DOT physicals explained
Before a driver can get on the road, the Federal Motor Carrier Safety Administration (FMCSA) requires all drivers of commercial motor vehicles (CMVs) to pass a DOT physical exam.
A DOT physical, or CDL physical, is a test performed by a Certified Medical Examiner (CME) reviewing your general health, mental and emotional well-being and is a required by federal law for anyone driving a CMV.
DOT physicals are required to obtain a DOT medical card, which must be renewed at least every two years, showing that the driver has consistently been medically qualified to drive.
Passing a DOT physical exam ensures that CMV drivers are fully equipped to handle the physical demands of operating a commercial vehicle, such as the long driving hours, stress and exhausting schedules that go along with the job.
After passing you will receive a DOT medical card, which must be placed in the Driver Qualification File (DQF) and kept there for at least three years.
For CDL drivers, the federal medical card is temporary proof in the DQ file until a Motor Vehicle Record (MVR) is received, reflecting the newest exam. The MVR must be on file within 15 days of the exam, along with a note that you checked the NRCME database for the exam and both must be kept on file for three years.
For questions regarding driver files,
contact a DOT Compliance Specialist about Driver File Management.
What do examiners test during a DOT physical exam?
Before any testing is done, a CME must be chosen using the National Registry of CMEs online database. All examiners listed have been verified as fully qualified and having the required medical credentials and complete knowledge of FMCSA regulations and the transportation industry.
Drivers must fill out a form—on-site or before-hand—detailing their current health, health history and a list of current medications.
Below are DOT physical exam requirements that are tested:
- Blood pressure/pulse rate
- Physical exam (check body for abnormalities in over a dozen areas)
A DOT medical card is considered relevant and valid for up to 24 months, however, if the CME has concerns about the driver’s health, a medical card certificate could be issued for 3 months, 6 months, or however long they see fit to come back for their next required physical exam.
Automatic disqualifications if found during a DOT physical exam
According to federal regulation 49 CFR 391.41, there are specific medical disqualifications that will prevent the examiner from passing your DOT physical exam. These include:
- Hearing loss
- Vision loss (if not correctable 20/40 vision in both left or right eye)
- Insulin use to treat diabetes
- If any habit-forming drugs are being taken, including narcotics and amphetamines
However, a driver can obtain an exemption for some of the automatic disqualifications.
For example, the FMCSA vision exemption program is for monocular vision and can be issued for a maximum of two years, to be renewed. To obtain this exemption, an ophthalmologist or optometrist must provide an annual medical and eye exam.
It is important to note that marijuana is still a schedule 1 drug federally. All safety-sensitive positions should not consume marijuana products or unregulated CBD oil products.
Non-CDL drivers of a CMV are not required to have a DOT drug test and many companies and drivers assume it is okay to consume marijuana in states where it is legal. However, the federal DOT health history form can cause an automatic disqualification when it comes to marijuana history.
There are two questions asking if the driver has used an illicit substance within that last two years, or if they have ever failed a drug test or been dependent on an illegal substance. Marking “yes” warrants either a federal drug test or an automatic disqualification. This can affect non-CDL drivers for construction, landscaping, local delivery, moving companies and more.
Some red flags leading to temporary disqualification include, but are not limited to:
- Cardiovascular issues
- i.e. – Drivers having higher than acceptable likelihood of acute incapacitation from a cardiac event.
- Psychological disorder
- i.e. – Drivers are experiencing a psychological or personality disorder (even in early stages) that can affect memory, reasoning, attention, or judgement.
What should I bring to my DOT physical exam?
In order for your DOT physical exam to go as smoothly as possible, arrive early and be prepared with any personal documents and information you might need, such as:
- Medical Examination Report (also available on-site)
- Driver’s license
- DOT medical card (if applicable)
- Medication list
- Corrective lenses or hearing aids
- Medical records, including recent lab results for Diabetes maintenance within the last year, cardiovascular testing results for heart conditions of any kind, and recent CPAP machine printout, if applicable
Where to get a DOT physical exam?
CNS offers DOT physical exams at our location in Lititz, PA with our Certified Medical Examiner (CME), and we also have mobile DOT physicals available in certain states.
Learn more about mobile DOT physicals
(Group volume discounts and mobile options available)
If you are a part of our Drug and Alcohol Consortium, we can assist in finding a location to obtain a DOT physical or drug test nationwide.
What to do after receiving a new DOT medical card
After receiving a DOT medical card—depending on state rules—the driver needs to take the certified document to the DMV within 15 to 30 days to update the medical expiration date or if the driver is applying for a CDL.
If we performed your DOT physical, our licensing team will attach the new medical card to your CDL license through PennDOT.
If any information on the medical card certificate in ineligible, inaccurate, or missing, the driver will receive a letter requiring the medical card to be corrected and faxed or emailed back to the DMV.
Employers must pull a Motor Vehicle Record (MVR) within 15 days of completing the certified driver physical exam. The DOT requires the medical card information at the DMV to be added to the MVR and is why an MVR must be pulled after each updated medical card.
The updated MVR is required to be placed in the driver qualification file and can be audited by the DOT. A non-CDL driver does not need an updated MVR after a new medical card is received. Instead, a copy of the medical card certificate needs to be on file for three years.
For questions about audits, contact a DOT Compliance Specialist about our DOT Audit services.
DOT Compliance Services
Simplify the entire physical, drug consortium and DQF process
Our complete Proactive Safety Management (PSM) program has been organized to get you through an FMCSA audit by managing your driver qualification files, drug consortium, Electronic Logging Devices (ELD), vehicle maintenance and more.
Whether you are a large trucking company that is onboarding drivers quickly or a construction outfit with multiple trucks in your fleet, you need to stay aware of FMCSA regulations.
What is your company’s Return to Work Plan?
As stay at home orders are being lifted across the country and employees start trickling back into the office or plants, it would be wrong to assume things will return to normal.
It is imperative that business owners take responsibility for protecting their employees and this can be accomplished by developing a Return to Work Plan for their organization.
In hotspots like New York, many are convinced they have already been exposed to and contracted COVID-19. However, the worse thing a person could do is assume they are immune because they believe that fever back in January was COVID-19.
This type of mentality makes a Return to Work Plan even more important.
What is a Return to Work Plan?
Basically, it means that businesses need to create a process and an environment that makes it safe for their employees to return to work.
Each Return to Work Plan will of course be unique to the company, but there are many similar concepts that can be implemented, including:
- Antibody Testing
- Pre-shift Temperature Screenings
- How often will employees be checked?
- Will employees return on a gradual basis?
- Are there plans for cleaning of work areas?
- Are there plans for keeping employees at a distanced?
- Will face masks be required?
There is a much longer list of rules and procedures that business owners can follow, but our focus is on the two that will assist in determining if employees are safe to be at work, Antibody Testing and Pre-shift Temperature Screenings.
What is COVID-19 Antibody Testing?
The COVID-19 Antibody Test provides individuals insight into whether they have been exposed to coronavirus and developed antibodies. This could be invaluable information for your company and assist in many decisions related to those employees who have developed immunity.
According to the US Food and Drug Administration, COVID-19 antibody testing may indicate whether “the person has been exposed to the virus and developed antibodies against it, which may mean that person has at least some immunity to the coronavirus.”
However, it is important to note that the length of protection and whether the antibodies protect from re-infection is unknown at this point.
On May 7, a New York Times article detailed a new study that “adds evidence of immunity among those who have already been exposed to the disease, regardless of age, sex or severity of illness – making antibodies to the virus.” Experts were shocked by the percentage of people who have antibodies that were never diagnosed with coronavirus.
How is Antibody Testing useful for employers?
While the science on COVID-19 is evolving, testing for antibodies may help identify individuals who have likely been exposed. This information is helpful to make informed decisions about their risk of infection and spreading the virus in the workplace.
This is useful for employers as staff who are immune could replace vulnerable individuals, especially in high-transmission settings in the transportation industry, building a “shield immunity” in the population.
As of this writing, the Center for Health Security has provided a list of tests approved for research or individual use in the US that accurately detect antibodies in people who have them between 82 and 100 percent of the time. Their ability to correctly identify antibodies only in those who actually have them ranges from 91 to 100 percent.
It may take up to 14 days after the onset of symptoms for antibodies to be developed within the body and 91% of people develop such antibodies within the first 8-13 days. Some of those infected with COVID-19 will never exhibit symptoms, but will have a detectable antibody response.
Who is a candidate for Antibody Testing?
Antibody testing is not intended for use in individuals with an active COVID-19 infection, including individuals with symptoms. Patients who believe they may have COVID-19 are strongly encouraged to contact their healthcare provider.
All interested persons who have neither felt feverish in the last 3 days nor experienced any other COVID-19 symptoms within the past 10 days are appropriate candidates. Symptoms include:
- loss of smell or taste
- shortness of breath
- dry cough
- feeling weak or lethargic
- lightheadedness or dizziness
- vomiting or diarrhea
- slurred speech
To protect collection site staff, please remember to wear either a face mask or some other form of face covering, when arriving at the laboratory collection site.
What are COVID-19 Pre-Shift Temperature Screenings?
Pre-Shift Temperature Screenings simply means that you will be screening each crew member and staff when they are reporting for duty, thereby reducing the risk to other employees.
If your employees have direct contact with someone who is ill or otherwise vulnerable populations, you want to know right away to prevent any spreading to other staff members.
Temperature screenings would be useful to continue using on all employees or those that have tested negative for antibodies.
Learn more about:
COVID-19 Services and Pre-shift Temperature Screenings
How can CNS help?
At CNS, we know how difficult it is as a business owner to determine what steps need to be taken, so we are assisting employers in getting their Return to Work Plans started by implementing our COVID-19 Antibody Tests and Pre-Shift Temperature Screenings.
Our Antibody test is a blood test identifying the presence of antibodies which indicate a person’s immune response to COVID-19. Positive results indicate that an individual may have had previous exposure to COVID-19 and their body has developed antibodies.
What is the return-to-duty and follow-up DOT SAP process?
After a driver receives a failed drug test result, they must begin the return-to-duty process in order to get back on the road, and then continue a follow-up testing process for the next 12+ months.
It is more evident today for employers and drivers to understand this SAP process. In the first two months, the new DOT Clearinghouse has calculated over 11,000 drivers found with a positive drug test result. These employees are now walking through the SAP and return-to-duty process before they can begin safety-sensitive functions.
This process begins with an evaluation of a substance abuse professional, as required in the federal regulations in 49 CFR Part 40 Subpart O.
Learn more about:
FMCSA Clearinghouse: What is it, common issues and FAQs
What is a DOT SAP?
The Substance Abuse Professional, or “SAP”, according to the DOT, is “a person who evaluates employees who have violated a DOT drug and alcohol program regulation and makes recommendations concerning education, treatment, follow-up testing, and aftercare.”
The SAP makes the important decisions on whether or not an employee is ready to drive a truck, school bus, oil tanker, train, airplane, subway car, or other regulated vehicles and how long the follow-up testing end education program should take.
How much does a DOT SAP program cost?
There are several different ways to evaluate the cost of the SAP process. There is the initial SAP examination fee, the education program, the DOT return-to-duty drug test, and the 6+ follow-up testing program.
Unfortunately, the length of the follow-up testing program can be 12 months to 5 years, depending on the SAPs recommendation. So it is hard to estimate a total cost.
On average, the SAP evaluation process can cost between $400 to $500. Drug tests average between $30 to $60 dollars each. The minimum SAP and follow-up testing program can cost an employer or the driver, depending on the company policy of who pays for the program, to be at least $700 for the first year.
How long is the DOT SAP program?
Each SAP program is customized for the person going through it, which can cause a wide range of time when estimating the length of a SAP program. However, this process can be split into two major sections: the time to return-to-duty, and the time to finish the follow-up testing program.
First, there is the SAP evaluation and return-to-duty process so a driver can get back to safety-sensitive functions. This process includes finding a qualified DOT SAP, the SAP evaluation, the SAP talking to a physician if the driver is convinced that a prescription could have caused a false-positive drug test, the length of time to finish an education treatment program, the second SAP evaluation after completing the program, and passing a return-to-duty drug test. This whole process can take weeks to months to finish.
Second, there is the follow-up testing program. According to the regulations, the SAP is required to recommend a minimum of 6 unannounced observed drug tests in the first 12 months after returning to duty. However, the SAP can recommend a program of follow-up drug tests for as long as 5 years. A repeated failed or refused test could require the process to be started all over.
What is the DOT return-to-duty process?
Before an employee can return to duty for safety-sensitive functions, they must complete the return-to-duty process. Once a positive test result is found, the following steps are required:
- Immediately remove the employee from safety-sensitive
- Find a qualified DOT SAP and complete an initial SAP evaluation
- Finish a SAP recommended education or treatment program
- When finished, complete a second SAP evaluation
- If the SAP report is good, complete a return-to-duty observed drug test
Once the DER receives the negative result, the employee can begin safety-sensitive functions again.
However, after the second SAP evaluation, a follow-up testing schedule is given to the DER. The follow-up testing schedule is a minimum of 6 unannounced observed drug tests within the first 12 months of returning to safety-sensitive work and can last up to 60 months, or five years, depending on the SAP recommendation.
What is the FMCSA Clearinghouse?
On January 6, 2020, the FMCSA launched the FMCSA Clearinghouse, an online database where CDL driver drug and alcohol testing violations and return-to-duty information will be stored and searched.
The purpose of the FMCSA Clearinghouse is to prevent job hopping of CDL drivers with positive drug and alcohol test results, refusal to test or information on a driver’s return-to-duty process.
DOT Clearinghouse: Employers and CDL Drivers
There are many new procedures that drivers, employers, consortium/TPAs and others must follow with the FMCSA Clearinghouse now in effect for pre-employment, random testing and return-to-duty processes.
Employers of CDL drivers must follow a new drug testing process when hiring a potential new driver before a pre-employment drug test can be done at a collection site.
What is required of employers?
- Before the new hire driver can be tested, the employer needs to:
- make sure the driver is registered to the FMCSA Clearinghouse,
- then request electronic driver consent to run a detailed query,
- run a query on the driver (employer or C/TPA), and
- ensure no recent negative drug testing history is present
After the detailed query is done, the pre-employment drug test can continue as part of the pre-employment new-hire process.
- Employers must query the Clearinghouse and request 3 years of drug and alcohol testing history until January 6, 2023.
- After that, the clearinghouse query will replace the need for employer requests.
- Employers must run annual limited queries for current drivers at least once a year.
- If the limited query returns any results, a detailed query is required.
What is required of CDL drivers?
There are 3 reasons why CDL drivers need to register to the DOT clearinghouse:
- drivers are changing employers
- registering allows employers to run queries to gather useful information during the hiring process
- drivers are registering with an SAP after a violation, and
- currently employed drivers are giving consent for an annual query
Let us know how we can help:
Ask us about our Drug and Alcohol Services
FMCSA Drug & Alcohol Clearinghouse FAQ
Is the FMCSA Clearinghouse mandatory?
Yes, it is mandatory if your business is governed by the FMCSA.
Information in the FMCSA Clearinghouse database will include:
- positive drug and alcohol test results
- refusal to test, and/or
- information on CDL driver’s return-to-duty process
- if the CMV has a gross weight greater than 26,000 pounds, has more than 15 seatbelts or is hauling anything requiring DOT HAZMAT placards.
Who must register for the FMCSA clearinghouse?
Registration is mandatory for authorized users so they are able to access the Clearinghouse database and the information mentioned above.
Authorized users include:
- Drivers holding a commercial driver’s license (CDL) or commercial learner’s permit (CLP)
- Employers of CDL drivers. This includes those who employ themselves as CDL drivers (i.e. – owner-operators)
- Consortia/Third-Party Administrators (C/TPAs)
- Medical Review Officers (MROs)
- Substance Abuse Professionals (SAPs)
Violations can occur if:
- annual driver queries are not performed in a timely manner
- required information is not loaded into the database, or
- if pre-employment drug tests are performed before a new hire gives consent for a detailed query
Note: CMV drivers are not required to immediately register for the clearinghouse; however, they will need to register to respond to pre-employment queries or other full queries.
How do CDL drivers register for the FMCSA Clearinghouse?
To register, or for assistance registering, drivers can go to the
DOT Clearinghouse website for instructions.
How do employers register for the FMCSA Clearinghouse?
To register, or for assistance registering, employers can go to the
DOT Clearinghouse website for instructions.
FMCSA Clearinghouse registration issues
The FMCSA Clearinghouse registration process faced many issues when first launched, most of which are now fixed.
Some of the common issues that employers or owner-operators may face when registering include:
- Companies have set up their FMCSA Portal account and do not remember their user-ID, security questions, or email address on the account.
- Solution: Call the FMCSA to prove who they are before gaining access.
- Companies have not set-up an FMCSA Portal account and forgot their DOT Pin number.
- Solution: Fill out a form to request their pin.
- If you are a carrier before 2010, and there is an old email or no email or phone number, the government will have to mail your DOT Pin number, taking 7-10 business days.
- Owner-operators seeing errors preventing query purchases is most likely because they are seen as the “employer” and the “driver” and are stuck in the “driver” role.
- Issue: If you hover over “My Dashboard” and see “Queries” and click “Buy”, an error can pop up.
- Solution: To get around this, look for the dark blue text that says “Drug and Alcohol Clearinghouse”, click there. This sort of refreshes your dashboard and you should now see an option to “Change Your Role”. You need to change your role from “Driver” to “Employer”. Now, you can hover over “My Dashboard”, and click “Buy” where it says queries.
FMCSA Clearinghouse Problems, Hiring Delays and Violations
With any major regulatory rollout, there are always unforeseen issues or new problems that appear.
Some of these problems include:
- January 2021, Clearinghouse website may crash again.
- Early Clearinghouse registration issues led officials to advise employers to wait to register until December 2020 or January 2021. Consequently, a large spike in DOT Clearinghouse web traffic is expected as companies rush to register and submit annual queries to the DOT Clearinghouse before the deadline.
- FMCSA Clearinghouse will catch drivers at roadside.
- According to the Commercial Vehicle Safety Alliance, starting April 1, 2020, drivers who are prohibited from driving—per the CDL Clearinghouse—will immediately be put out-of-service by CVSA roadside enforcement inspectors and employers will need to arrange for another driver to pick up the load.
- Hiring driver process issues:
- Employer sends a consent request, but the driver has not registered to the Clearinghouse to authorize consent.
- FMCSA will mail a letter to the driver regarding the consent request (2-3 week process)
- Employer falsely tells a drug testing site that driver consent was given. If audited, the employer can be held at fault if the violation of no consent was caught, causing delays in the pre-employment testing process, headaches for companies and drug testing sites not up-to-date on Clearinghouse rules.
- Employer sends a consent request, but the driver has not registered to the Clearinghouse to authorize consent.
- What happens if you fail or refuse a DOT drug screen?
- In the first 2 months the DOT Clearinghouse was in effect, over 11,000 drivers were found with a positive drug test and must begin the return-to-duty and SAP process before getting back on the road.
Learn more about:
DOT SAP and Return-To-Duty Process
Drug and Alcohol Services
Do you need help registering to the FMCSA Clearinghouse or looking to switch to a trusted drug testing consortium?
At CNS, we offer a comprehensive Drug and Alcohol Consortium Service and are a certified consortium and third-party administrator (C/TPA).
In response to the HOS issues highlighted during the ELD mandate rollout, and in an effort to improve safety and flexibility to CMV drivers, the FMCSA has moved into the final stages of publishing the new hours-of-service rule changes.
In August of 2019 the FMCSA released a notice of proposed rulemaking (NPRM) related to the hours of service rules and regulations and were also taking public comment on the DOT hours-of-service proposal.
On March 2, 2020, the FMCSA announced that they have filed the rule to the White House Office of Management and Budget (OMB), which is one of the final steps before the rule is published in the Federal Register.
When will the HOS rule take effect?
FMCSA Acting Administrator, Jim Mullen, announced Thursday, May 14, 2020 that the rule should be published in the Federal Register in the coming week and the changes will become effective 120 days after that.
During this time, ELD providers will have to implement software changes to reflect the new hours of service rules.
If the new rules are published next week, and ELD providers are given enough time to make the necessary changes, drivers could begin operating under the new HOS regulations in September 2020.
What are the new hours of service rules?
There are 4 major changes to be included in the hours of service reforms:
- Short-haul exception: Changes will lengthen the current 100 air-mile exemption of the drivers’ maximum on‑duty period from 12 to 14 hours, and extending the short-haul radius from 100 air-miles to 150 air-miles, to be consistent with the 150 air-mile exemption of trucks with a GVWR of 26,000 lbs. or less.
- Drivers under the short-haul exemption are not required to keep records of duty status.
- Adverse driving conditions exception: Changes will extend both their drive-time limit and their on-duty window by 2 hours if they encounter adverse conditions such as weather or traffic congestion.
- According to the FMCSA, the provision will allow drivers to either sit and wait out the conditions or to slowly drive through them with caution.
- 30-minute break requirement: Changes will allow drivers to satisfy the required break using on-duty (not driving status) rather than off-duty, and requiring it within their first 8 hours of drive time, rather than their first 8 hours on-duty.
- For example, if you are on-duty refueling your truck and it takes 30 minutes, this could qualify as your 30-minute rest break.
- Sleeper berth exception: Changes will allow more flexibility for drivers to split the required 10 hours off-duty into two periods.
- 7 and 3 split: Must contain at least 7 consecutive hours, either off duty or in the sleeper berth, the shorter period will pause the rolling on-duty clock.
- 8 and 2 split: Cannot be less than 2 consecutive hours, either off duty or in the sleeper berth, the shorter period will pause the rolling on-duty clock.
Unlike the proposal issued last August, the hours of service changes do not include the option for drivers to pause their 14-hour clock for up to three hours while off-duty to extend the 14-hour clock.
Mullen said the agency deemed the seven-hour, three-hour split “sufficiently flexible” to that end, given with the new change the shorter period in any sleeper split will in fact stop the rolling duty clock, unlike the current split-sleeper rules.
What does this mean for fleets and truck drivers?
These changes provide an important time for fleets to update their driver training. CNS offers a variety of in-person and online training courses for the specific needs or weaknesses of your company or its’ drivers.
Fleets that incorporate training alongside driver qualification, drug testing and fuel tax management can create a complete picture of fleet safety.
Our complete safety program—Proactive Safety Management (PSM) Program—will complement or become your current safety department, without the cost of employing the many staff members it takes to run an effective safety program.
Prescreening temperature checks:
What are they and why are they important?
The trucking industry will be dealing with the coronavirus, or COVID-19, for the long haul, which is why prescreening temperature checks are so important.
Until a vaccine has been found, approved and mass produced and distributed, fleets and distribution sites will need to find ways to keep their drivers and facilities safe from potential exposure.
Earlier this month, the president of the Owner Operator Independent Driver Association (OOIDA), Todd Spencer, expressed concern that “once word spreads that drivers are testing positive, we could very well see a tremendous reduction in drivers willing to risk everything for the rest of us.”
Spencer believes there should be greater efforts made to provide drivers with personal protective equipment, which hopefully helps them avoid infection and stay on the job.
Truck drivers working from home?
Unfortunately, truck drivers cannot work from home and with more than 1.8 million CMV truck drivers in America, the potential for exposure is high.
For anyone that is exposed, the Centers for Disease Control and Prevention (CDC) released guidance for essential workers—including those in trucking—allowing them to continue work provided they are asymptomatic and take additional precautions to protect themselves and the community.
Potential exposure means having close contact within 6 feet of an individual with confirmed or suspected COVID-19, including the 48 hours before the individual became symptomatic.
This guidance was in response to several states and local cities, such as Ohio, Delaware, San Francisco, and Santa Clara County, who urged or required temperature checks before employees are permitted to report to work.
Truck drivers face greater risk of illness
Several factors put truck drivers at greater risk of being exposed and/or contracting the coronavirus, including nationwide travel, handling of overseas goods, exposure at truck stops for meals and showers and multiple facility stops.
Besides the greater risk of contact with the coronavirus, according to a 2014 study by the CDC, drivers may also be at greater risk of falling ill from the virus.
The study showed more than half of truck drivers smoke and are two times as likely to have diabetes as the rest of the population. These health factors put them in a higher risk category should they contract
Why are pre-shift temperature screenings important?
Screening each fleet driver and staff when they are reporting for duty ensures less risk to other employees. If your staff has direct contact with someone who is ill or otherwise vulnerable, it is important to catch it ahead of time to prevent spreading to other staff members.
With frequent facility stops, it is nearly impossible for drivers to know if they have been within 6 feet of someone who has been exposed to coronavirus. The best practice in this situation is to implement CDC’s guideline of pre-screen temperature checks for your entire fleet and staff.
Do not risk the health or your employees or your business. Follow these best practices when implementing temperature screenings:
- Communicate with your employees clearly before temperature checks are implemented
- Administer screening questionnaires to get a better idea of potential exposures
- Set a temperature test limit, preventing any employees to enter the workplace if exceeded
- The CDC considers a person to have a fever when temperature is at least 100.4 degrees Fahrenheit
- Set-up temperature testing in the least invasive way possible, ideally with devices that can register temperature without exposure to bodily fluids.
- Appoint someone with proper training, such as CNS on-site staff, to facilitate or administer on-site temperature checks.
- Maintain social distancing guidelines with your temperature check station.
Are you concerned for your staff and drivers about COVID-19 exposure?
We offer on-site pre-shift screenings, screening questionnaires and temperature screenings for your distribution site, terminal, construction site or office.
We will also be offering antibody testing soon, which will allow employers insight into employee exposure to COVID-19 and whether or not they have developed antibodies.
We appreciate all you do in this time of struggle.
When we entered into this industry through DOT licensing, compliance and safety management years ago, we immediately recognized the selflessness of truck drivers across the country. Away from their families, transporting goods for other families, battling traffic and changing regulations – it is a tough gig.
Aside from the services we offer at CNS to aid the industry, we always wanted to see the respect that truck drivers deserve shown to them in homes, families, corporations and media across the country.
While we are in dire circumstances with COVID-19 right now, a silver lining has been the recognition of the tireless work of drivers transporting food and necessary supplies to those that need it most.
With hearts full of gratitude, we join in.
Thank you to all drivers and essential workers, today and every day, for your sacrifice and dedication to the needs of those around you.
We are honored to serve you at CNS.
– John Irwin, CDS
How to set up a Driver Qualification File?
In industries like trucking, construction and distribution, hiring a commercial motor vehicle driver requires companies to follow strict Federal Motor Carrier Safety Administration (FMCSA) guidelines. The regulations under 49 CFR Part 391 lists requirements for Driver Qualification File (DQF) Management.
What is a Driver Qualification File or DQ File?
Driver Qualification Files are simply the driver’s personnel file that includes information of past employment, drug testing history, motor vehicle records, credit history, and more.
Failure to maintain these driver qualification file basics can lead to CSA violations, fines, an Unsatisfactory Safety Rating, and Out-of-Service Orders. In 2019, there were over 3,500 enforcement cases alone that averaged over $6,600 in fines per company, with the average cost of a Driver Qualification File violation fine over $600 per fine.
It is important to understand what the common DQ file violations are and how to prevent them from happening in your company’s driver qualification file management process.
Mistake #1: Not having a Driver Qualification File when required
When is a driver qualification file required?
A driver qualification file, according to 49 CFR 390.5, is required for anyone who operates a Commercial Motor Vehicle (CMV). This includes vehicles that weigh over 10,000 pounds, are placarded for hazardous materials or are designed or used to transport multiple passengers (at least 9 or more).
DQ files are needed even if the driver is salaried, a mechanic, the owner of the company, a part-time temp driver, is only driving one time, works for a private company, etc. There are some exceptions found in sections 390.3, 391.2, and 391.61-391.69.
For intrastate commerce where the driver stays within a single state, some state requirements may vary.
Mistake #2: Not obtaining a driver Motor Vehicle Record
What is a Motor Vehicle Record (MVR)?
An MVR is a report of driving history from the Department of Motor Vehicles (DMV).
The MVR contains important information from a driver’s license including, endorsement level for any kind of vehicle, accident reports, DUI convictions, vehicle crimes, traffic violations, license suspensions and more.
According to the FMCSA, a copy of the MVR(s) obtained in response to the inquiry must be placed in the driver qualification file within 30 days of the date the driver’s employment begins and be retained in compliance with 49 CFR 391.51.
If no MVR is received from the State required to submit this response, the motor carrier must document a good faith effort to obtain such information and certify that no record exists for that driver.
An MVR must be pulled from every state where the driver has held a license or permit in the past three years. If any red flags appear, a potential employer could use it to influence their hiring decision. This is why it is important for drivers to be aware of what is on their MVR and should request one every year. If any information is inaccurate, the driver could request to fix the mistake.
The carrier must then obtain an updated MVR annually, and review it to determine whether minimum safe driving requirements have been met, and confirm that there are no disqualifying offenses.
Mistake #3: Not keeping a driver qualification file long enough
How long to keep driver qualification files?
Another common mistake is how long you need to keep driver qualification files.
Some companies dump records after three years of employment, and do not keep these initial safety records on file for three years after driver is no longer employed at the company.
It is important to note that, separately, any safety history information gathered from previous employers must be retained for as long as the driver is employed by that motor carrier and for three years thereafter.
Mistake #4: Not having important drug test history and medical card on file
For drivers who hold a commercial driver’s license, the motor carrier must obtain a new motor vehicle record (MVR) within 15 days after each new DOT medical exam and place that in the driver qualification file as proof of medical certification. Each new medical exam certificate must be placed into the DQ file and kept there for at least three years, to show that the driver was medically qualified to drive at all times.
Often times these medical cards are out-of-date or the DQ files never replaced the old medical card on file. During a DOT audit, this is a simple mistake that can be caught and fines for each violation in your fleet can add up quickly.
Similarly, important drug testing history and alcohol test results must be saved in the DQ File for at least one year. These test results includes: previous employer test results; copy of alcohol test form, with results and drug test chain of custody form; documents sent to the employer by the MRO; documentation of any refusal to submit; and documents provided by a driver to dispute results.
How to prevent Driver Qualification File Management mistakes with CNS
After a driver is hired, managing driver files becomes an ongoing burden as employers are required to keep files current for drug tests, physical exams, safety records, annual MVRs, commercial driver’s licenses, endorsements and even conducting annual driver reviews (a burdensome process).
With high driver turnover in trucking, construction and distribution fleets, this problem becomes amplified.
CNS goes beyond just helping you manage your driver qualification files. Our Proactive Safety Management program helps to manage your entire plan for safety, compliance and record keeping, from drug consortium management to vehicle and equipment maintenance.
Need faster DOT drug test results?
With trucking’s high driver turnover and competitive job market, fleets risk losing top candidates if their hiring process is not efficient.
When an employer sends a potential hire to a collection site for a DOT drug test, the company hopes to receive the results quickly in order to get the new-hire through the hiring process as quickly as possible.
In an attempt to speed up the new-hire process, it is important for fleets to understand how drug test results can be delayed before finding solutions to get results faster.
The DOT drug testing process can be split into three areas: collection sites, labs, and—if a positive test result—the MRO, all of which can cause preventable delays in the entire process.
What are some causes of delays in drug test results?
Delays at collection sites
Delays caused at collection sites are usually caused by a simple collector mistake. For example, each sample should have the donor’s and the collector’s signature on the vial, and the collector may have forgotten. Also, the required forms may not have been filed at the collection site to have the errors fixed before lab testing of the samples can begin.
Beyond these simple collector errors, many smaller or remote collection sites do not send the urine samples to the labs on a daily basis. They may only have a courier come every two or three days before being shipped to labs for testing.
Also, many collection sites may not have a male or female collector available for an observed collection, forcing the donor to wait for that staff member to come in or being advised to find another collection site with proper staffing.
These delays could easily be avoided by working with a best-in-class collection site who use trained collectors, or using a drug and alcohol consortium who verifies quality collection sites in their network and, if a mistake is made, they continually follow-up on the status of the results.
Delays at the lab
Once the donor provides a sample, it is quickly sent to a drug testing lab for testing. Labs receive thousands of these specimens daily and each one must have their chain of custody form reviewed for accuracy.
Many of the flaws are correctable and an affidavit or memorandum is sent to the collector to be corrected and sent back. Once a completed chain of custody form or required signatures are received for the specimen sample, the specimen then goes through an initial base screen test.
If the drug test results is negative, no further testing is needed and the employer is quickly notified of the negative result. Negative results are often received within 24-48 hours.
If a non-negative result is found in the initial base screen test, the sample goes through a Gas Chromatography – Mass Spectrometry (GCMS) test process that includes breaking down the urine sample.
A delay in results from the lab can happen if the GCMS test does not affirm a negative or positive result. If this is the case, the specimen goes through another GCMS test process until an affirmative negative, positive, negative-dilute or positive-dilute result is given.
According to most labs, each round of GCMS testing is a batch of other specimens and each batch only gets ran once per 24 hours. If this happens, the delay of this donor’s drug test is unavoidable.
If a positive test is affirmed, the results are sent to a Medical Review Process (MRO). The MRO review process can take over a week to complete as the MRO attempts to reach the donor, has an initial interview with the donor, and, if the donor claims a prescription could have caused a false-positive, the MRO follows a procedure to verify the prescription.
Speed up the hiring process with fast DOT drug test results
Compliance Navigation Specialists ensure that the hiring process runs as efficiently as possible in order to speed up the pre-employment process. Not only do we help with your consortium, collection site and MRO services, we take it one step further.
Our Proactive Safety Management (PSM) program is the most comprehensive service we offer, covering all of your needs to manage your business, including driver qualification files, consortium management, ELD management, vehicle maintenance and more.
Many companies are finding it increasingly hard to maintain proper systems to make sure they are staying compliant throughout the year. We are your best solution, to support or act as, your safety department for a fraction of what it costs to hire a DOT Safety Director.
We pride ourselves in being flexible for our clients and working with all types of carriers from busy owner operators to larger fleets. CNS will be a valuable asset by keeping your company safe, compliant, aware of regulatory changes, proactive in all phases of potential risks, as well as profitable.
Can truckers use CBD oils?
The use of cannabidiol (CBD) and related products has trended in recent years. It’s common now to see many products labeled with CBD as an ingredient.
However, it’s important to remain aware of FDA regulations concerning CBD, and the DOT stance on the use of CBD for drivers.
Is CBD considered marijuana or not?
The classification of a product as marijuana depends on the concentration of tetrahydrocannabinol (THC) in the product. Anything containing more than 0.3% THC is classified as marijuana.
Cannabidiol (CBD) products do contain levels of THC, sometimes above or below the marijuana classification levels.
DOT drug testing: Required for marijuana, not CBD
The DOT requires drivers to test for marijuana, but not for CBD. However, the labeling of CBD products can be misleading. If the product contains a higher than 0.3% cannabidiol concentration, it would fall into the category of marijuana.
Drivers taking a marijuana drug test after using a CBD product with higher levels of THC would end up testing positive for marijuana.
CBD usage and labeling confusions
Because the FDA (Food and Drug Administration) doesn’t certify levels of THC in CBD products, there’s very little way to tell if the labels are accurate. A person could end up unknowingly using a product that falls into the marijuana classification.
The FDA reminds the public that “it is currently illegal to market CBD by adding it to a food or labeling it as a dietary supplement.” Many companies have received FDA warning because their products exceed the CBD levels listed on their label.
Therefore, it’s entirely possible that CBD product you’re using COULD in fact, be classified as a marijuana product.
This creates a dangerous situation for people who require drug testing, including safety-sensitive drivers.
DOT, Marijuana and Cannabidiol (CBD)
Because the DOT does not allow the use of marijuana for any reason, drivers who use a CBD product could unintentionally run afoul of DOT regulations.
If a driver tests positive for marijuana, but was only using a CBD product, this claim will not be allowable. Laboratory-confirmed marijuana positive results will stand regardless of the drivers claim of CBD product usage.
Avoiding CBD usage is the best precaution
Drivers risk getting a marijuana positive test from the use of CBD products. Since employees subject to the DOT drug testing regulations are forbidden from using marijuana, great care must be taken with CBD products. Exercise caution about using CBD products. Because the labeling is often inaccurate, there are many unknowns about the actual levels of CBD in the products.
Remember positive drug tests remain on your record for three years. A positive test can require additional driver retraining and fines. A driver’s employment and income could be put in danger.
Why run the risk of having a positive drug test on your driving record? Avoiding the use of CBD products keeps your record clean, and keeps you worry-free when taking mandatory drug tests.
Drug and Alcohol Services
We offer a number of services related to drug and alcohol requirements
If you have any concerns regarding CBD usage or any other questionable prescription medications, we can answer any questions you have.
- We offer comprehensive Drug and Alcohol Services and Drug and Alcohol Consortium
- Learn more about how to stay compliant with the mandatory Clearinghouse Rule