One of the required documents that must be maintained in the Driver Qualification (DQ) file is a copy of the driver’s license. This requirement is tied to 49 CFR §391.33(b), which addresses the equivalent of a road test when a driver presents a valid commercial driver’s license (CDL) or certificate.
Key Regulation: 49 CFR §391.33(b)
According to FMCSA:
If a driver presents a valid driver’s license or certificate that is accepted by the motor carrier as the equivalent of a road test, the motor carrier must:
Retain a legible copy of the license or certificate in its files
Place the copy as part of the driver qualification file
This ensures that proof of the driver’s licensing status and testing equivalency is pr
Practical Application for Motor Carriers
Motor carriers must ensure they:
Collect and retain a copy of each driver’s valid driver’s license (front and back if applicable).
Accept electronic uploads if available:
Drivers may upload a scan of their license directly.
Carriers may also send drivers a secure link for smartphone upload.
Confirm that the license:
Is valid and unexpired
Matches the driver’s qualifications and endorsements for the type of CMV being operated
Why This Requirement Matters
Serves as documented proof of driver qualification.
Ensures compliance when the CDL is used as a substitute for the road test.
Provides evidence during audits that the driver was properly licensed.
Protects carriers from liability if questions arise about driver eligibility.
Related FMCSA Guidance
Driver Qualification Files (DQ Files)
FMCSA requires carriers to maintain specific driver documents in a DQ file, including a copy of the CDL when used as road test equivalency.
Source: FMCSA – Driver Qualification File Checklist
Road Test Alternatives
A valid CDL is accepted as equivalent to a road test if it authorizes the driver to operate the vehicle type in question.
Source: 49 CFR §391.33 – Equivalent of Road Test (eCFR)
Official FMCSA Regulatory Reference
49 CFR §391.33(b) – Equivalent of Road Test
