If you employ drivers who are required to hold a commercial driver’s license (CDL) and regulated drivers who are not, are you aware of the differences between the two when it comes to driver qualification (DQ) files? Let’s look at each piece of the DQ file for a comparison.
The driver-specific application contains the same data elements for both driver types; however, information provided on the application differs. For instance, underemployment history, both driver types list all employment for the previous three years and indicate whether they were subject to DOT testing and the Federal Motor Carrier Safety Regulations (FMCSR). But, if applying for a position requiring a CDL, the applicant must enter an additional seven years’ worth of work experience in which he or she operated a CDL vehicle.
Safety Performance History
Companies must pursue the past three years’ worth of safety performance history data from former DOT-regulated employers if such a history exists. The general employment verification and DOT crash history contained in the inquiry apply to all drivers. But, the DOT drug and alcohol history only applies if the driver was in a Part 40 program. For the non-CDL driver, you may not have any testing history to pursue. The driver’s application and licensing history will help explain why the information was not available.
The Road Test
A road test, using the vehicle type you intend on assigning, is required of anyone operating a commercial motor vehicle. A certificate is filled out upon successful completion of the test. Section 391.33 provides these exceptions to the road test:
- A road test certificate from a test performed within the past three years using a representative vehicle. This is available to all regulated drivers.
- A copy of a CDL. This exception is not available to drivers assigned to a double, triple, or tank vehicle. In those instances, you must perform a road test using the respective vehicle.
Proof of Medical Qualifications
Both driver types are subject to the same medical standards in Section 391.41. Documentation of the exam differs. Proof of medical status for the non-CDL driver includes a copy of the medical examiner’s certificate and any applicable variances. Also, the carrier must create a note that it verified that the medical examiner who performed the physical appears on the National Registry of Certified Medical Examiners (NRCME).
For the CDL driver, self-certified as non-excepted interstate, the medical examiner’s certificate is used as temporary proof of medical status — up to 15 days following the exam — until the company obtains a motor vehicle record (MVR) showing the medical status. The MVR becomes the long-term record of the exam, along with any variances and a note that the NRCME was checked.
For a new driver, you must request an MVR from each state in which he or she was licensed in the previous three years. Carriers are given 30 days from the date of employment to request the MVR(s) for a non-CDL driver. The CDL holder’s initial MVR is used for dual purposes: medical status and driving history. You either need an MVR right away when accepting an existing medical card or within 15 days of any new exam.
Annual MVRs & Review
An annual MVR is required for both CDL and non-CDL drivers. The carrier must generate a note that it performed a review of the driving record to ensure the driver is qualified. This is required within 12 months of hire and annually thereafter. When you request an MVR for a CDL driver’s medical recertification, you may also use it for the annual MVR — so long as it is before the annual process is due.
Annual List of Violations
Beginning at the one-year anniversary and annually thereafter all drivers must complete a list of traffic convictions occurring in any type of motor vehicle in the previous year. The one difference between driver types is that a CDL driver is required to notify the motor carrier within 30 days from the date of a conviction as prescribed in Section 383.31. These violations do not have to be listed on the CDL driver’s annual certificate of violations.
About the Author
Kathy Close is a transportation editor at J. J. Keller & Associates, Inc. Her areas of expertise include transportation security, DOT drug and alcohol testing, and driver qualification. For more information e-mail [email protected]