Driver Qualification File (DQF) — 49 CFR 391

Every interstate motor carrier MUST maintain a DQ file on every driver who operates a CMV. Auditors look at these first.

What goes in the DQF

Document	Citation	When	Retention
Driver's application for employment	391.21	Pre-hire	Length of employment + 3 years after
Inquiry to previous employers (last 3 years)	391.23	Within 30 days of hire	Length of employment + 3 years
Annual inquiry/review of driving record	391.25(a)(b)	Within 12 months of hire, then annually	Length of employment + 3 years
Note relating to annual review of driving record	391.25(c)	Annually	Length of employment + 3 years
List of violations or certification of no violations	391.27	Annually	Length of employment + 3 years
Medical examiner's certificate	391.43	Pre-hire (within last 24 months); renewed every 24 months max	Length of employment + 3 years
Medical examiner's national registry verification	391.43(g)	Pre-hire	Length of employment + 3 years
Road test certificate OR equivalent (CDL, etc.)	391.31	Pre-hire	Length of employment + 3 years
Entry-Level Driver Training (ELDT) certification	380 subpart F	If applicable (new CDL after Feb 2022)	Length of employment + 3 years
Prior drug & alcohol test history (FMCSA Clearinghouse query for previous employers' records)	382.413	Pre-hire	3 years from query
Note re Safety Performance History records	391.23(j)	Pre-hire	Length of employment + 3 years
CDL copy / verification	391.11(b)(5)	Pre-hire + at each renewal	Length of employment + 3 years
Hazmat endorsement verification (if applicable)	383	At hire + each renewal	Length of employment + 3 years

Things that are NOT in the DQF (separate file)

• Drug & alcohol test results — kept in a separate, secure D&A testing file. 49 CFR 382.401.
• Hours of Service / ELD records — separate driver duty status file.
• Vehicle inspection reports — vehicle file, not driver file.
• Personnel / payroll — HR file.

The most common DQF deficiencies auditors find

1. Missing or expired medical examiner's certificate. A medical cert is valid for max 24 months. If expired by even one day, the driver is unqualified. Auditors check date stamps.
2. Annual MVR not pulled within 12 months of the prior pull. 49 CFR 391.25 says "at least every 12 months." Day 366 since last pull = violation.
3. No "Note relating to annual review of driving record" signed by a company official. 391.25(c). Often forgotten — pull MVR but no signed note.
4. No inquiry to previous employers for the last 3 years of employment. 391.23. Carriers skip this for "low-risk" hires; auditors don't care about your risk model.
5. No Safety Performance History. 391.23(d) requires you to ask previous employers for accident/D&A test info. Many carriers don't even know this is required.
6. Application incomplete. 391.21 lists required fields including: name + address, DOB, employment for last 3 years, violations for last 3 years, denials/suspensions, list of all driving experience. Common gaps: skipped employment gaps, no "explain unemployment" entries, missing signed certification of accuracy.
7. Road test certificate missing OR substituted incorrectly. 391.33 lets you use a valid CDL as equivalent — BUT only for the class of vehicle the CDL covers. If a Class A CDL holder is driving a Class B vehicle for you, you still need a road test for the Class B (or rely on previous-employer documentation).

DQF lifecycle

Pre-hire (day 0)
  ├── App + signed certification
  ├── CDL copy + class + endorsements
  ├── Medical cert verification (NRCME-certified examiner check)
  ├── MVR pull (initial)
  ├── Road test OR CDL equivalent
  ├── ELDT cert (if CDL issued after Feb 2022 + first-time issuance/upgrade)
  ├── PSP report (recommended, not required) — 5-yr crash + 3-yr inspection history
  └── Clearinghouse pre-employment FULL query

Day 30
  └── Previous employer inquiries (must be completed within 30 days)

Annually (every 12 months from hire date)
  ├── MVR pull
  ├── "Note relating to annual review" — signed by supervisor
  └── List of violations (driver certifies) OR cert of no violations

At medical cert expiration (max every 24 months)
  └── New medical cert filed

At CDL renewal
  └── Updated CDL copy

Separation
  └── File retained for 3 years after termination

Length of file & employment

"Length of employment + 3 years after" means: if you fire a driver after 5 years, you retain the DQF for 8 total years.

If you have a driver come back after a gap, you start a NEW DQF cycle but can reference the old one. Cleanest practice: archive old DQF + create fresh DQF for re-hire.

Where this skill fits in a typical X3 workflow

X3's dq-files.html page surfaces the driver's DQF state. The "compliance score" includes a DQF completeness metric. If a driver fails their annual MVR review, X3 fires a notification to the safety manager via send-compliance-notification and creates a checklist item.

If asked about specific deficiencies, walk the user through the 49 CFR 391 numbered list above and ask which they're missing.

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