Driver qualification file checklist (49 CFR 391.51)

A motor carrier must keep a driver qualification file, usually called a DQ file, for every driver it employs who is subject to Part 391. Auditors ask for these files first, because they are quick to check and often incomplete.

This checklist covers the core contents. State rules and your own situation can add items, so read the section linked above too.

What goes in the file

Item	What it is	Rule
Employment application	A completed application with the information the rule requires, signed by the driver	49 CFR 391.21
Motor vehicle record at hire	A driving record from each state where the driver held a license in the past 12 months	49 CFR 391.23
Previous employer inquiries	Safety performance history requests to employers from the past three years, or a record of your good-faith attempts	49 CFR 391.23
Road test certificate	A completed road test certificate, or a copy of the driver’s valid CDL, which the rules accept in its place	49 CFR 391.31 and 391.33
Medical examiner’s certificate	A current certificate, with the medical examiner’s information verified as the rule requires	49 CFR 391.43 and 391.45
Annual driving record review	A current driving record at least every 12 months, with a note that you reviewed it	49 CFR 391.25

Check the current text of 391.51 for the full list, including any additional items that apply to your drivers.

Related records kept alongside the file

These are not always stored in the DQ file, but an auditor will ask for them in the same request:

• Clearinghouse query records and the driver’s consent. See our Clearinghouse annual query guide.
• The pre-employment drug test result, before the driver’s first safety-sensitive task.

How long to keep it

Keep the file for as long as the driver works for you and for three years after. Section 391.51 lets you remove some items, such as old annual driving record reviews and expired medical certificates, three years after they were completed. Keep the application, road test records and similar items for the full period.

Gaps auditors find most often

1. No motor vehicle record at hire, or one pulled after the driver started driving.
2. No annual review, or a driving record older than 12 months.
3. An expired medical certificate, often discovered at roadside rather than in the office.
4. Missing previous employer inquiries, with no record that you tried.
5. An incomplete application, such as a missing employment history.
6. No road test certificate and no CDL copy.

A simple routine that keeps files complete

• Give every driver a folder with the same structure, and keep a copy of each document the day you receive it.
• Put every expiry date and annual review date on a calendar or tracker, with alerts 60, 30, 14 and 7 days ahead.
• Review the whole roster once a month, listing every file that is missing something.
• Never mark a document as valid until a person has read the actual dates on it.

DotReady does this for you: it reads the dates from an uploaded document, shows them next to the image so you can confirm them, and warns you before anything expires.