation for a missing, altered or falsified medical certificate often exceeds $2,000.

To prevent hefty fines or out-of-service orders, it’s important to keep a close eye on medical certificate and variance expiration dates to ensure that drivers have enough time to schedule and have a medical evaluation or submit their variance application before their certificate expires.

License Expiration Dates

In order to legally operate a motor vehicle, drivers must have a valid license and all required endorsements and/or classes must be active. It is important to track expiration dates carefully to ensure that no one with an expired license gets behind the wheel.

How long a CDL is valid will depend on where it was issued, with each state having its own licensing laws. In Connecticut, for example, CDLs must be renewed every 4 years. In Ohio, CDLs are renewed every 8 years.

Expired CDL Violations

In 2017, driving with an expired CDL was one of the top violations, amounting in fines of approximately $2,000 per occurrence. Unsurprisingly, it also results in the most out-of-service orders, with 98% of drivers being taken off the road because of an expired CDL.

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