Last week I arranged a meeting for one of our trucking partners and Mike Purcell with Compass Compliance Management. The purpose of our meeting was to go over best practices for DOT Compliant record keeping. The partner we met with was not new to the trucking business and was not a small operation. I was blown away by the DOT requirements, simply from a paper work point of view. There are mandatory items required to be kept in file, that their staff were not aware of. It was a real eye opener for me. Larger fleets have key personnel tasked with maintaining their DOT compliance files. How about the little guy?? What about the trucking operation that runs a handful of trucks, but can't afford staff to maintain DOT compliant records?? What about the owner-operator working for himself and keeping no files??
My purpose in this post, and future ones to come, is to provide you with a hit list of records to keep for your DOT files. No one gets excited to hear about any sort of audit, especially one performed by the Department of Transportation! Hopefully this will put you on the path to maintaining compliant files, so you don't have to sweat your audit too much!
9 REQUIREMENTS for Driver Qualification File (even if you are the owner and only operator)
Application for employment - Federal Motor Carrier requires application for employment be made on a form furnished by the motor carrier, completed by the applicant, and signed by the applicant. You can click HERE for a link to the full list of application requirements.
Inquiries to previous employers - An inquiry attempt must be completed within 30 days. Make sure to document the attempt, whether mail, email, or fax. You are non-compliant if the inquiry is outside 30 days from the date of application.
Driving Records New Hire - Driving record (MVR) should be run at the time of application and be a 3 year history at minimum. MVR report options vary state by state. Most give you a 3 year report, but states like Texas will give you a 5 year history option.
Driving Records Annual - A new MVR must be run and maintained once every 12 months. We have some trucking partners that like us to run them on a quarterly basis. We have had situations where a drivers CDL was suspended during an annual term, but went unknown. This could be a MAJOR problem for the motor carrier.
Annual certification of violations - This certification can be a combined form in conjunction with number 6 below. Each driver should have an annual performance review. The form will give the driver the opportunity to state any violations they may have on their record and a place for driver to sign.
Annual review of driving record by management - This lets DOT know that management is reviewing driver MVR and performance on an annual basis, at minimum.
Copy of current valid driver's license - A copy of the applicant/employee driver's license must be maintained in file with notation of their expiration date.
Medical Examiner's Certificate - A copy of the applicant/employee's med cert must be in file. You are required to keep the most current, along with any previous certificates you have on file. Current medical certificates do not replace the old one in file, you must retain all.
- Verification of Medical Examiner's listing - You are responsible for going to the National Registry of Certified Medical Examiners LINK HERE to verify the examiner is on the national registry. You simply submit the examiners number in the search field and confirm they are listed.
I hope this brings some value to you and can assist in keeping your DOT files compliant. Compass Compliance offers a really cool tool to keep up with all of this in a digital form. Reach out to them via email or check out their web based File Management Tool: MYDOTFILES.COM
You're always welcome to reach out to me via email with any trucking insurance questions or if you'd like to talk shop.