Image Courtesy of J. J. Keller & Associates, Inc.

Image Courtesy of J. J. Keller & Associates, Inc.

Using the DQ file to your advantage

Your driver qualification files are a risk management tool. They have the potential to reduce the likelihood of an unfit driver operating your CMV.

Provided below are Driver Fitness BASIC roadside inspection violations and how proper DQ file management can assist:

Violations


Proactive measures


At hire


Existing drivers

 License violations:

  • Not having the appropriate license, class, or endorsement

  • Not following restrictions

  • Operating a CMV while disqualified

  • Ensure proper licensing for the vehicle(s) to be assigned

  • Review the initial motor vehicle records (MVRs) for:

    • Current license, classes, and endorsements

    • Restrictions, including air brakes and in-state only

  • Determine if a non-CDL commercial class (e.g., chauffeur’s) license is needed based on state of residency

 

  • Know which license is required for all current and future vehicles to be assigned

  • Request and review an annual MVR for:

    • Current license, classes, and endorsements

    • Restrictions, including air brakes and intrastate-only

  • Use an MVR monitoring service to alert you of loss of driving privileges or an expired license

  • Create a tickler system to:

    • Monitor license expiration dates

    • Remind drivers to renew licenses

    • Confirm that drivers renewed licenses and endorsements

 Medical violations:

  • No current medical card in the driver’s possession

  • An expired medical card

  • CDL drivers with a “Not medically certified” status or downgraded license

 

  • Obtain a copy of the current medical card (non-CDL)

  • Request a CDL driver’s MVR before operating a CMV to verify medical status

  • When requesting a new-hire medical exam of a CDL holder:

    • Obtain a copy of the medical card, and

    • Request an MVR within 15 days of the exam to confirm the exam appears on the record

  • Verify the medical examiner appears on the National Registry of Certified Medical Examiners

  • Create a tickler system to monitor medical exam expiration dates

  • Remind drivers to renew medical cards

  • Request a copy of the medical card following all physical exams

  • Verify the medical examiner appears on the National Registry of Certified Medical Examiners

  • Request an MVR within 15 days of a CDL driver’s exam

 Is not at least 21 years of   age (federal)

  • Confirm the date of birth on the driver’s application

  • Review the driver’s MVR for:

    • Date of birth

    • In-state-only restrictions due to age

  • Request a copy of the plastic license to confirm date of birth

  • Limit routes to in-state commerce for younger drivers

 


English-language requirement

Another Driver Fitness violation uncovered during roadside inspections is the inability to speak and write English well enough to converse with the public, understand traffic signs and signals, respond to official inquiries, and make entries on reports and records.

This violation probably isn’t one you’ll uncover through your DQ files, but rather during the hiring process.

Many carriers use a phone or in-person interview as a first step for drivers who have English as a second language. During the interview, drivers are asked a series of industry-related questions that might mimic what an officer would ask during a stop (e.g., logging experience, driving experience, previous routes). They should be able to answer without difficulty.  

Specific to written language, carriers often use new-hire documents as a means of testing the driver’s abilities. If the driver has no difficulty completing the new-hire forms (safety performance history, application, Clearinghouse consent, orientation documents, etc.), a carrier might be satisfied that the driver can complete the necessary paperwork in English per the regulations.

Some carriers use an English-language test, but consult with an attorney before taking this route, to ensure you are not violating any employment laws as a result.

Other best practices

A few other best practices may spare your carrier from Driver Fitness BASIC violations.

  • Request a Pre-employment Screening Program (PSP) report prior to hiring a driver.  PSP reports provide the past three years of roadside inspections and five years of crashes. An applicant’s safety history helps carriers identify trends in roadside inspection violations. For example, a carrier might find that a driver took risks by operating vehicles when not licensed to do so or without medical certification.
  • Assist drivers with the submission of their medical cards to the state driver’s licensing agency. This might include the use of a fax, scanner, or computer.
  • Train those who assign routes and vehicles on licensing requirements.
  • Monitor roadside inspection data to identify areas to address.

Kari DuBois, Vice President of Client Service at J. J. Keller & Associates, Inc. shared, “The motor carrier is responsible for ensuring that only qualified individuals operate their vehicles. A pattern of Driver Fitness BASIC violations may be an indication that DQ files are either not being maintained or not used for their intended purpose.” She suggested, “If your Driver Fitness BASIC score is high, it may be time to review your DQ file procedures.”

CSA 101

CSA was designed by the Federal Motor Carrier Safety Administration (FMCSA) to identify high-risk motor carriers. Roadside inspection violations found to have a correlation to causing a crash are categorized by BASIC and run through an algorithm to calculate a BASIC measure. For the Crash Indicator BASIC, an accident’s circumstances (injury, towing, fatality, hazmat spill) are used in the math. Each individual BASIC measure is then compared against similar carriers and assigned a percentile ranking to arrive at a carrier’s BASIC score.

If your BASIC score exceeds a predetermined threshold, FMCSA will intervene to help get you back on track. This may mean:

  • A warning letter — FMCSA’s correspondence alerts you to address specific compliance areas;
  • Target roadside inspections —   Officers will focus on specific issues based on your CSA scores; or
  • An investigation — Enforcement may perform a focused audit of problem areas or a full-blown compliance review.

If an acute or critical violation categorized under a BASIC is found during an investigation, an alert status will be placed on the BASIC for a year.

Note that violations found during any investigation has the potential to result in fines.