Driver qualification file checklist (49 CFR 391.51)
Updated · Reviewed by Israel Margulies, founder and CEO of High Point GPS
A checklist for each driver's qualification file: the records the federal rule lists, the date each was received and when the next one is due, so a missing MVR or an expired medical card is caught before an audit.
Motor carriers must keep a driver qualification file for each driver they employ. 49 CFR 391.51(b) lists what goes in it: the employment application, motor vehicle records, the road test certificate or its equivalent, the annual driving record review, the medical examiner's certificate and a few other items.
Keep the file for as long as the driver works for you and for three years after. Some items, such as the annual MVR, the review note and the medical certificate, may be removed three years after they were made. Drug and alcohol testing records are kept separately under their own rules. This checklist follows the federal text; it isn't legal advice.
Driver qualification file
Fields: Driver name · CDL / license no. and state · Date of hire · Motor carrier · File reviewed by
At hire
- Employment application (391.21)
- MVR from each licensing authority (391.23)
- Road test certificate (391.31) or accepted equivalent license or certificate (391.33)
- Medical examiner's certificate (391.43), or for CDL drivers the CDLIS MVR showing medical status
- Note verifying the medical examiner is on the National Registry
Every year
- MVR from each licensing authority (391.25(a))
- Note of the annual review of the driving record (391.25(c)(2))
If applicable
- Skill Performance Evaluation certificate (391.49) or medical exemption
- Medical variance documents
- Dates to track. Medical certificate expiry, next annual MVR and review, license expiry.
- Retention. Keep the file while the driver is employed and for three years after (391.51(c)); some items may be removed three years after they were made (391.51(d)).
Fill it in the right way
- Start a file for each driver at hire with the application, MVRs and road test record.
- Add the medical examiner's certificate and the National Registry check.
- Write down the expiry and due dates for the medical card, license and annual MVR.
- Each year, get the MVRs, review the driving record and file the signed note.
- Check the file against this list before any audit, and keep it three years after the driver leaves.
Tips
- Set reminders 60 days before each medical certificate and license expires.
- Keep the annual review note signed and dated; the MVR alone isn't enough.
- Store drug and alcohol testing records separately from the qualification file.
- Audit a sample of files every quarter, not only when an audit is coming.
Do it in FleetZap
- Driver license and medical certificate expiry dates can be tracked as compliance items in FleetZap, with reminders.
- Each truck's inspections, defects and repairs stay on its own record.
- FleetZap records checks and repairs; it doesn't manage driver files or certify compliance.
Sources
FleetZap Maintenance
Work orders, PM, parts, compliance, assets and KPIs. Explore FleetZap Maintenance.
Frequently asked questions
What goes in a driver qualification file?
Under 49 CFR 391.51(b): the employment application, MVRs from each licensing authority at hire, the road test certificate or equivalent, the annual MVR and review note, the medical examiner's certificate (or CDLIS MVR for CDL drivers), any SPE certificate or medical exemption, and the National Registry verification note.
How long must a driver qualification file be kept?
For as long as the driver is employed and for three years after. Some items, like the annual MVR, the review note and the medical certificate, may be removed three years after they were made.
Do drug and alcohol test records go in the DQ file?
No. They're kept separately under their own rules.
How often do you review a driver's record?
At least once every 12 months, with an MVR from each licensing authority and a signed note of the review.