February 5, 2025
Every person who operates a commercial motor vehicle (CMV) for a motor carrier must be qualified. But what does “qualified” really mean?
At minimum, motor carriers are required under the safety regulations to assemble driver qualification (DQ) file documents at time of hire and maintain renewable items through course of employment. For those called upon to operate a CMV requiring a commercial driver’s license (CDL), the driver must be tested and investigated in accordance with DOT drug and alcohol rules to reduce the likelihood of using an impaired driver.
But is compliance with the Federal Motor Carrier Safety Regulations (FMCSRs) enough? It depends. Consider the following:
You must be able to defend who is behind the controls of your CMV against claims of negligence.
Negligence is usually based on something you should or could have known.
Your safety management controls should identify and address unsafe drivers.
Safety management controls typically include a combination of compliance and best practices.
Your safety practices will be under the microscope in the event of a serious crash. Not only will the DOT review your records, so will a plaintiff’s attorney. If your program were to be examined today, how would it fare?
Take the following quiz to help identify areas you may need to enhance:
Vetting Applicants
Which of the following statements best fits your screening process?
1. As best practice, we request a pre-employment screening program (PSP) report on driver applicants.
A. For every hire
B. Occasionally, but not consistently
C. Rarely or never
2. We use a driver-specific application for CMV operators.
A. For every hire
B. Occasionally, but not consistently
C. Rarely or never
3. Within 30 days of hire, we send out safety performance history requests and either have a returned inquiry or recorded attempts at retrieving the information.
A. For every hire
B. Occasionally, but not consistently
C. Rarely or never
4. We have a policy on what disqualifies an applicant from consideration when found after reviewing the initial Motor Vehicle Record (MVR).
A. For every hire
B. Occasionally, but not consistently
C. Rarely or never
Skip questions 5-6 if you don’t operate CDL CMVs
5. We request an applicant’s pre-employment query of the Clearinghouse prior to the first dispatch.
A. For every hire
B. Occasionally, but not consistently
C. Rarely or never
6. We receive a driver’s negative DOT pre-employment drug test result before the driver performs safety-sensitive functions for the first time.
A. For every hire
B. Occasionally, but not consistently
C. Rarely or never
Driver Orientation
Which statement best fits your driver orientation program?
1. We require new hire training on several regulatory and safety topics.
A. For every hire
B. Occasionally, but not consistently
C. Rarely or never
2. We provide drivers with a handbook of policies and procedures, collect a signed receipt, and go over key points.
A. For every hire
B. Occasionally, but not consistently
C. Rarely or never
3. We take new hires through hands-on demonstrations and training on company assets, including trucks, trailers, converter gears, cargo securement, etc.
A. For every hire
B. Just for drivers with less than 3 years’ experience
C. Rarely or never
Continued Qualification for Existing Drivers
Which statement best describes your process when determining whether a current driver remains qualified?
1. We use MVR monitoring to learn of changes to driving records.
A. For every driver
B. Occasionally, but not consistently
C. We don’t use an MVR monitoring service
2. We track roadside inspection reports to find trends and identify corrective action training for drivers.
A. For every driver
B. Occasionally, but not consistently
C. Rarely or never
3. We monitor expiration dates to remind drivers that medical exams are due to expire.
A. For every driver
B. Occasionally, but not consistently
C. Rarely or never
4. The company has a policy of reviewing annual MVRs to determine if a driver needs coaching or corrective action.
A. For every driver
B. Occasionally, but not consistently
C. We don’t consistently request and/or review annual MVRs
5. We require annual or refresher training for all drivers on most safety topics.
A. For every driver
B. For every driver, bit on a handful of select training topics
C. Some, but not all drivers
Skip questions 6-7 if you don’t operate CDL CMVs
6. We check the FMCSA Drug & Alcohol Clearinghouse on existing drivers.
A. Within 12 months of the last query
B. Only when reminded
C. Rarely or never
7. We consistently meet our annual random DOT drug and alcohol testing rates.
A. Every year
B. Most years
C. We don’t run random selections, although required
How Did You Do?
Mostly A’s - You have strong, well-established driver qualification practices!
Your safety management controls are thorough, ensuring compliance and risk mitigation. Keep up the great work!
Mostly B’s - You have a solid foundation but room for improvement.
While you have good compliance and safety measures in place, inconsistencies may leave your company exposed. Strengthening weaker areas will help reduce risk.
Mix of B’s & C’s - Your driver qualification practices may be putting your company at risk.
Gaps in compliance and best practices could increase your exposure to compliance and safety risks. Take steps to standardize your approach and close these gaps.
Mostly C’s - Your company is at high risk!
Significant deficiencies in your driver qualification process could lead to compliance failures and liability. Immediate action is needed to improve safety management controls.
Would your current drivers still qualify for hire today? If the answer is no, it's time to act. A well-structured driver qualification program isn't just about compliance—it’s about protecting your company, your drivers, and everyone on the road.
Want to improve your hiring and onboarding practices?
Learn more about J. J. Keller's Employee & Driver Services or visit our Resource Library.