Stop 2 of 4 · File your drivers
File your drivers: the qualification file.
Running both? Follow the CDL track, which covers everything, and scope by unit as you go: the testing program covers anyone who ever drives a CDL vehicle, IFTA and IRP follow the trucks over 26,000 lbs, and your lighter trucks' drivers may qualify for short-haul time records instead of an ELD.
Every driver needs a qualification file, and your drug and alcohol program has to be live before the first load, not after. Missing DQ files are the most-cited violation in FMCSA audits, and having no testing program is an automatic fail at your new entrant audit. This is the step to do carefully.
2.1Start a qualification file for every driver.
The “file” is literally a folder with the driver's name on it — a paper folder in a drawer, a folder on your computer, or a driver record in your Dotra account. FMCSA doesn't care which, only that everything below is in it when someone asks. One folder per driver, including you if you drive.
- 1Make the folder now, before you have anything to put in it. Label it with the driver's full name.
- 2Everything in the rest of this step goes into it, and it stays for as long as the driver works for you, plus three years after.
Save this: The folder itself. This is the backbone of your compliance record.
2.2Have the driver fill out an employment application.
A DOT-compliant driver application — not a generic job form. It asks for ten years of work history for CDL drivers, plus license and accident history. Yes, an owner-operator fills one out on themselves.
- 1Search for a “DOT driver employment application” form — your insurance agent or consortium can hand you a compliant template, and Dotra provides one inside your account.
- 2The driver fills it out completely and signs it. Gaps in the history need an explanation written in.
- 3Into the folder.
Save this: The completed, signed application.
2.3Pull the driver's driving record, now and every year.
An MVR (motor vehicle record) is the official copy of a driving record, and you buy it from the state that issued the license. You need one from every state the driver was licensed in over the past three years, then a fresh one every year with a short written review.
- 1Go to the website of the state DMV that issued the driver's license and search “driving record request.” Most states sell the record online for a few dollars; some make you mail a form.
- 2Order the record for each state the driver held a license in during the past three years.
- 3Once a year from now on: pull a fresh MVR, read it, and write a dated note that you reviewed it and the driver is still qualified. Sign the note. Both go in the folder.
Cost: A few dollars per record, set by each state.Save this: The MVRs and each year's signed review.
2.4Do the road test.
Either a road test you give the driver, or a copy of their valid CDL, which the rule accepts in its place. Most CDL operations just photocopy the license.
- 1Simplest path: photocopy the driver's valid CDL, front and back, and put the copy in the folder. Done.
- 2If you'd rather road test: someone competent rides along while the driver runs through normal driving — pre-trip check, turns, backing, braking — then fills out and signs a road test certificate form.
Save this: The CDL copy (or the signed certificate).
2.5Get the DOT physical.
Every driver needs a DOT physical from a certified examiner. Since mid-2025, a CDL driver's result posts electronically to their driving record, so your proof is the MVR — with a short paper-card grace period while states finish switching over.
- 1Find an examiner on FMCSA's National Registry: enter your zip code and it lists certified examiners near you — many are at walk-in clinics. Call and book a “DOT physical.”
- 2The driver brings their license, a list of any medications, and their glasses, contacts, or hearing aids if they use them.
- 3The exam takes about 30 minutes: vision, hearing, blood pressure, and a urine check (that one screens health, it is not a drug test), plus a basic physical.
- 4The examiner issues a medical certificate and reports the result to the state. Pull the driver's MVR after a few weeks to confirm the certification shows; keep the paper certificate in the folder until it does.
Where: FMCSA National RegistryCost: Prices vary by clinic — call ahead and ask.Time: About 30 minutes at the clinic.Save this: The MVR showing the certification, plus the paper certificate until it does.
2.6Ask the last three years of employers.
For any driver who worked for another DOT-regulated company in the past three years, you ask those companies about the driver's safety record. If a past employer never answers, your documented attempts count.
- 1List the driver's DOT-regulated employers from the application, going back three years. (An owner-operator with no such employers writes “none” and is done.)
- 2Send each one a written request for the driver's safety performance history — email works. Your consortium or insurance agent can give you the standard inquiry form.
- 3No reply in 30 days? Send it again and keep copies of both attempts. The attempts go in the folder either way.
Save this: The responses, or your documented attempts.
2.7Check the English standard at hire.
A driver must read and speak English well enough to talk with the public, read road signs, and answer an officer. Since June 2025, inspectors can put a driver out of service over this, so settle it during hiring: hold the interview in English, and note in the folder that you did.
2.8Enroll in a random-testing consortium.
Anyone driving a CDL vehicle is in the federal random drug-testing pool, and you can't run your own pool — even a one-driver company joins a consortium, a shared pool run by a third-party administrator (C/TPA). They handle the random selections; you make sure anyone selected actually tests.
- 1Ask your insurance agent for a consortium referral, or search “DOT drug testing consortium” — national ones enroll you by phone or online in a day.
- 2Enroll the company and every CDL driver. They'll schedule the pre-employment test (next item) and send you a written testing policy to adopt.
- 3Keep the enrollment certificate they send — an auditor asks for it by name.
Cost: Typically $100 to $300 per driver, per year.Time: Enrollment done in a day.Save this: Your consortium enrollment certificate.
2.9Register with the Clearinghouse and run the queries.
The Clearinghouse is FMCSA's database of drug and alcohol violations. Every employer of CDL drivers registers, then checks each driver in it before they drive, and once a year after.
- 1On clearinghouse.fmcsa.dot.gov, choose “Register” as an employer and sign in with the same Login.gov account from step 1.
- 2Designate your consortium (C/TPA) when it asks — they gave you their exact name at enrollment.
- 3Have each driver create their own Clearinghouse account too; the full pre-employment check needs their electronic consent from inside it.
- 4Run the full query on every driver before they drive, and a limited query on every driver once a year (that one runs on a signed paper consent you keep in the folder). Queries cost a few dollars; buy them inside the site.
Save this: Every query result, into the folder.
2.10The test, the policy, and the training.
Three things before anyone drives a CDL vehicle: a negative pre-employment drug test in hand, a written testing policy signed by every driver, and, if you employ drivers, two hours of supervisor training.
- 1Your consortium schedules the pre-employment drug test at a collection site near the driver. The negative result must be in your hands before the first load — before, not after.
- 2Adopt the written policy your consortium provides, give a copy to every driver, and collect a signed receipt from each.
- 3If you employ drivers, take the supervisor training your consortium offers: one hour on drug misuse, one on alcohol misuse. Keep the completion certificate.
Save this: The negative test result, the signed policy receipts, and the training certificate. Testing records have their own clocks: negatives kept one year; positives, refusals, and return-to-duty records kept five.
2.11Verify entry-level driver training.
For any CDL first issued after February 7, 2022, confirm the driver's training came from a provider on FMCSA's Training Provider Registry. Drivers licensed before that date are grandfathered — nothing to do.
- 1Ask the driver where they trained, then check that provider on the registry site.
- 2Note the verification in the folder.
Your file is building
Every “save this” above needs a home.
Those documents are your compliance file, and they come with expiration dates. Put them in your Dotra account as you go and they stay organized, watched, and ready for the audit, with a heads-up before anything goes stale.
Start your file in DotraFree to start. Your progress on this road comes with you.
Dotra is a tool, not your compliance department. The duty to comply sits with the motor carrier under 49 CFR, and it doesn’t transfer to a vendor, a consultant, or a software product. This road is general information about federal requirements, not legal advice: state obligations aren’t covered, hazmat, passenger, and intrastate-only operations carry requirements it doesn’t address, and rules change. Verify anything that matters at fmcsa.dot.gov before you rely on it.