§391.11 lists the seven prerequisites every driver must satisfy: at least 21 years old (or 18 for intrastate where state law allows), can read and speak English sufficiently to converse with the public and respond to traffic signs/inquiries, can drive the vehicle safely, is physically qualified per §391.41, holds a valid CDL where required, has furnished the §391.21 application, and has passed a §391.31 road test (or equivalent).
Severity weight + audit auto-fail
Severity weight 3 in the Driver Fitness BASIC. The bigger issue is audit: the Table to §385.321 lists knowingly using a physically unqualified driver (§391.11(b)(4)) as a standalone audit auto-fail. A single confirmed occurrence can convert a passing audit to a fail — and a failed audit puts the carrier into the §385.319(c) corrective-action track.
What auditors check
- DQF contents per §391.51(b) — physical qualification, MVRs, application, road-test certificate
- §391.25 annual review note
- Medical certification status synced to FMCSA (§391.45/§391.41)
- CDL class and endorsements appropriate for the vehicle and cargo
- §391.23 previous-employer inquiries completed within 30 days of hire
How to prevent it
- Run the §391.11 checklist at hire — every line item must be documented before first dispatch.
- Bake the checklist into the new-driver onboarding workflow so nothing depends on memory.
- Maintain §391.51 retention: while employed plus 3 years after termination.
How Roadworthy HQ helps
The driver's DQF tab lists the required items — application, pre-hire MVR, road test certificate or equivalent, annual MVR, annual review note, medical certificate, NRCME verification, CDL copy — each as present or missing, and the dashboard's audit-readiness panel counts the gaps across the fleet. Roadworthy HQ has no dispatch system, so nothing in it can stop a driver or a vehicle from being assigned a load.