Dot Your I’s and Cross Your T’s for Motor Carrier Compliance
Sunday, June 16, 2024
by: Terry Reil- Pro Fleet LLC

Section: Project Roadsafe

We’ve talked about the importance of your compliance and how you should evaluate where you’re at with your DOT compliance in the first two articles.  In this article, let’s start diving into some of the specifics you’ll be looking at.  The jumping off point for this article will be your driver qualification files.  There’s lots of requirements here and lots to look at and know.
An audit or assessment worksheet is very helpful when evaluating your driver qualification files, especially if you have a lot of drivers.  Oh, and by the way, this is for anyone driving commercial motor vehicles, not just CDL drivers.  Local vendors such as PRO Fleet LLC from East Barre, VT who provide motor carriers with compliance support, can provide these checklists or complete the evaluation of your files for you.
The employment application for a CDL driver is very different from a standard employment application.  It contains information specific to CMV drivers that is required.  So, is your application a “driver’s application”?  If not, you’ll need to acquire these and have them completed.  Make sure the entire driver’s application is completed and signed.  If there is a place for the date of hire, include it, or simply record it at the top of the application.  Many annual driver qualification tasks will become due based on this date so it’s important to have easy access to it.
The application includes a place for the driver to acknowledge and report accidents and violations.  There is also room for a driver to report up to ten years of employment history.  These need to be complete and accurate.  The pre-employment driver motor vehicle record should match up with what the driver has reported.
The pre-employment driver motor vehicle record requires the driver to consent here in Vermont.  A form may be acquired from VT DMV.  Once you have a driver’s motor vehicle record, you should review it in detail.  Does the driver have the correct class license and endorsements?  When does the license expire?  Does the driver have any violations or accidents?  Is the driver’s medical certification current?  When does that expire?
If the driver has less than a year of driving experience, you should have a completed road test form and certification.  You should also have a copy of the driver’s current driver’s license and medical certification (card).  Inspect these and ensure the information matches with the driver’s motor vehicle record.  Note the expiration dates of each of these documents.  You should be tracking these to ensure they are renewed before expiration.
An often-missed document, the medical examiner registry certification must be completed each time a driver receives a new medical certificate (card).  This form documents that you checked the medical examiners registry to ensure the medical examiner is approved by FMCSA to complete driver certifications.
Next up, the statement of on-duty hours.  This is a pre-employment requirement that documents the driver’s on-duty hours for the seven days prior to their date of hire or start date.  As a driver of a CMV, the driver must be in compliance with hours-of-service requirements, even when switching jobs. 
The next document, which is a duplicate of information gathered on the driver’s application, is the certificate of violations.  As a best practice, I prefer this to be a form by itself.  It is simply the driver’s acknowledgment and report of any violations within the last three years. 
Lastly, annually on the CMV driver’s hire date anniversary, you must run their motor vehicle record after acquiring their consent.  You will review this report in detail to ensure the driver has not had any violations, accidents, or suspensions in the last twelve months.  Your review must be documented on an additional form annually as well.
This completes the first part of your review of driver qualification files.  In the next issue we’ll cover the second half of driver qualification files, which includes a safety background check and drug and alcohol documentation.
Check in next issue to learn more about how to dot your i’s and cross your t’s for motor carrier compliance.
Terry Reil