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Driver Qualification File Audit - 49 CFR Part 391

Driver Qualification File Audit - 49 CFR Part 391

Audit each commercial driver qualification file for required documents under 49 CFR Part 391, including application, MVR, medical certificate, road test, and Clearinghouse query records, to identify missing, incomplete, or expired items before an FMCSA audit.

Audit Setup and Driver Identification

  • Driver file is correctly labeled with full name and employee/driver ID
  • Driver type and status are documented
    Verify whether the driver is active, inactive, terminated, or seasonal, and whether the file is expected to contain current qualification records.
  • Audit date recorded
  • Auditor name and signature captured
  • File review scope confirmed
    Confirm the audit covers the complete qualification file and any required supporting records maintained separately.

Driver Application and Employment Record

  • Driver employment application is present and complete
    Verify the application includes required employment history, address history, and signature/date where applicable.
  • Application is signed and dated by the driver
  • Employment history gaps are explained
    Check for unexplained gaps in employment history and note any missing prior employer information that could affect qualification review.
  • Previous employer safety performance inquiries documented, if applicable
    Verify any required prior employer inquiries or responses are retained in the file when applicable to the driver and carrier process.
  • Discrepancies or missing application data documented

Licensing, MVR, and Driving Record

  • Valid CDL or required driver license is on file
    Verify the license is current, appropriate for the vehicle class, and matches the driver identity in the file.
  • License expiration date recorded
  • Motor Vehicle Record (MVR) is present
    Confirm a current MVR is retained in the file and covers the required review period per company policy and applicable regulation.
  • MVR review date is within required interval
    Verify the MVR is current and reviewed at the required frequency for ongoing qualification monitoring.
  • Driving violations or disqualifying events documented and addressed
    Check whether any violations, suspensions, or disqualifying events are documented with follow-up action as required.

Medical Qualification and Road Test

  • Medical examiner's certificate is present
    Confirm the current medical certificate is on file and legible.
  • Medical certificate expiration date is current
  • Medical examiner listed on certificate is authorized
    Verify the certificate identifies a valid medical examiner and the certificate appears complete and unaltered.
  • Road test certificate or equivalent qualification record is present
    Confirm the file contains a road test certificate or acceptable equivalent documentation, signed and dated as required.
  • Road test documentation identifies vehicle type and evaluator

Clearinghouse, Drug/Alcohol, and File Readiness

  • FMCSA Drug and Alcohol Clearinghouse query record is present
    Verify the required query documentation is retained in the file and matches the driver identity.
  • Required query type and date are documented
    Confirm the file shows the query date and whether the query was limited or full, as applicable to company process.
  • Missing, expired, or inconsistent documents identified
    Record any deficiencies, non-conformances, or expired records that would create audit exposure.
  • Corrective action assigned for each deficiency
    Document the action owner, due date, and next step for each missing or expired item.
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