Personnel File vs DQ File — What Goes Where

The Driver Qualification File (DQF) and the personnel file are separate documents with different purposes, regulators, and retention periods. Mixing them is the #1 cause of DQF audit findings.

DQF (regulated by FMCSA)

Per § 391.51(b), exactly these 12 documents:

1. Driver's employment application (§ 391.21)
2. Inquiry to prior employers (§ 391.23)
3. Inquiry to state driver licensing agencies (§ 391.23(a)(1) for MVR)
4. Annual review of driving record (§ 391.25)
5. Annual driver's certificate of violations (§ 391.27)
6. Medical examiner's certificate (§ 391.43) — current
7. Medical examiner verification (§ 391.51(b)(7)) — National Registry number
8. Road test certificate OR equivalent (§ 391.31, § 391.33)
9. Safety performance history (Previous Employer Information Request)
10. Medical variance/exemption (if applicable)
11. Driver's license copy
12. Entry-Level Driver Training certificate (§ 380.609) — post-2/7/2022 hires

Personnel file (HR / state law)

• Pay rate, payroll history
• Tax withholding forms (W-4, I-9)
• Health insurance enrollment
• 401(k) records
• Performance reviews
• Disciplinary actions
• Driver bonus + incentive history
• Personal information (emergency contact, beneficiary)
• Workers' comp claim history
• ADA accommodation requests

What does NOT go in either

• Drug & alcohol test results → separate file under § 382.401(b) (retention 5 years)
• Workers' comp claim documents → separate per state requirements

Retention

• DQF: Duration of employment + 3 years after termination
• Personnel: State law varies (typically 3-7 years post-termination)
• D&A: 5 years (longest), 1 year for negatives

Audit consideration

At an FMCSA compliance review, auditors request DQF. They do NOT have authority to review personnel files. Keeping them separate protects both your driver privacy and audit clarity.

CFR citations

• 49 CFR § 391.51
• 49 CFR § 391.53
• 29 CFR § 1602

How Compass surfaces this

This skill is searchable in Compass Ask and runs against the carrier's actual fleet data when invoked from the relevant tracker. Read-only; no actions taken without explicit user approval.

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