Do You Have a DQ File? Driver qualification requirements apply to all drivers, no matter how big or small the company. By Thomas Bray, Editor, J.J. Keller & Associates The driver qualifications regulations, which are found in Part 391 of the FMCSA regulations, apply to all interstate drivers and most intrastate drivers that operate a commercial motor vehicle no matter whether your company employs one driver or 1,000.
Its part of the safety audit when you first get your authority. Whether you are a one man show or a company that employes 1,000s YOU MUST have a driver qualification on file. An owner op has to even perform a road test on himself stating he thinks he is qualified to operate the motor vehicle.
Actually, the CDL serves that purpose according to the regulations. In other words, as long as the state road tests you for your CDL in the type and class vehicle which you will be operating, your CDL is proof of a road test. Tankers and doubles/triples are exempted because there is no road test for those endorsements...so if you are going to O/O and pull a tanker or doubles/triples, you might need to look into option 2: In other words, if you went to work for a tanker company 2 years before you bought your truck and got your authority, you'd be fine just using that proof of the road test. The carrier still reserves the right to make you take a road test, though...even if you have a valid CDL or a proof of road test from a previous employer. Most of them do, just to cover their rears...err on the side of caution.
I don't have a JJ Keller DQ file. I have a made up one. It was fine for my safety audit. It has name and list of previous employers a copy of my DL. All done in Word.
