Here are some highlights of today’s JJ Keller webcast on Driver Qualification (DQ) Files, in case you missed it.
The DQ file assists in vetting drivers. It is legal proof of compliance.
An incomplete DQ file is a DOT violation and that file will always be in violation if it is missing required documents or information.
If the DQ file is incomplete, then one may do a “corrective action.”
For example, if the original MVR is missing, then one could substitute the next oldest MVR, and document that by putting a note in the file: “DID THIS IN LIEU OF ORIGINAL MVR.”
Never backdate documents.
The corrective action should show meaningful action to offer a solution by showing safety management controls are now in place to avoid the same mistake.
All CMV drivers in interstate commerce are subject to having DQ Files.
Drivers in intrastate commerce must follow their state rules, which vary from state to state.
Keep DQ files at your primary place of business.
Records must be made available with in 48 hours of DOT request.
Records can be off-site, but you must be able to access them.
DQ file can combined with the personnel file, but you need to be able to separate the documents.
The DOT Drug and Alcohol file must be secured in a controlled access location.
Copies and scans are okay, but must be clear and readable when printed out.
Keep files until end of employment plus at least 3 years.