§391.31 requires the carrier to give every driver a road test that demonstrates the driver's ability to safely operate the type of CMV the driver will be assigned. The test must cover at least the items in §391.31(b): pre-trip inspection, coupling and uncoupling, placing the vehicle in operation, use of vehicle controls and emergency equipment, operating in traffic and passing, turning, braking, slowing by means other than the brakes, backing and parking, and the driver's general handling of the vehicle.
§391.33 substitution
A driver with a valid CDL (or LCV-equivalent under §380.401) qualifies under §391.33 — the CDL skills test is accepted in lieu of the carrier's road test. The carrier still files either the CDL copy (under §391.33) or the §391.31 road-test certificate in the DQF; the §391.51(b)(4) requirement is satisfied either way, but a missing certificate is the finding.
Severity weight
Severity weight 3 in the Driver Fitness BASIC. The audit context matters more than the BASIC weight — §385.321(b)(1) makes "no road test certificate or §391.33 equivalent" a new-entrant audit fail when found as a pattern.
How to prevent it
- For CDL drivers, file the CDL copy at hire and re-verify at the §391.25 annual review.
- For non-CDL drivers, conduct an actual §391.31 road test — desk-test "certificates" do not survive audit.
- The road-test examiner must sign the certificate; carrier-signed-only certificates are a finding in their own right.
How Roadworthy HQ helps
The Roadworthy HQ DQF surface treats §391.31 (or §391.33 equivalent) as a discrete item with a present/missing state, retains the examiner-signed certificate, and surfaces it against the driver's audit-readiness signal.