We recently talked about proper documentation and file management for fleet managers here at the QuickTSI blog. No matter what size your fleet is, you need to ensure you follow all FMCSA guidelines on compliant documentation. In today’s post, we will look at the specific FMCSA guideline that covers documentation (Part 391) and the importance of digitizing your Driver Qualification Files (DQF) and Safety Performance History (SPH).
Today, in Part II of our series, we will look at specific records and what each entails from a compliance perspective. Our first document will be medical certificates. Every truck driver is required to have a medical certificate on file, but what are the specifics? Let’s dig a little deeper.
Medical Certificates
All truck drivers must have a Department of Transportation (DOT) medical evaluation. They can receive these evaluations either as often as a medical examiner deems necessary or every 24 months, whichever comes first. The medical certificate is mandated to ensure that truck drivers are physically able to carry out their jobs and operate commercial motor vehicles. Updated medical certificates must be kept in the driver’s DQF.
Fleet managers must keep carful track of the variance renewals required among their truck drivers, especially if they run a large fleet. When a truck driver has a physical impairment that impacts their ability to safely operate their fleet vehicle, they must get a state-issued “variance” document that they carry with them wherever they operate their CMV.
For operators that have impaired or missing limbs, a special type of variance, called a Skill Performance Evaluation (SPE) is required. This is separate from a truck driver simply needing more frequent medical examinations. Conditions that may require more frequent medical examinations include hypertension, heart disease, diabetes, and sleep apnea.
All variances, whether SPE or otherwise, must be renewed periodically. It is critically important that fleet managers keep close eye on variance expiration dates; they should be tracked right along side medical certificate expiration dates. Failure to do so could result in a violation, which no one wants.
Keep Violations at Bay
No one wants to be on the receiving end of a violation, especially when it hits your bottom line or puts you in the government’s eyesight. Yet violations related to documentation are some of the most prevalent, and easily preventable.
In 2020, for example, over 54,000 truck drivers were cited for not having a valid medical certificate with them during roadside inspections. That would make “medical certificate violations” one of the most common violations of 2020. Now consider that a single violation for a missing medical certificate can cost thousands of dollars. These should be easily prevented within your organization.
The best way to stay ahead of violations is to keep a close eye on expiration dates. You need to stay on top of the validity of the documents you or your truck drivers use. Also keep schedules in mind. If you know an expiration is coming up, have it worked out ahead of time with the truck driver. If they are out on the road when something expires, you are running with too much risk.
Look at Expiration Dates
Far too many fleet managers and truck drivers are cited because they don’t keep an upcoming expiration date in mind. It goes without saying that truck drivers must always have a valid license and all required endorsements and/or classes up-to-date and verifiable with them.
Of course, other regulations are governed by the state these companies operate in. Commercial drivers’ licenses are only valid for a specific amount of time and under accordance with state licensing laws. In Ohio, for example, CDLs must be renewed every 8 years. In California it is 5 years. The state your trucking operation is based out of will govern that number.
Expiration dates are another example of easily avoidable violations. Expired CDLs was in the top five for most violations issued in 2020. Most out-of-service orders are also generated because of an expired CDL. Expired CDL violations can also run into the thousands of dollars per violation. They aren’t cheap to be at the receiving end of.
Annual Documentation Requirements
Truck drivers and trucking companies are subject to compliance, regulatory and documentation requirements that must be renewed on an annual basis. The number one record that we all deal with is the Motor Vehicle Report (MVR). MVRs are important because they contain a record of all moving violations, crashes, suspensions, and/or revocations.
For truck drivers specifically, there are additional questions. Are there any violations regarding hazardous materials? Furthermore, were there any violations on the MVR that showed a general disregard for public safety? Fleet managers will look specifically for speeding, careless driving, reckless driving, and drug and alcohol violations.
All truck drivers will have an annual MVR placed in their DQF. The fleet manager or other member of operations or management who conducts the annual review, and the date, should also be noted along with the inspection itself.
It is important to note that truck drivers are individually required to report an annual list of moving violations that occurred in the prior 12-month period. Truck drivers must individually certify if they have no new moving violations on their MVR. At the outset of an annual review, it is likely the fleet manager provides their truck drivers with certification forms to fill out. This form will then be kept in their DQF.
Risk Reduction Matters
In the end, this is all about risk reduction. The government uses specific tactics to get truck drivers and trucking companies to reduce risk. MVR monitoring and the auditing of truck driver files are part of this ongoing strategy. And it is about more than just the government. Trucking companies are required to run annual MVRs, but it has become standard practice for them to randomly check their truck drivers’ MVR periodically throughout the year. They don’t want to be surprised at the end of the year.
Because if a truck driver receives a license suspension because of a DUI while off the clock, fleet managers can’t wait until the end of the year to act on that information. Without an MVR check, they are relying on their operators to come clean or wait it out until the end of the year. That’s why many fleet managers decide to enroll their drivers in MVR monitoring programs.
Vendors provide solutions for continuous MVR monitoring that allows the fleet manager to receive new driving record information as it becomes available. This takes the guesswork out and prevents the manager from having to periodically pull MVRs. If they forget, who does it? An MVR monitoring solution prevents this and reduces risk.
In many cases, MVR monitoring vendors can also keep tabs on your truck drivers’ medical certificates. When the certificates get updates, the vendor can let you know. This fulfills your annual requirement to run an updated MVR on each of your truck drivers and lets you focus on running the fleet.
Driver File FAQs
Many trucking companies have questions about their truck driver files. New truckers and owner-operators can be thrown off by the filing requirements. One common question is whether or not there are any categories of CMV operator who is exempt from CDL requirements. The answer, per Part 383.3 of the FMCFRs, only farm vehicle, emergency vehicle, or snow and ice removal vehicles are subject to exemption and even then, it is at state discretion.
Another common question is if the age requirement in FMCFR Part 391.11 applies solely to CMV truck drivers involving interstate commerce. The answer is no. And let’s remember, there are some grumblings in Congress of lowering the truck driving age for interstate commerce. With the trucking sector experiencing another truck driver shortage (or perhaps an ongoing one), the industry needs as many applicants as it can get.
There are many other important questions related to driver qualification files. It is important that anyone operating a commercial motor vehicle is familiar with a DQF and what goes into it. It is vitally important to stay up to date on expiration dates and other requirements related to your licensing and endorsements. Keep documentation at the top of your truck driving priority list and you will be sure to keep unnecessary expenses at bay. Don’t let violations nickle and dime you to death, keep your files straight and set yourself up for success.