What You Need To Know About DOT Background Checks
Conducting a Department of Transportation (DOT) background check when hiring a commercial driver helps protect your business. Here’s what you need to know.
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Karen Axelton
11 min read
To maintain registration with the US Department of Transportation (DOT), commercial motor vehicle carriers must keep driver qualification files for their drivers, including non-CDL drivers.
Learn why a DOT driver qualification file is important, what records to keep, and how often to update the information to stay in compliance.
Commercial motor vehicle carriers registered with the US Department of Transportation (DOT) have to comply with many regulations to maintain their DOT registration. This includes maintaining driver qualification files (DQFs) for the drivers you employ.
The Federal Motor Carrier Safety Administration (FMCSA), the DOT arm that oversees commercial motor vehicle safety, requires DQFs from every new carrier as part of the new-entrant safety audits they perform. If you pass the audit, your DOT registration becomes permanent. If you fail, your registration will be revoked, and your business won’t be allowed to operate until you correct the safety problems specified by the FMCSA.
Even after you’ve obtained your DOT registration, you’ll need to maintain DQFs in case of an audit. Keep reading to learn more about DOT Driver Qualification Files.
A Driver Qualification File (DQF) is a mandatory collection of documents and records that motor carriers must maintain for each commercial motor vehicle (CMV) driver, as required by the Federal Motor Carrier Safety Administration (FMCSA) and the US Department of Transportation (DOT). The primary purpose of a DQF is to prove that a driver fulfills DOT driver qualifications, both legally and medically, to safely operate a commercial vehicle. This rule applies to drivers with commercial driver’s licenses (CDL) as well as some non-CDL drivers. Self-employed owner-operators must also maintain a DQF to ensure their own compliance with safety regulations.
Within the first 12 months of operation, new motor carriers must pass a new-entrant safety audit. The DQF is among the documentation you’ll have to submit as part of that initial audit. You must also maintain an updated DQF for each driver throughout the duration of driver’s employment and be prepared to provide it in case of future audits.
A DQF is required for all CDL drivers as well as non-CDL drivers if their vehicles meet certain weight criteria. Interstate non-CDL drivers of vehicles that have a gross vehicle weight (GVW), gross vehicle weight rating (GVWR), gross combination weight (GCW) or gross combination weight rating (GCWR) between 10,001 and 26,000 pounds require a DQF. (Once a vehicle reaches 26,001 pounds, a CDL is required in order to drive it.)
A DQF is also needed regardless of vehicle weight if any of the following apply to an interstate non-CDL driver:
Intrastate non-CDL drivers may have different weight criteria, because state regulations sometimes differ from FMCSA regulations. For example, states may have different weight limits than those set by the FMCSA or may exempt certain drivers from some DQF requirements. Contact the state agency that regulates commercial motor vehicles to find out what rules apply in your state.
A DOT license, which is commonly referred to as a commercial driver’s license (CDL), allows an individual to operate certain large commercial vehicles. There are three classes of CDLs (A, B, and C), each corresponding to different types of vehicles and cargo the individual will operate and transport.
To earn a CDL, drivers must meet DOT certification requirements which include passing a skills and knowledge test and complete a training program through a registered provider. Drivers also must obtain an endorsement if they plan to drive the following types of vehicles:
The FMCSA maintains standards for getting a CDL, while the driver’s home state issues the license after the driver completes all requirements.
Whether you need a CDL depends on the weight of the vehicle, what the driver is transporting, and the passenger capacity. You likely need a CDL if one or more of the following apply:
The DQF should contain records documenting the driver’s qualifications, including their employment application and prior employment verification, state motor vehicle records, road test certification, medical exam and certificate of examination, and an annual list of violations. A DQF is required for both CDL and non-CDL drivers if the vehicles meet certain weight criteria.
Here’s an overview of what employers must keep in a DOT driver qualification file, as outlined in Section 391.51 of the FMCSA Regulations:
Driver’s employment application (§ 391.21) | • A copy of the driver’s signed job application (keep on file for the duration of their employment and for three years after they leave the company) • Job application which must include the driver’s: Employment history from the past three years; experience operating motor vehicles; accidents and moving violations from the past three years; and a statement explaining denial, revocation, or suspension of any license, permit, or privilege to operate a motor vehicle • Refer to the FMCSA’s New Driver Application Package for guidance |
State motor vehicle record (MVR) at time of hire (§ 391.23) | • Motor vehicle records for every state in which the driver has held a license or permit over the last three years. Obtain these within 30 days of the driver’s start date • A note related to the annual review of the driver’s MVR |
Verification of past employment (§ 391.23) | • Signed release forms that give the employer permission to request information about the driver’s alcohol and controlled substances history and safety record while in previous jobs • Safety performance history records from all DOT-regulated employers during the previous three years • Notes from the employer’s inquiry and how the employer contacted previous employers • Investigation must be completed within 30 days of the driver’s start date. • Records of applicable accident history and alcohol or controlled substances violations, and rehabilitation completion • Documentation of good faith efforts if information is not received within 30 days • The driver must receive a copy and have the opportunity to review and comment on information received and have it corrected, if needed • Safety Performance History Information Driver/Applicant Correction Request or Rebuttal form, if needed |
Road test certificate | • A certificate of the driver’s road test (or equivalent) or a written statement that the driver doesn’t need the road test • If waived, keep the documentation of waiver |
Medical examiner’s certificate | • A medical examiner’s certificate or a legible copy of the certificate, along with related documents |
Driver’s license | • Valid commercial driver’s license (CDL), if needed, for the appropriate class • Endorsements, if needed |
Skill performance evaluation | • A skill performance evaluation certificate issued by FMCSA (or a medical exemption document) • Note about the verification of the medical examiner (for non-CDL holders) |
Annual driver violations certification | • Annual certification of motor vehicle law violations with the driver’s signature |
Drug and alcohol testing | • Pre-employment drug test results • Random testing documentation Documentation of testing program compliance • Previous employer substance testing history (past three years) |
By carefully investigating each job candidate’s driving record and employment history, you’ll protect your business—and ensure safer roads for everyone. But gathering the information you need for a DOT background check can be time-consuming with its multiple steps.
A provider that offers ongoing background checks, including motor vehicle checks and employment verification checks, can make your life easier by gathering information the DOT needs. GoodHire can speed and simplify the process of background checks and maintaining your DQFs. Get started today with fast, accurate DOT background checks that provide results you can trust.
The resources provided here are for educational purposes only and do not constitute legal advice. We advise you to consult your own counsel if you have legal questions related to your specific practices and compliance with applicable laws.
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