Driver Qualification

DQF Quick Tips

Be sure to have a negative pre-employment drug test AND a clear Drug and Alcohol Clearinghouse query in file BEFORE a driver begins hauling for you.

Dont forget to complete the driver's Safety Performance History within 30 days of hiring.

You must run a new MVR AND Drug and Alcohol Clearinghouse query at least once per year!

Once you begin hiring drivers, your compliance world changes dramatically. 

Now, you not only have to be responsible for maintaining your own qualifications, you must manage the qualifications of other drivers as well. 

While the task may seem daunting at first, break it down into smaller steps! 

DQF Checklist +

Use this Driver Qualification File Checklist to ensure that you have all required documents in each driver's file.

Driver Application +

A complete driver application is the first piece of a complete driver qualification process. 

Feel free to use the application below. 

I would download it and then send it as a PDF to your driver candidates for them to complete because it's a fillable PDF form.

Once they begin filling it out, many of the fields automatically complete. 

 

PRO TIP: 

Make sure that the driver candidate provides a complete 10-year employment history (this will be important a bit later).  

Copy of CDL +

You have a choice here.

You can either keep a copy of the candidate’s CDL or you could give them a road test and retain the results of that test in their DQF.

We recommend that you do both, of course.

But, make sure that you do at least one!

Having a copy of their CDL will help make sure that the info provided on the app is 100% correct when you go to order their MVR.

Motor Vehicle Record (MVR) +

Verifying the driver candidate’s driving history is very important and the first way to do that is by ordering and reviewing their Motor Vehicle Record.

Most states have a process for ordering a driver’s MVR online, but many find it helpful to contract with an MVR Provider Service which will order these for you quickly and send you the results.

You want to make sure of a few things on their MVR:

First, check the candidate’s license status. You must make sure that the candidate’s CDL is active (not suspended, invalid, cancelled or otherwise disqualified).

Second, check to see what kind of violations they have received over the last 36 months.

Do they have a history of speeding? How about any suspensions?

This report gives you a good preview of how this driver candidate may act when they’re driving for you.

These cost anywhere from $5 to $30 depending on the State MVR fee.

If you go through a 3rd party to get the candidate’s MVR, you’re going to have to pay a few bucks extra for the work that they do for you.

 

Pro Tips:

  • Be sure to order a new MVR for each driver on your Active Driver list at least once every 365 days.
  • Avoid the MVR providers who provide the “$19.95 special MVRs”. These tend to be low quality as they don’t gather all the important information that you need for commercial drivers.
  • If a driver candidate or driver’s CDL has ever been suspended for failing to pay child support, it’s a strong possibility that this may happen again. If you ever discover a child support suspension, order that driver’s MVR much more regularly (ever 3 months, perhaps?) or consider enrolling them in a Driver Monitoring Service like SuperVision.
  • Be sure to obtain the driver’s permission to order this report. It is illegal not to.
PSP Reports (Not Required) +

Many folks don’t know about this amazing resource. So, the FMCSA keeps tabs on trucking companies in their “CSA system”.

For motor carriers, this scorecard is called the Safety Measurement System (SMS).

Well, most drivers and companies don’t know that they keep close tabs on drivers too!

They do this in their Driver Safety Measurement System (DSMS).

They used to keep this data secret, but then figured out that it would really help trucking companies better understand if a driver candidate is going to wreck (no pun intended) their safety and compliance scores (BASICs).

So, for $25 annually and $10 per report ordered, they provide you with a 36-month snapshot of every roadside inspection violation that a driver candidate has received.

Personally, I find that these are usually more valuable than a candidate’s MVR.

The DOT says that companies who use PSP to screen drivers lower their crash rate by 8% and their driver Out of Service Percentage by an average of 17%!

 

Pro Tip:

  • You can use the PSP report to make sure that all companies that the driver previously worked for were included on the application. (a bit more on that later)

 

  • You only get one shot at a PSP report and that is when the driver is still a candidate. (PSP stands for Pre-Employment Screening Program….it’s kind of in the name).

 

  • Be sure to obtain the driver’s permission to order this report. It’s illegal not to.
Negative Pre-Employment Drug Test +

This is one of the most important documents that you will have in your DQFs.

Not having one of these bad boys for each of your drivers will automatically cost you thousands of dollars in fines and most likely cause you to fail this critical compliance area during a DOT audit.

 

Pro Tips:

  • Make sure that the drug test administered is a DOT regulated test.

 

  • Be sure to have a verified negative test result in hand before dispatching a driver for the first time.

 

Copy of Medical Certificate +

Make sure that a copy of the driver’s medical certificate is in file and that it hasn’t expired.

When a driver renews their medical certificate they have self-certified with their State.

Within 15 days of the medical certificate renewal, you have to order a new MVR to verify that they did this correctly.

 

NRCME (Medical Examiner) Verification +

This one may seem obscure, but the Investigator in EVERY compliance review that I’ve been involved with recently has made sure that these have been completed.

Compliance is actually pretty easy here.

You just have to go to the FMCA’s Medical examiner’s website (link below).

Click on "Advanced Search" on  the bottom right. 

Enter the medical examiner’s National Registry Number (NRN) (found at the bottom right hand corner of the medical certificate).

Hit “Search”.

Print the results and save it in the file.

 

Pro Tip:

  • You need to repeat this process every time the driver renews their medical certificate, even if it’s the same medical provider. (They may have lost their ability to conduct DOT physicals.)
Full Drug and Alcohol Clearinghouse (DACH) Query +

You must run a "full" DACH query on each new driver candidate and receive a "Driver Not Prohibited" result BEFORE that truck driver operates for you.

Once you submit a query, the FMCSA goes and requests permission from the driver candidate.

If that candidate gives permission for the release of their records, the FMCSA will send you the report. Print the report and keep it in the DQF.

You must also run a "Limited" DACH query at least every 365 days on each driver.

Additionally, you must secure a truck driver's written permission to order a DACH query.

Employers (or their C/TPA) are responsible for telling the FMCSA when a driver refuses to test. Medical Review Officers have to report failed drug/alcohol tests to the DACH.

Every owner-operator must register AND select to be served by a "C/TPA".

These are compliance management companies, like Carrier Risk Solutions, Inc., who specialize in helping fleet owners with safety and compliance.

Every motor carrier must register for the Clearinghouse.

Once you’re registered, you can “query” or search for a driver’s drug and alcohol history in the database.

Driver Safety Performance History +

If your  driver served in a safety sensitive function at a DOT regulated entity within the last 36 months, you must verify their past safety performance history.

This means contacting each DOT regulated employer and asking if the driver failed and drug or alcohol tests or had any crashes.

You have to do this up to 3 times for each prior employer! 

This must be completed within 30 days of the driver beginning to work for you!

Make sure that each driver candidate completes the prior employer section of their application.

Use the info provided and grab that carrier's email and phone number from the FMCSA SMS website. 

Email the completed release form to each prior employer and document your contact attempt on the SPH Tracking spreadsheet (Button #2 below). 

If the prior carrier doesn't respond in a week, send another email and call them to try to get the info. 

Repeat this one more time if they still don't respond. 

Just be sure to document each attempt in the tracking spreadsheet!!

 

PRO TIP:

  • Be sure to check the driver candidate’s PSP report to make sure that you don’t miss any prior employers that may not have made it to the application.
Other Required (but less important) Items +

All of the stuff before this are the BASICS of what you must have in each driver’s qualification file. These few items are nice to have…and technically required but are secondary concerns.

Driver’s Record of On Duty Hours   49 CFR395.8 (j)(2)

You use this form to make sure that the driver has enough hours of service available to start working for you when they did.

MVR and PSP Authorization Forms   Fair Credit Reporting Act (FCRA Regulations)

You need to make sure that you obtain a driver’s permission prior to ordering their MVR or PSP report. There isn’t a set format for the MVR authorization, but the PSP program has a specific form that the driver must complete.

Drug & Alcohol Policy Receipt   49 CFR 382.601(d)

The FMCSA requires that you provide each driver with a copy of your DOT compliant Drug and Alcohol Policy. A great way to prove compliance here is to simply have a driver sign a form to serve as a receipt.

We've Got You!

We can fully qualify a new driver for you within 3 hours for only $75!

This includes:

Ordering and reviewing both MVR and PSP reports

Verifying the driver's medical examiner

Ordering the driver's initial "Full" DACH Query

Setting up their pre-employment drug test, collection, testing and MRO review

Conducting their Safety Performance History

Storing/Sending everything to you electronically

 

(This is only $49 for most My Safety Manager Members)

 

My Safety Manager members also enjoy the following services:

MVR, DACH, CDL and Medical Certificate expiration alerts

Ongoing monitoring of CDL suspensions or new MVR activity

Ongoing DQF Management

Once a driver begins working for you, it's important that you maintain your Driver Qualification Files going forward.

Here is a quick list of things that you have to do an an ongoing basis:

 

Within every 365 days, you must:

Order and review each driver's MVR to ensure they're still qualified to drive

Order and review a new "Limited" Drug and Alcohol Clearinghoue Query

 

Each time a driver's medical certificate expires, you must:

Order a new MVR to verify the driver's self-certification status within 15 days of renewal.

Verify that the medical examiner is listed on the NRCME database. 

Sleep Apnea and Drivers

Sleep Apnea +

For years, the Federal Motor Carrier Safety Administration (FMCSA) has been researching obstructive sleep apnea (OSA) and its impact on driving a fleet safety commercial motor vehicle (CMV).

The agency searched the scientific literature for evidence, conducted expert panel meetings of sleep apnea specialists, and developed and published reports. FMCSA’s two advisory committees—Medical Review Board (MRB) and the Motor Carrier Safety Advisory Committee (MCSAC)—reviewed the reports, listened to sleep apnea specialists, industry representatives, and drivers, and developed recommendations for FMCSA’s rulemaking and guidance development.

Since FMCSA has no specific rule or guidance on OSA, medical examiners (MEs) may not require a sleep apnea study, CPAP usage, or recording of the CPAP usage.

The agency does not list specific criteria for diagnosis and treatment of OSA.

But FMCSA gives MEs authority to make determinations and decisions based on their medical knowledge, the results of the driver’s physical examination, and the current medical standards of practice.

As mentioned above, the FMCSA’s Advisory Criteria direct the ME to refer the CMV driver to a specialist if a respiratory dysfunction is detected.

FMCSA expects the ME to gather additional information to ensure that the fleet safety driver can safely operate a CMV.

The ME must clearly understand and explain to the driver that the tests he/she is requiring are not FMCSA requirements.

Since the driver’s livelihood is involved in the ME’s decision, the ME should make practical recommendations considering the driver’s financial situation and lost work time.

If the fleet safety driver can be effectively diagnosed and treated with less expensive modalities, those should be used.

Drivers diagnosed with OSA and using a CPAP must have a follow-up sleep apnea study.

FMCSA does not require specific diagnostic testing/treatment, but the agency permits the ME to use medical best practices to govern his/her decisions.

This nuance is very confusing for drivers, MEs, and carriers. Lack of specific requirements for OSA results in inconsistent qualification decisions.

So, FRA and FMCSA are taking responsible steps to ensure they gather information to determine whether to develop a regulation or guidance.

Whatever their decision, it should be based on the most recent data and information.

The best way for the FMCSA to make its decision is to publish an ANPRM (which it published March 10, 2016), ask questions, and obtain recent information from a wide range of people in the regulated community.

The best way the public can participate is to obtain accurate information about rulemaking, refrain from spreading rumors, and submit substantive comments to the rulemaking processes.

I believe that this fear keeps drivers from having conversations with their doctors about potentially having sleep apnea. 

As someone who has severe OSA, I can tell you that my life changed dramatically for the better when I started using a CPAP machine! 

Do some research, get your life back and please keep yourself and all of our families safer!!

Great Resources!