DOT Requirements for Non-CDL Drivers

Jennifer Brozic
June 14, 2024
4 min read

Employers that hire non-CDL drivers must remain compliant with Department of Transportation (DOT) regulations that require specific driver records, including MVR checks, physical exams, safety history, and more. Conducting the proper background screenings can help identify candidates who meet DOT driver requirements for operating a commercial vehicle, while failure to do so could result in warnings, fines, and other penalties.

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In this article, we’ll take an in-depth look at the information you need to keep on file for non-CDL drivers, the difference between CDL and non-CDL drivers, regulations you should know to conduct compliant DOT background checks, and more.

What are Driver Qualification Files (DFQs)?

A driver qualification file, or DQF, is a file maintained by an employer that verifies an employee has the proper qualifications to operate a commercial vehicle. The federal DOT requires employers maintain DQFs for all CDL and non-CDL drivers who operate vehicles that have a gross vehicle weight between 10,001 and 26,000 pounds. The DQF must include the candidate or employee’s employment application, safety history from previous employers, MVR record, road test certificate, proof of a physical exam, and alcohol and drug inquiry. 

What is a DOT license?

A DOT driver license is a commercial driver’s license that allows individuals to operate a motor vehicle that exceeds 26,000 pounds, transports hazardous materials, or carries 16 or more passengers. There are three classes of commercial driver’s licenses, depending on the type of vehicle the individual will operate. In addition to a CDL, drivers are also required to have an endorsement to drive trucks with double or triple trailers or a tank, trucks transporting hazardous materials, passenger vehicles, or school buses.

Because operating a commercial vehicle isn’t like driving a car, DOT license requirements include completing a training program offered by a registered training provider and passing skills and knowledge testing. The Federal Motor Carrier Safety Administration (FMCSA) maintains the standards drivers must meet to obtain a commercial driver’s license. However, a driver’s home state issues the commercial driver’s license after the driver meets the skills and knowledge testing requirements.

CDL vs non-CDL driver

A CDL driver may have a Class A, Class B, or Class C license, depending on the type of vehicle they drive. Examples of vehicles that require CDLs include buses, flatbed trucks, truck and trailer combinations, dump trucks, livestock carriers, large delivery trucks, tractor trailers, and hazmat vehicles.  A CDL driver may also have endorsements on their license that allow them to drive special types of commercial vehicles that require additional training, such as vehicles carrying more than 15 passengers or hazardous materials and those that use double or triple trailers.

A non-CDL driver does not have a commercial driver’s license and may have a Class A, Class B, or Class C non-commercial driver’s license. Non-commercial licenses allow drivers to operate vehicles that do not exceed certain limits for weight, capacity, or load, such as small trucks, delivery vans, and taxis. Drivers can obtain a non-CDL class A, B, or C license from the state where they reside.

DOT regulations for non-CDL drivers

The FMCSA establishes regulations that employers must adhere to when hiring non-CDL drivers. Here are common DOT requirements for non-CDL drivers

Employment application

All employment applications must meet the minimum DOT requirements established in the Code of Federal Regulations. Non-CDL drivers must list their employers for the last three years, driving violations, accidents, driver license number, and additional information.

Physical exam

Non-CDL drivers need a DOT physical at least once every two years, and the health screening must be completed by an approved medical examiner. A Medical Examiner’s Certificate, also known as a DOT medical card, confirming the driver meets the physical requirements to operate a commercial motor vehicle must remain in the candidate’s DQF. Employers must also include documentation that the medical examiner who completed the DOT physical is included in the National Registry of Certified Medical Examiners.

Candidates who do not meet the physical requirements for operating a commercial vehicle may be approved to drive if they obtain a Skill Performance Evaluation (SPE) Certificate.

MVR checks

Within 30 days of a candidate’s first day of employment, employers must review the driving record of non-CDL candidates for the previous three years in every state where they have obtained a license. Additionally, employers must conduct MVR checks every year thereafter to confirm the driver meets the minimum safety non-CDL requirements and check for disqualifying offenses.

Safety performance history

Employers must request a candidate’s safety performance history for the last three years from previous employers. Records must be received within 30 days of the first day of employment and include general driver identification and employment verification information, accident history, and alcohol and controlled substance violations. The record must also include any information the driver provides in response to the employment records the employer receives.

Inquiry about drug and alcohol tests

Employers must ask candidates if they have had a positive pre-employment drug and alcohol screening or refused to complete a pre-employment drug test within the past three years. Candidates who previously tested positive or refused to submit to a drug screening must complete the return-to-duty process before they can work in safety-sensitive positions.

Road test certificate

Drivers must complete a non-CDL road test before they are allowed to drive a commercial motor vehicle. Upon successfully completing the road test, the candidate will receive a certificate that must be kept in their DQF. A road test certificate issued within the last three years may satisfy this requirement.

Record of duty status

Drivers of commercial vehicles are required to maintain a driver’s log with details of each trip. Non-CDL log book requirements include the date, carrier’s name, hours driven, miles driven within a 24-hour period, and driver’s notes about the trip. Certain non-CDL drivers may qualify for a short-haul exemption and may not be required to maintain a record of duty status.

Non-CDL car hauler requirements

Non-CDL drivers may be able to haul cars without a commercial driver’s license if they don’t go over the weight requirement. Generally, the combined weight of the vehicle they are driving, the vehicle(s) they are hauling and any other equipment must have a gross vehicle weight of less than 26,000 pounds.

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DOT laws to know

The FMCSA governs the requirements for which employers must adhere when employing drivers in their workforce. Employers may want to familiarize themselves with the following DOT driver requirements to help support compliance, but should consult with legal counsel to verify the most up-to-date requirements.

DQF file

Employers must maintain driver qualification files for non-CDL drivers operating vehicles weighing between 10,001 and 26,000 pounds. A candidate’s DQF must include various documents verifying their safety history, ability to operate a commercial vehicle, history of drug and alcohol testing, and more. In general, documents for non-CDL drivers must remain in their files for three years. 

Drug testing

The DOT does not require drug testing for non-CDL drivers. Employers can implement a drug testing program for non-CDL drivers, but the program must be separate from any DOT-regulated drug-testing policy that is in place for CDL drivers.

Drive time

Employers must adhere to drive time regulations set by the FMCSA for drivers operating commercial vehicles. In general, drivers must take a 30-minute break after eight consecutive hours of driving. Drivers transporting cargo may drive for up to 11 hours after 10 consecutive hours off duty and drivers transporting passengers may drive for no more than 10 hours after eight hours off duty. Non-CDL drivers who drive within a 150-air-mile radius may qualify for a short-haul exception to the drive time rule. Drivers who qualify are not required to take a 30-minute break. 

Get a DOT background check with Checkr

No matter how many vehicles are in your fleet, staying compliant with DOT regulations can be a complex and time-consuming process. Checkr offers multiple background screening options to meet industry regulations, including MVR checks, employment verification, drug testing, and more. Our simple pricing and customizable packages enable you to conduct comprehensive background checks that meet your business needs, while supporting compliance with local, state, and federal laws and regulations. Get started with Checkr.

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The resources and information provided here are for educational and informational purposes only and do not constitute legal advice. Always consult your own counsel for up-to-date legal advice and guidance related to your practices, needs, and compliance with applicable laws.

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About the author

Jennifer writes about a variety of topics, including background checks, employee benefits, small business insurance, risk management, workplace culture, and more. Her work includes educational articles, blogs, e-books, white papers, and case studies.

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