Your driver qualification files, or DQ files, are one of the most crucial things you need to keep your fleet rolling. A driver file is required by both Transport Canada and the US Department of Transportation (DOT) for every one of your drivers. These files act like snapshots of a driver’s operating history and skills. If that snapshot is blurry or incomplete, your fleet could face serious consequences from the government.
No fleet ever plans on operating with subpar DQ files, of course. From the number of violations handed out by the FMCSA every year, however, it’s something that happens all too often. So how do you stop your fleet from becoming yet another statistic in this regard?
DQ file maintenance needs to be treated as an ongoing process. Your team should be aware of what can put a DQ file out of compliance, and what they need to do before that happens. Here are three things to watch for that could put your fleet on the penalty list.
Out of date documents
A complete DQ file isn’t going to stay that way forever. Critical documents, such as a drivers license or medical certificate, all need to be renewed sooner or later. And since your drivers all acquired these documents at different times, your team needs to remain on top of expirations and renewals. Fines for expired documents can be hefty ($6,269 alone for an expired drivers’ license, in some jurisdictions).
Here are just a few items that need to be renewed, and how often:
- Class A CDL license: on average, every five years. If a driver is over 45, it’s often less than that.
- Medical certificate: anywhere from two months to five years depending on jurisdiction.
- TWIC card: every five years.
- Dangerous goods/HAZMAT endorsement: every few years.
While various government agencies may send out printed reminders to your drivers about expiring documents you should also be reminding yourself. Set up digital flags on your files, so your team is aware if a driver needs to renew crucial compliance documents, and then take appropriate action to make sure this happens on time.
Incomplete FMCSA Clearinghouse information
The Drug & Alcohol Clearinghouse, to an inexperienced user, can be confusing. It’s not always obvious when and how the Clearinghouse must be used, what information is needed, and the consequences of submitting an incomplete or incorrect query. And yes, the consequences are serious: your employee can face civil and even criminal penalties for Clearinghouse violations.1
Here are some of the most common causes of Clearinghouse violations.
- Allowing drivers to start before the Clearinghouse results are received. Fleet employees are sometimes unaware that a query must not only be submitted through the Clearinghouse before a driver can begin hauling for a fleet, the results must be delivered, as well.
- Missing or lost driver consent forms. All consent forms must be carefully tracked and retained, even after the query results have been received. If one is missing, penalties can be incurred.
- Missing drug and/or alcohol tests. All drug and alcohol tests, including negative ones, must be submitted to the FMCSA.
- False information. Most the time, false information in Clearinghouse isn’t malicious. It’s often a case of incorrect or misunderstood information instead. Regardless of how or why false information was put in the Clearinghouse, though, your fleet can be penalized for it.
- Selecting the incorrect query. Choosing the correct type of Clearinghouse query is important to ensure compliance with regulations, maintain road safety, make informed hiring decisions, access relevant information efficiently, and meet legal obligations. If the wrong query is one, crucial information could be missed.
You might have noticed: these violations are for things which are easily overlooked. A robust digital tracking system can make it easier for your team to be aware if they’re about to submit incorrect or missing information to the Clearinghouse. Pair that with rigorous Clearinghouse training, and human errors from your team will be greatly reduced.
Incomplete background checks
Regardless of how capable a driver may appear, you’re required by law to perform a full background check before you hire them. It’s not enough to go on your gut instinct. Doing so could make you liable for future lawsuits.
A complete background check should include:
- A Motor Vehicle Report (MVR)
- A previous employer employment check
- A pre-employment query in the FMCSA Clearinghouse (which is why it’s so crucial for Clearinghouse information to be correct).
You need to be aware of any moving violations, accidents, drug and/or alcohol abuse and SAP (Substance Abuse Program) results before you put a driver in one of your rigs. The only way to know to the best of your ability is to perform a full background check. Make sure you have a dedicated team for this. Implement software that will allow you to track if and when a background check was requested, its status, and results as well. This way, your DQ file will be in good standing, regardless of what happens next.
Consequences of DQ file errors can be dire. The FMCSA treats this as a serious violation, with penalties in the thousands of dollars. Your best defense is to have a robust digital tracking system along with a dedicated compliance team. If you need to bolster one or the other, drop us a line to find out how we can help.