COMPLIANCE TOOLKIT · MY SAFETY MANAGER
Turn a driver-file review into a clear work list. See the records that apply, identify gaps, and assign the next steps.
START WITH THE RIGHT REQUIREMENTS
Designed for U.S. interstate property carriers reviewing ordinary driver files under the full Part 391 rules. Required fields are marked *.
A PRACTICAL DRIVER-FILE GUIDE
Use the carrier’s application and verify all required fields, the signed certification, and employment history. The federal application calls for all employers during the last three years, plus an additional seven years of CMV employers for CDL-required applications. Keep personal identifiers in the secure application system. Read §391.21.
The initial inquiry covers the prior three years and every relevant licensing authority. Record what was requested, when it was requested, and what came back. The initial record and the medical-status verification can have different timing requirements; do not use the 30-day initial-MVR deadline as a medical-qualification grace period. Read §391.23.
Match the road-test certificate or permitted equivalent to the actual vehicle assignment. A CDL is not an equivalent for the tank or doubles/triples endorsement. The alternative vision standard has its own road-test provisions. Keep the evidence that supports the carrier’s decision. Read §391.33.
For CDL-required work, verify and document the current licensing-state CDLIS record. For non-CDL CMV drivers, retain the medical examiner’s certificate and the National Registry verification note. Retain applicable medical variance documents. The full medical examination report is not a standard DQ-file requirement. Read §391.51.
Request the applicable driving records at least every twelve months, then perform and document the review. The reviewer’s name and review date belong in the file. The former federal annual driver certification of violations requirement was removed in 2022; it is not included in this checklist. Read §391.25.
The prior-employer safety investigation has a separate, secure file with controlled access. Keep responses, good-faith attempts, and required rights notices. If no applicable previous DOT employment exists, document that. A Clearinghouse query does not replace employment verification and crash-history investigation. Read §391.53.
Part 382-covered drivers have separate drug-and-alcohol requirements, including pre-employment testing or a properly documented exception, a pre-employment Clearinghouse full query, and ongoing queries. Protect these records through the appropriate restricted workflow. This checklist is not a complete drug-and-alcohol program audit. Read §382.701.
Rules reviewed October 24, 2026. Review the current Alaska medical-record exemption and its conditions before relying on it.
A CDL requirement and a Part 391 qualification-file requirement are different questions. A non-CDL driver operating a covered interstate CMV can need a DQ file. State-only and excepted operations require a separate applicability review.
The checklist records your answers and helps organize work. The carrier must verify the underlying records, current qualifications, and all requirements before assigning driving.
The former federal §391.27 annual certification requirement was eliminated effective May 9, 2022. Annual MVR inquiries and annual driving-record reviews remain. Separate driver reporting duties and company policies can still apply.
Yes. My Safety Manager helps carriers manage qualification records and recurring compliance work. See what MSM membership includes or ask for help with your driver files.
My Safety Manager · A practical file-review aid. Version 1.0 · October 2026.
