What Goes in a US Driver Qualification File

The 391.51 core (at hire and ongoing)

Part 391.51 is the filing rule. It tells carriers which pieces of evidence must exist for each driver they use, and how long to keep them. Safety teams that memorize a vendor checklist without reading 391.51 miss updates and exemptions.

Treat the list below as the skeleton. Your written safety program can require more (customer inductions, FAST, company policies). It cannot require less than the rule that applies to that driver.

• Employment application completed as 391.21 requires, with dates and signatures intact.
• Motor vehicle record from each state licensing authority inquired under 391.23(a)(1), placed in the file within the 30-day window.
• Road test certificate (391.31) or the CDL / equivalent the carrier accepted under 391.33, matching the vehicle class the driver will operate.
• MVR from each annual state inquiry required by 391.25(a).
• A note that the annual review of the driving record was performed (391.25(c)(2)). Pulling the MVR is not the review.
• The driver’s list of violations furnished at least once every 12 months (391.27).
• Medical examiner’s certificate and/or CDL medical certification status, as currently required for that driver.

What often sits beside the DQ file

Not every driver document is a 391.51 item. Mixing program files into the operational DQ packet creates two problems: auditors cannot find the qualification evidence, and privacy rules for drug-test results get broken.

• Part 382 / Part 40 drug and alcohol records: restricted program file, limited access.
• Clearinghouse consent and query evidence: keep a pointer in the DQ file; raw violation detail stays controlled.
• Hours-of-service logs, ELD data, and supporting documents: HOS program, sampled on a different clock.
• Personnel items (payroll, benefits, I-9): HR file, not the qualification packet.
• Travel documents (passport, FAST): dispatch and border tools, with their own expiries.

The 30-day hire clock people miss

Several 391.23 inquiries must be launched promptly, and the resulting MVR is expected in the file within 30 days of the date employment begins. A complete-looking folder that still has “MVR pending” sticky notes at day 45 is a finding waiting to happen.

If a state returns nothing, document the good-faith attempt and the result. Silence is not evidence unless you wrote down what you asked, when, and what came back.

How to assemble a packet an auditor can sample

Name every document by type, not by filename (“scan3.pdf”). Put issue and expiry dates on medical and licence items. Keep superseded scans archived, not stacked on top of the current one. One driver, one packet, same order every time.

FAQ

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