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DQF Completeness Checker

Walk every item required by 49 CFR §391.51(b) and its companion rules. For each, mark whether you have it on file. The tool will compute a completeness score and list the gaps you need to close.

Completeness score

13 applicable items · 0.0 earned

0%

13 gaps to close

  1. Item 1 · §391.21

    Driver's application for employment

    Signed application with the items in §391.21(b): name, address, employment history (3 years), accident history, and CDL list.

    Retention: Duration of employment + 3 years

  2. Item 2 · §391.23(a)(2)

    Inquiry to previous employers

    Documented inquiry to each CMV employer of the driver in the past 3 years, including responses or evidence of contact attempts.

    Retention: Duration of employment + 3 years

  3. Item 3 · §391.23(a)(1)

    Initial MVR from each licensing state

    Motor vehicle record from every state in which the driver held a license in the past 3 years.

    Retention: Duration of employment + 3 years

  4. Item 4 · §391.25(a)

    Annual MVR (most recent)

    MVR pulled within the past 12 months from each state where the driver currently holds a license.

    Retention: 3 years per inquiry

  5. Item 5 · §391.25(b)

    Note of annual review of driving record

    Carrier's written review of the annual MVR, including a determination of continued qualification.

    Retention: 3 years per review

  6. Item 6 · §391.31 / §391.33

    Road test certificate (or CDL in lieu of)

    Either a road test certificate, or a copy of the CDL with a written acceptance under §391.33.

    Retention: Duration of employment + 3 years

  7. Item 7 · §391.41 / §391.43

    Current medical examiner's certificate

    Copy of current med cert (or National Registry verification). Must be unexpired.

    Retention: 3 years from exam date or current — whichever is later

  8. Item 8 · §391.49

    Skill performance evaluation certificate (if applicable)

    Required only for drivers operating under an SPE for a physical impairment.

    Retention: 3 years from execution

  9. Item 9 · §391.64 / §391.46

    Medical variance documentation (if applicable)

    Required only for drivers operating under vision or diabetes exemption.

    Retention: 3 years from execution

  10. Item 10 · §391.51(b)(8) / §391.23(m)(1)

    NRCME verification note (non-CDL drivers)

    A note verifying the medical examiner was listed on the National Registry of Certified Medical Examiners. Required for non-CDL drivers since June 23, 2025; for CDL drivers the requirement ended June 22, 2025 — the CDLIS MVR carries medical certification status instead.

    Retention: 3 years from execution

  11. Item 11 · §382.301

    Pre-employment drug test result

    Verified negative drug test result before the driver performs any safety-sensitive function.

    Retention: 5 years (negatives); longer for non-negatives

  12. Item 12 · §391.23(d) / §382.413

    Previous-employer drug & alcohol testing inquiry

    Documented inquiry into the driver's prior D&A program participation, including a Clearinghouse query under §382.701.

    Retention: Duration of employment + 3 years

  13. Item 13 · §391.15

    Disqualification documentation (if applicable)

    Records of any disqualification under §391.15, the basis, and any corrective action. Not an enumerated §391.51(b) item, but expected on file when a disqualification has occurred.

    Retention: Duration of employment + 3 years

Not on this list · §391.27

The annual list of violations is no longer required

Older DQF templates still ask for a driver-furnished annual list of violations under §391.27. That requirement was rescinded on May 9, 2022 — the annual MVR and review (items 4 and 5 above) cover it. If a template tells you to collect one, the template is out of date.

Gap report

Close these items before your next audit.

  • Driver's application for employment (§391.21)
  • Inquiry to previous employers (§391.23(a)(2))
  • Initial MVR from each licensing state (§391.23(a)(1))
  • Annual MVR (most recent) (§391.25(a))
  • Note of annual review of driving record (§391.25(b))
  • Road test certificate (or CDL in lieu of) (§391.31 / §391.33)
  • Current medical examiner's certificate (§391.41 / §391.43)
  • Skill performance evaluation certificate (if applicable) (§391.49)
  • Medical variance documentation (if applicable) (§391.64 / §391.46)
  • NRCME verification note (non-CDL drivers) (§391.51(b)(8) / §391.23(m)(1))
  • Pre-employment drug test result (§382.301)
  • Previous-employer drug & alcohol testing inquiry (§391.23(d) / §382.413)
  • Disqualification documentation (if applicable) (§391.15)

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How to use this checker

For each item, mark Have if the document is on file, Partial if some but not all of the required content is present, and Missing if you don't have it. Items marked Not applicable are excluded from the score.

The §391.51 list applies to every CMV driver — including the owner-operator who is also the only driver. There is no single-driver exemption.

What the checker doesn't do

This is a self-assessment, not a legal review. It cannot verify that your documents are correctly filled out, current, or signed by qualified people. For your specific situation, consult counsel or a qualified compliance professional.

Roadworthy HQ enforces this list automatically and tracks every retention period to the day. Start a 14-day free trial to build your DQF in 15 minutes.