Who is required to have a Drivers' Qualification file

Who is required to have a Drivers' Qualification file?

It is often thought that the Drivers' Qualification (DQ) file is only necessary if the driver has a commercial driver’s license (CDL). This is a misperception that has created confusion for many carriers across the nation.

For interstate drivers, the need for a DQ file is based on the size and type of vehicle being driven, and/or the type of cargo being hauled. According to the FMCSR, part 390.5, the definition of commercial motor vehicle includes both CDL and Non-CDL drivers alike. However, Intrastate drivers would need to either look at state-specific regulations to determine applicability or use the FMCSR rules if their cargo is part of a continuing interstate shipment.

Drivers operating the following vehicles in interstate commerce need to have a completed DQ file:

Vehicles with a gross vehicle weight (GVW) or gross vehicle weight rating (GVWR), or gross combination weight (GCW) or gross combination weight rating (GCWR) of 10,001 pounds or more:

Vehicles designed to transport more than 15 people:

Vehicles transporting hazardous materials that require the vehicle to be placarded:

The issue which causes the most confusion is the definition of the vehicle weight. The general weight criterion for which a CDL is required is 26,001 pounds or more. However, the weight for which a DQ file is needed is 10,001 pounds. Therefore, interstate drivers of vehicles between 10,001 and 26,001 pounds (not hauling hazmat) need to have a DQ file but do not need to have a CDL.

For intrastate drivers that are not part of a continuing interstate shipment, it depends on what the state has adopted for the weight requirement. Many states use the same 10,001 pound criterion that is found in the Federal Motor Carrier Safety Regulations. Other states have increased the weight limit anywhere from 12,000 pounds up to 26,001 pounds (which does coincide with the CDL requirements).

By the way, the same rules apply for drivers having to be subject to the Drivers' Physical Exam. As spelled out above, anyone needing to have the DQ file must also cary their Physical Exam card with them.