Driver Qualification File Audit Checklist

Pull the file from Foley, J.J. Keller Encompass, Tenstreet, or your local DQ folder. Confirm you are auditing the active file — terminated drivers retain a separate retention rule (3 years post-termination per Part 391.51).

Record the driver's full legal name (matching CDL), CDL number, issuing state, and date of hire. Mismatches between the application name and CDL surface naming inconsistencies that have flagged DQ files in past audits.

New-hire and existing-driver files have different required artifacts. New hires (within first 30 days) must have prior-employer inquiries underway; existing drivers must show the annual review of driving record.

The application must contain all 13 required elements per 391.21 — including 10-year address history, 3-year employment history, accident record, traffic conviction history, and license history. Unexplained gaps over 30 days are a common audit finding.

Photocopy or scan must show class (A/B/C), endorsements (H, N, P, S, T, X), restrictions, and expiration date. Flag any CDL expiring within 30 days for renewal follow-up.

If the driver runs hazmat, confirm the H endorsement (or X for combo) plus current TSA threat assessment. Tank or doubles/triples assignments require N or T. Mismatches between dispatched freight and endorsements are a Driver Fitness BASIC violation.

An MVR from the state of licensure must be obtained at least once every 12 months. The most common audit finding in this section is an MVR dated more than 12 months prior to the audit date.

Part 391.25(c)(2) requires a signed note in the file documenting the carrier's review of the MVR — not just the MVR itself. Many carriers have the MVR but no signed review document; that is a violation.

Look for DUI, controlled-substance, leaving-the-scene, felony with CMV, and serious traffic violations (excessive speeding, reckless driving, improper lane change, following too close). Two serious violations in 3 years = 60-day disqualification.

Pull the driver from the dispatch board, notify the Safety Director, and document the disqualification under Part 391.15. Do not allow a return to safety-sensitive duty until the disqualification period ends and a new MVR is reviewed.

Standard cert is 24 months; shorter (3, 6, 12 months) for certain conditions like hypertension or sleep apnea. Expired med cards = immediate OOS at roadside and a Driver Fitness BASIC hit.

Look up the National Registry number on the FMCSA NRCME site. Certificates issued by examiners removed from the registry on the date of exam are invalid — this happens after enforcement actions and the carrier is responsible for catching it.

Skill Performance Evaluation (SPE) certificates for limb impairments, vision exemptions, diabetes exemptions, and seizure exemptions must be in the DQ file alongside the medical card. Confirm the exemption is current and matches the driver's actual condition.

Inquiries must cover all DOT-regulated employers from the prior 3 years and be sent within 30 days of hire. Include general employment verification plus the drug & alcohol history under Part 40.25.

If a prior employer does not respond within 30 days, the file must show the inquiry attempt — date sent, method (fax, email, certified mail), and follow-up calls. The documented attempt is itself the compliance artifact.

For each DOT-recordable accident reported by a prior employer, attach the accident register entry and any preventability determination. Pattern of accidents may trigger additional training before assignment.

The road test must be administered in a vehicle representative of what the driver will operate. A CDL skills test from the past 3 years can substitute under 391.33 — file the CDL test copy in lieu of the road test if used.

Drivers obtaining a Class A or B CDL, an upgrade, or H/P/S endorsement after Feb 7, 2022 must complete Entry-Level Driver Training. Confirm the training provider is on the FMCSA TPR and the certification has been transmitted.

For drivers hauling placardable hazmat, 49 CFR 172.704 requires general awareness, function-specific, safety, security awareness, and in-depth security training every 3 years. Missing in-depth security plan training is a common hazmat finding.

Negative pre-employment DOT 5-panel must be received before the driver performs any safety-sensitive function. Confirm the chain of custody form (CCF) copy 4 is in the file alongside the MRO report.

Pre-employment requires a full query (with driver consent). Annual queries thereafter can be limited unless a hit appears. File the query result and the driver's electronic consent — the consent itself is a required artifact.

Driver must be in a consortium / TPA pool meeting the annual minimum rates (50% drugs, 10% alcohol). File the enrollment letter from the TPA — Foley, J.J. Keller, USA Mobile Drug Testing, etc.

For any DOT-recordable accident or reasonable-suspicion event in the past 3 years, confirm the test was administered within the required window (8 hours alcohol, 32 hours drugs post-accident). Late or missing tests are a Controlled Substances BASIC violation.

The Safety Director or DQ File Administrator signs off on the audit. Capture the overall result, list any remediation items with owners and due dates, and attach a scan of the corrected documents once received.

Set the next-cycle MVR pull and DQ audit date — typically 11 months out so the annual review never lapses past 12 months. Add to the compliance calendar in Foley / J.J. Keller / Manifestly.