If you’ve been around the trucking industry for any length of time, you’ve undoubtedly heard the term “DQ file” thrown around here or there. But what exactly is a DQ file and what does it contain? In this article, we‘ll take a close look at the federal regulations that govern these files, but generally speaking:
A DQ—short for driver qualification—file is a paper or electronic file created and maintained by a motor carrier on all drivers that operate commercial motor vehicles under its USDOT number. DQ files are mandated by Part 391 of the Federal Motor Carrier Safety Regulations and must contain specific documents evidencing each driver’s qualifications to operate a commercial vehicle, including, for example, motor vehicle records, medical examiner certificates, and road test certifications, to name a few.
Who must keep DQ files?
DQ files, and the driver qualification rules more broadly, apply to motor carriers and drivers who operate "commercial motor vehicles" in interstate commerce. For this purpose, the term "commercial motor vehicle" (CMV) includes:
Vehicles or combinations with a GVWR, GCWR, or gross weight of 10,001 lbs. or more;
Vehicles designed or used to transport more than 8 passengers (including the driver) for compensation or more than 15 passengers (including the driver) not for compensation; and
Vehicles used in transporting placardable quantities of hazardous materials.
Carriers who utilize drivers to operate these types of vehicles in interstate commerce must ensure the drivers meet the minimum qualification standards set forth in Part 391 of the Federal Motor Carrier Safety Regulations (FMCSRs) and must document those qualifications in DQ files.
Even if you're a carrier that operates exclusively in intrastate commerce in a particular state, it's very likely your state has adopted the vast majority of the driver qualification rules we address in this article. That said, be sure to check with the agency in your state that regulates motor carrier operations.
What specific documents must be included in a DQ file?
The FMCSRs specify exactly what types of documents must be included in a DQ file, both initially and on an ongoing basis. We'll briefly summarize each document type below. Note that Trucksafe has created fully-customizable and downloadable versions of each document type that carriers, themselves, generate, which are available to purchase at the links included below. If you are just getting started and need each document type, be sure to check out our Driver Qualification Bundle, which contains all of the documents linked below plus a handy DQ File Checklist and Cover Sheet for each of your files.
Copy of Driver's License or CDL - It may go without saying, but you'll need a current copy of each driver's license or commercial driver's license (CDL), as applicable, to keep in their DQ file. And as with most other documents in this list, you'll need to track the expirations of the drivers' licenses, make sure they are renewed before they expire, and update the DQ file with each renewed license.
Driver Application - All CMV drivers are required to complete a driver application, and a copy of the completed application must appear in their DQ file. The application must contain all of the required data points set forth in Part 391 of the FMCSRs, including, for example, the driver's employment, licensing, and driving history.
Safety Performance History Request - Each prospective employer of a CMV driver is required to request specific safety performance history (for all commercial drivers) and drug/alcohol testing violation details (for non-CDL drivers, as CDL drivers' drug/alcohol history is now obtained through the Drug/Alcohol Clearinghouse) from any DOT-regulated employer for whom the applicant worked within the 3 years prior to his/her application with that carrier. Applicants must provide written consent for these requests, and the consents must accompany the requests. Carriers must document their good-faith attempts to obtain this information from the previous employers in the DQ files.
HOS Record for First Time or Intermittent Drivers - Carriers who are using a CMV driver for the first time or intermittently must obtain a signed statement from that driving that lists the total time the driver spent on-duty and driving during the immediately preceding 7 days, as well as the time at which the driver was last relieved of duty prior to beginning work for the carrier. A copy of the completed statement should be kept in the driver's DQ file and used for purposes of ensuring the driver has a sufficient number of hours left to work on a given day/week.
Medical Examiner's Certificate - Drivers are not qualified to operate a CMV in interstate commerce unless they meet the FMCSRs physical qualification standards, as certified by a licensed medical examiner that is listed on the FMCSA’s National Registry of Medical Examiners. The FMCSA’s physical qualification standards ensure that drivers with certain medical conditions that would impair their ability to safely operate a CMV do not do so. In order to demonstrate they meet these standards, CMV drivers must be evaluated by a DOT medical examiner pursuant to the examination standards set forth in the FMCSRs. If the driver meets these standards, the examiner will issue him/her a medical examiner’s certificate (a/k/a med card), which is valid for a period of time designated by the medical examiner, up to a maximum of two years. Drivers must be reexamined and re-certified prior to the expiration date of their most current med card in order to remain qualified to operate a CMV. Further, drivers who are subject to the CDL requirement must provide documentation of their updated medical certification to their state licensing agency in order for their CDL to remain valid.
Medical Examiner Registry Verification - As noted above, CMV drivers must be examined by a medical examiner that is listed on the FMCSA's National Registry of Medical Examiners. In addition to keeping a copy of each driver's med card in their DQ files, carriers are also required to verify that the examiner who performed the driver's examination is, in fact, listed on the National Registry and document that verification in the DQ file. This can simply be a matter of searching the examiner's National Registry number online at this link and printing off the results to place in the file.
Road Test Certificate or Equivalent - As part of the driver onboarding process, carriers must normally administer a road test to driver-applicants to ensure they can safely operate the types of CMVs that they will be expected to operate for the carrier. Upon successful completion of that road test, the examiner must complete a certificate, a copy of which is to be provided to the driver and another kept by the carrier in his/her DQ file. For driver-applicants who have already successfully passed a road test administered by another carrier within the past 3 years and those who already possess a CDL at the time of hire, the carrier can (but is not required to) accept that prior road test certificate or CDL in lieu of performing and documenting its own road test.
Motor Vehicle Record - Within 30 days after a CMV driver is hired or otherwise engaged, the motor carrier must obtain and review a Motor Vehicle Record (MVR) from every state in which the driver has been licensed within the 3 years preceding his/her application date. A copy of the MVR must be kept in the DQ file.
Annual Review - At least annually, carriers must review each driver’s MVR, as well as other information described in 49 C.F.R. 391.25, to ensure each driver remains qualified to operate. The carrier must then complete an Annual Review form to place in the driver’s DQ file.
In addition to these primary documents, the FMCSRs require, in certain circumstances, the following additional documents:
LCV Training Certificate - Drivers who are expected to operate longer combination vehicles (e.g., double or triple trailers) must not only have the proper CDL endorsement to do so, but also successfully complete a training program that meets the requirements of 49 C.F.R. Part 380, Appendix F. Upon successful completion of that training, drivers must be issued a training certificate, a copy of which should be retained in their driver file.
Hazardous Materials Training Certificate - Drivers who are expected to haul hazardous materials must receive the training that is required by Parts 172 and 173 of the federal Hazardous Materials Regulations (HMRs) (e.g., general awareness, function-specific) within 90 days of employment or change in job function and at least once every 3 years thereafter. Evidence of the training should be kept in their driver files. Trucksafe offers this type of training through its Trucksafe Academy at this link.
Drug/Alcohol Policy Receipt - CDL drivers are subject to the FMCSRs' drug/alcohol testing requirements. Carriers that engage those drivers are responsible for implementing a compliant drug/alcohol testing policy and ensuring that drivers receive a copy, as evidenced by a signed receipt that should be kept in the drivers' files.
Pre-Employment Drug Screen - Again, CDL drivers are subject to the FMCSRs' drug/alcohol testing requirements, including mandatory pre-employment drug screens. Carriers must ensure that CDL drivers test negative for drugs prior to operating a CMV that requires a CDL, and that a copy of the negative test result is placed in the drivers' files.
Drug/Alcohol Clearinghouse Queries - The FMCSRs require carriers that employ or engage CDL drivers to run queries (pre-employment and annual) on those drivers through their Drug/Alcohol Clearinghouse account. Copies of the query results should be kept in the drivers' files.
Must DQ files be periodically updated?
The FMCSRs impose an ongoing obligation on motor carriers to ensure that their drivers remain qualified to operate CMVs in interstate commerce. This entails periodically updating some, but not all, of the records contained in the DQ file. Specifically, the following records must be updated periodically:
Driver's License/CDL - Motor carriers must ensure that each DQ file contains a copy of the driver's current and valid license or CDL.
Medical Examiner Certificate - Carriers must also ensure that each DQ file contains a copy of the driver's current and valid med card.
MVR - At least once every 12 months, carriers must run and review a new MVR on all CMV drivers. It may be necessary to do so more frequently in certain cases, such as if a driver's license has been temporarily suspended. Running a new MVR in that situation to ensure that the license has been reinstated would be advisable. Additionally, for CDL drivers, carriers are required to run a new MVR within 15 days after the CDL driver obtains a new med card to ensure that the driver's med card details have been successfully uploaded to his/her state of license.
Annual Review - As noted above, at least annually, carriers must review each driver’s MVR and other information described in 49 C.F.R. 391.25, and complete an Annual Review form to place in the driver’s DQ file.
Hazmat Training - Carriers whose drivers are subject to the HMRs' hazmat training requirements must ensure that their training remains current (conducted at least every 3 years) and evidence of that training is updated in their driver files.
How long should DQ records be retained?
The FMCSRs specify that motor carriers must retain DQ files and their contents for the entire length of time that the driver operates under its USDOT number plus an additional 3 years. That said, the following individual records may be removed from each driver's DQ file 3 years after the date of execution:
MVRs except for the initial MVR, which should be retained for the length of employment plus 3 years;
Medical Examiner Certificates; and
Medical Examiner Registry Verifications.
Keeping compliant and up-to-date DQ files is an important part of a carrier's safety management controls, and will be closely scrutinized in the event of a DOT audit. Further, drivers who are not properly qualified will be placed out-of-service if they are stopped for a roadside inspection. It is, therefore, crucial that motor carriers take the time to understand their regulatory obligations and to build compliant files.
For in-depth training on how to prepare a DQ file and other regulatory topics like hours-of-service, vehicle maintenance, drug/alcohol testing, DOT enforcement, and much more, check out our industry-leading training courses offered through Trucksafe Academy!
About Trucksafe Consulting, LLC: Trucksafe Consulting is a full-service DOT regulatory compliance consulting and training service. We help carriers develop, implement, and improve their safety programs, through personalized services, industry-leading training, and a library of educational content. Trucksafe also hosts a monthly live show on its various social media channels called Trucksafe LIVE! to discuss hot-button issues impacting highway transportation. Trucksafe is owned and operated by Brandon Wiseman and Jerad Childress, transportation attorneys who have assisted some of the nation’s leading fleets to develop and maintain cutting-edge safety programs. You can learn more about Trucksafe online at www.trucksafe.com and by following Trucksafe on LinkedIn, Facebook, Twitter, and YouTube.