Fleets all over the nation must contend with compliant truck driver qualification files. And here’s the thing: Doing so has always been a bit of a challenge for trucking companies. Even the best fleet manager may find outdated documents, error-filled documents, and much more. In fact, problematic truck driver files are such an issue that they account for over a third of all FMCSA-acknowledged fleet violations.
And now the problem is compounded by offsite audits. We’ve talked before about the importance of inspections, but with offsite audits, the compliance urgency is now. It was bad enough when inspectors found insufficient documents in your own files, but with offsite audits coming more frequently, the risk has grown. Motor carriers who are unprepared may find themselves on the wrong in of a compliance violation.
Remember, if you get called for an offsite audit, you only have 48 hours to get the proper documentation turned over. Trucking companies used to have two weeks, but that is no longer the case. You also used to be able to submit paper documents. That has also changed. You now have less time and must submit everything in a digital format. Does your fleet have a digital compliance solution in place? Many don’t, but you must be prepared. First, let us dive into the specific regulation that covers driver qualification documentation.
Examining Regulation Part 391
FMCSRs regulation Part 391 is written to ensure that all motor carriers operating under federal jurisdiction are qualified to operate. The records governed by Part 391 specifically apply to truck driver health, professional experience, and driving record. It also does not matter how large or small your fleet is, or what kind of vehicle you operate or load you haul – Part 391 applies to every trucking company involved in interstate commerce meeting the specific regulations if they:
- Operate vehicles running more than 10,001 pounds.
- Carry 9 or more passengers.
- Transports hazardous materials.
For those running as owner-operators, it is important to remember that you are both the boss and the employee of your trucking company. You need to ensure you perform the duties mandated by federal authorities, whether it is just you or you and other employees. You are required to follow all the rules even if you are the only truck driver on your payroll.
You also need to ensure you comply with the timelines set out by the FMCSA. According to Part 391, all compliant files must be kept at the ready for the entirety of one’s employment with a trucking company, plus an additional three years beyond initial employment. Staying in compliance goes beyond simply having the file, however. The file must also be correct.
Examining DQF and SPH
There are two aspects of your documentation that are especially important. They are your Driver Qualification File (DQF) and Safety Performance History (SPH). These documents will give inspectors a clear idea of your documentation and safety history in the event you are audited. Your driver qualification file specifically should include:
- DOT-Compliant application.
- State MVRs where a truck driver held a CDL or permit going back three years.
- Road test certificate.
- Photocopy of the truck driver’s CDL.
- Valid Medical Examiner’s Certificate.
- Medical Examiner verification (within the registry).
- Skill performance evaluation certificates.
Next up, you want to take a close look at your SPH. Your SPH should include a copy of the truck driver in question’s written authorization to contact prior employers about any history with alcohol or controlled substances. Second, you need to make sure the SPH file contains responses from all previous employers, as well as all attempts you have made to get in touch with them.
Keep in mind that even when you have all your files in order, you still need to take additional steps, such as keeping a close eye on expiration dates. This is especially true if you operate a large fleet. Keeping track of when things expire, in and of itself, can be a tedious and time-consuming task, yet it is just one you need to ensure you keep an eye on to keep yourself in compliance.
Compliance Goes Digital
In addition to making sure your files are all in order, you also need to worry about digitizing all of them. With offsite audits becoming the norm, whether it be for a safety or compliance review, motor carriers have got to set up a digital filing solution. Fortunately, there are plenty of third-party vendors out there who work specifically with trucking companies on digital file management.
Paper is increasingly problematic because the FMCSA specifically requires trucking companies to submit digital files during an offsite audit. Paper files are no longer even an option. So, if you are still keeping paper files and find yourself at the receiving end of an offsite audit, you’ve got to audit, scan, and upload all the requested documentation within 48 hours.
Imagine if you have a large fleet. Preparing, scanning, and providing all those documents might seem like an impossible task. It doesn’t need to be that way, however. You should look at digital file documentation as more than just a compliance requirement. Consider that digital files also equate to more security.
Digital Files are Secure Files
You have probably noticed that a lot of sensitive information goes into DQFs and SPHs. Imagine the damage if this information were to be compromised in some way. If you are running with paper files, they are far more susceptible to potential misuse or loss. And if there is a breach or you fail to protect your DQF or SPH files, you could on the receiving end of some hefty FMCSA fines.
That is why a secure online storage environment might be exactly what you need. Because of the sensitive nature of SPH files, make sure only those involved in the actual employment decision can access the files. You also want to ensure you are operating within an online compliance environment. Your online system must also meet Part 391 guidelines.
It is also important to consider that online file storage will protect against accidents like fires, flooding, or other disasters which could destroy paper records. Water damage is one such accident that is far more common than you think and can wreak havoc on paper records. If you lose your records in an accident, you will be out of compliance until you can re-create your records, making you susceptible to an audit at any time.
How to Make the Transition
Digital filing solutions may not be federally mandated, but they are a requirement if you want to operate a smart and efficient fleet not burdened by avoidable violations. Offsite truck audits grew by 400% between 2019 and 2020. That is a huge jump. Even worse, some estimates put the number of trucking companies not ready at nearly 50%.
When you are ready to jump over the digital divide, you’ve got to conduct due diligence. You need to identify a solution that is right for your operation. Moving from a paper DQF process to a digital solution requires more than the simple act of scanning pieces of paper into your computer. Remember, this is sensitive information, so the process you use to migrate must be both secure and reliable.
You will likely choose a vendor that provides a cloud environment for their services. Secure cloud environments backed by robust enterprise software systems aren’t cheap, but they give fleet managers peace of mind. They ensure you run a smooth, violation-free, and efficient operation. They can also be easily customized with automatic alerts and modular interfaces.
Start the Transition Properly
The last thing you want to do is begin moving your paper records to digital without first conducting a compliance audit. Take a fine-toothed comb through your current paper records to make sure everything is up to date. This is where you should catch problems and get 100% up to speed on expiration dates and other critical licensing factors.
Many vendors who provide digital DQF solutions provide ways to identify missing and/or expired documents. Complex systems can determine if there are gaps in expiration dates and most other documentation problems. One thing to note is that if you find there is not a record for a truck driver, or if you plan on bringing a new truck driver on, you are not required to create a paper record. You can create it within the digital system, and it will be fine for an inspector.
Once it is done and you have fully converted to a digital system, offsite audits will become a cinch. Imagine easily downloading and transmitting files and producing them for inspectors at the drop of a hat. Modern trucking companies and smart fleet managers can hand over files confidently, knowing that action has already been taken to ensure compliance.