DOT Driver Qualification and Background Checks

Mike Coffey, SPHR

It’s Coffey Time

Not that coffee. Yesterday, Mr. Mike Coffey held his webinar on “DOT Driver Qualifications and Background Checks”

Mike is the president of Imperative Information Group and conducts professional background checks on CDL and CMV drivers for small to medium sized businesses and motor carriers.

Why Background Checks are Important

Your name is on the side of the truck. Any wild or crazy driving reflects badly on you and the other folks you work with and work for. A bad hire can destroy a business.  A bad hire can take down a lot of people with him. Lawsuits, fines, higher insurance are a few of the consequences of a bad hire.

Know the Regulations

To know the regulations, know how a Commercial Motor Vehicle (CMV) is defined:
Parts 382 and 383 — apply to CDL drivers
Parts 390 and 391 — apply to non-CDL drivers (everyone).

Know what a Safety-sensitive function is under Part 382.107. Say a CDL driver fails a DOT drug test and you forbid him from driving. The fact is, until the driver is cleared by a Substance Abuse Professional (SAP), he has no business being around trucks, performing Safety-sensitive functions. Even trucks between 10,001 GVWR and 26,001 GVWR.

Driver Applications: The Three Imperatives

  • The app must be furnished by the motor carrier.
  • The app must be completed by the applicant/ driver.
  • The app must be signed by the driver.

Part 391.21 has a number of driver application requirements that must be followed.

Top Tip: All regulated drivers (even non-CDL) must list all of their previous regulated employers.

Top Tip: CDL drivers should provide a complete employment history for the last 10 years, explaining any periods of unemployment.

Part 391.23(a.) Investigation and inquiries.

Top Tip: First start with a CDLIS check — then get MVRs from respective, required states.

(Some experts even recommend doing CDLIS searches at every annual review.)

Commercial Driver’s License Information System (CDLIS) is a nationwide computer system that shows every license your driver has held in the past three years. From there, ordering required Motor Vehicle Records (MVRs) is easy.

Top Tip: Ask previous employers questions like:

  • Is the drive eligible for rehire?

  • Has the driver ever acted in a threatening or coercive manner?

  • Has the driver ever acted in an unsafe manner?

Know the requirements of the General Confidentiality Rule (49 CFR 40.321)

Top Tip: Get specific written consent from the driver. A mistake is using blanket forms where a driver signs off on a form and it is copied and sent to all previous employers.


49 CFR 40.25 (d) — If feasible, you must obtain and review this information before the employee first performs safety-sensitive functions. If this is not feasible, you must obtain and review the information as soon as possible. However, you must not permit the employee to perform safety-sensitive functions after 30 days from the date on which the employee first performed safety-sensitive functions, unless you have obtained or made and documented a good faith effort to obtain this information.

This means at least two or three documented attempts within the first 30 days of hire.

Mike detailed many other requirements in qualifying new DOT drivers and listed numerous traps and pitfalls.

Here is previous webinar from 2015:

Thank you for reading this.



John Taratuta is a trucking safety advocate and Risk Engineer. (989) 474-9599

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