What are the qualifications or standards to administer company D.O.T. driving tests?

What are the qualifications or standards for individuals who administer company D.O.T. driving tests?

Per Part 391.31, every driver should be road tested, as part of the Driver Qualification (DQ) process and given a Certificate of Driver’s Road Test. If the driver does not have a CDL but is driving a Commercial Motor Vehicle (CMV), he or she must be road tested.  Owner-operators or non-CDL owner-drivers (referred to by the DOT as “a driver who is a carrier”) need to be road tested by someone other than themselves.

Ideally, the most experienced driver in your organization would conduct the road test. The regulation states in (b):

“The test shall be given by a person who is competent to evaluate and determine whether the person who takes the test has demonstrated that he/she is capable of operating the commercial motor vehicle, and associated equipment, that the motor carrier intends to assign him/her.”

After the successful completion of the road test, a copy of the Certificate of Driver’s Road Test should be placed in the Driver Qualification file, and a copy given to the driver.

Certificate of Driver's Road Test

Certificate of Driver’s Road Test

When can the Road Test be administered?

The road test may be conducted before administering the DOT pre-employment drug screen. After receiving results of the drug test and after a job-offer, if required by company policy, a DOT physical can be administered.

What should be covered on the Road Test?

A well-administered road test should address these aspects:

  • The driver’s skills (technical, mechanical and physical) associated with                  driving a commercial vehicle;
  • The attitude of the driver, while driving a commercial vehicle.

How is a Road Test done?

A road test should begin with a full pre-trip or “walk-around” or safety inspection as required by §392.7. The driver should explain what is being looked at during the inspection, for example, any possible safety defects, as he or she observes and checks the vehicle.

The driver should demonstrate his or her range skills including steering, stopping, shifting and backing exercises. Coupling and uncoupling of combination units should be included, if the equipment he or she may drive includes combination units.

Safety Tip: The driver’s range proficiency (the parking and backing portion) should be adequate enough to determine that the applicant will drive safely during the on-the-road portion of the test.

The actual road test should be over a predetermined route of approximately 45 minutes of in-traffic driving, including the following:

1. Four left-hand and four right-hand turns.

2. A straight section of road in or near a business district.

3. Three or more intersections with various controls and rights-of-way as stop, yield, a yellow caution light, etc.

4. A railroad crossing.

5. At least one tight curve.

6. A five mile section of limited access highway or expressway or a stretch of rural two-lane highway.The applicant should demonstrate lane changing during that part of the test.

7. A downgrade long enough to allow the driver to demonstrate downshifting and /or stopping without rolling.

8. An upgrade (hill) to show stopping/starting without rolling backward.

9. An underpass or bridge with a posted weight limit or some other hazard which the driver should see and identify to you when asked.

If the above features are not locally available, then it may be possible to simulate that portion of the test. For example, if no railroad-highway grade crossing is near, the road-test administrator can say, “At the sign (or some landmark) ahead, I would like you to simulate a rail crossing.” Document why any portion of a road test was not done. All tests should be conducted in the same manner for all drivers.

Click here for a road test evaluation form in .pdf format. This form is placed in the driver’s DQ file at the end of the test.  JJ Keller has commercially printed forms.

Doubles/triples or tank vehicle endorsement on a CDL

A copy of the CDL alone is not sufficient for any driver required to have a double/triple trailer or tank vehicle endorsement. These CDL drivers need to be road-tested.

CSA Impact

While no specific CSA points for a Part 391.31 violation are allocated in Table 3. CSMS Driver Fitness BASIC Violations of the CSA Methodology, keeping inadequate safety records or failing to provide records can result in fines of varying amounts.


Road test every driver as part of the qualification process. All non-CDL CMV drivers must be road tested, as well as CDL drivers required to have a double/triple trailer or tank vehicle endorsement. A driver cannot roadtest himself. A competent driver in your organization should conduct the road test. Conduct every road test in the same manner. Give the driver a copy of the Certificate of Driver’s Road Test and put a copy in the DQ file along with a copy of the Road Test Evaluation form.



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