They did it, again!
What they did was present another information-jammed-packed presentation—
Yesterday, Kathy Close and Daren Hansen of J.J. Keller presented a webinar called, Top Driver Qualification FAQs The who, what, when, and where of DQ file management.
Here are a few highlights . . .
If someone drives a Commercial Motor Vehicle (CMV), then they need to be qualified. And if they need to be qualified — with few exceptions — the qualifications need to be documented in a DQ file.
This could include . . .
- Hostler truck drivers (Yard spotters)
- Temps/seasonal drivers
- Contract drivers
- Business owners/principals
- Any CMV driver
Did we miss anyone?
“If they are Behind-The-Wheel (BTW), then they are a driver.” Kathy Close, Transportation Publishing editor.
What has to be in the DQ File?
- DOT Application for Employment
- Motor Vehicle Record (MVR)
- Safety Performance History
- Certificate or Road Test/CDL
- Medical Card/National Registry verification
- Annual Driver’s List of Convictions/Annual Review
JJ Keller can assist motor carriers in their DQ file needs in several ways.
- Most commonly, they sell millions of blank DQ files, for the do-it-yourselfers.
- JJ Keller also offers a Driver Qualification (DQ) File Management Service.
Some may prefer to download various forms available on federal and state websites. I will caution you these forms may not always be current or the latest form version. Download at your own risk.
What if something is missing in a DQ File or on a form?
Suppose you downloaded a free form from somewhere but are missing a page or two? Now what?
Kathy and Daren gave four golden rules of DQ File compliance . . .
- Acknowledge the error.
- Show a good-faith effort to comply.
- Never back-date documents (falsify)
- Correct your process/procedures.
Goofs occasionally happen to the very best motor carriers. Forms are not filled out. Forms are incomplete. Follow-ups are not done. Mistakes are made . . .
Okay, a paperwork mistake was made. Now what?
One consideration is the amount of time that has elapsed since the error. But if it was recent, it should be corrected.
Errors in DQ File recordkeeping should never be corrected by anything that could be considered fraudulent.
Do not attempt to hide the error. Document what was discovered and what, if anything, was done to correct it.
Then, the most important part, is to initiate a correction to your process and procedures so something like this does not happen again or is not likely to happen again. This might be in the form of a new checklist, a self-audit review or some other form of administrative control that works best in your particular operation.
Other DQ File Considerations
• Keep the file organized.
Things have a way of creeping into the DQ file. In some respects it’s a lot like a personnel file.
But it is not a personnel file, HR file, employment file or what-have-you file. The DQ file should not serve as a collection point for such things as payroll garnishments, court documents, accident reports, and the like. Only keep the information that is required to be in the file, nothing more and nothing less.
Any optional records in the DQ Files can and will be audited for violations if presented to auditors.
• Keep the file secure, if . . .
If the DQ File is keep together with secure information as Drug and Alcohol testing results or background investigation results, then the file must be kept secure (under lock and key, with authorized access only).
Tip: Federal Motor Carrier Safety Regulations list minimum retention periods.
Kathy and Daren covered much more in their presentation, including a question and answer segment at the end. I appreciate their help in keeping folks informed of the many regulatory nuances and thank JJ Keller & Associates Inc for sponsoring the webinar.
Thank you for reading this.