As part of FMCSA’s Driver Qualification File (DQF) requirements, motor carriers must not only obtain an updated Motor Vehicle Record (MVR) annually but also document the review of that record.
Key Regulation: 49 CFR § 391.25(c)
(c)(1) — A copy of the motor vehicle record obtained under § 391.25(a) must be maintained in the driver’s qualification file. (c)(2) — In addition to the record itself, the DQF must also contain a note, including: The name of the person who performed the driving record review The date on which the review occurred
Why This Requirement Matters
Demonstrates Compliance
It confirms that carriers are actively monitoring driver eligibility according to FMCSA standards.
Audit Readiness
During audits or inspections, carriers can show who reviewed the MVR and when.
Promotes Accountability
Assigning a reviewer and logging the date ensures follow-through and accountability.
Supporting Guidance & Best Practices
The FMCSA recognizes that automated systems or employer notification systems (ENS) may be used to satisfy this requirement, provided they: Capture who reviewed the record Record the review date Retain documentation in a retrievable format (e.g., computer printouts that can be produced upon request, per 49 CFR § 390.31) FMCSA The FMCSA’s Driver Qualification File Checklist reiterates the need to include both the MVR and the reviewer note annually in the file. CSA Compliance
Regulatory References
[49 CFR § 391.25 — Annual Inquiry and Review of Driving Record (eCFR)] [FMCSA Guidance on Employer Notification Systems and Electronic Recordkeeping] FMCSA
[FMCSA Driver Qualification File Checklist (DQF Checklist)]
