DQ files, MVRs, and Clearinghouse kept continuously audit-ready — so a file review is never a fire drill.
Part 391.51 lists what a DQ file must contain, and an investigator checks it literally. The application for employment, the motor vehicle record obtained at hire, the annual MVR and the annual review of driving record, the road test certificate or the CDL accepted in place of it, the medical examiner's certificate and its verification against the National Registry, and the inquiries into previous employment covering the prior three years.
The failures cluster in predictable places. Previous-employer inquiries that were sent but never followed up when nobody replied. The annual review that exists as an MVR in the file with no evidence anyone actually reviewed it. Medical certificates that expired while the driver kept running. Each one is a citable finding, and in a crash the same gap becomes the foundation of a negligent hiring argument.
The Clearinghouse adds its own calendar: a full query before you put someone behind the wheel, a limited query annually for every CDL driver, and consent records for both. A missing annual limited query is one of the easiest violations to accumulate quietly, because nothing goes wrong until someone asks.
Managed DQ work means the files are built right at hire and stay current after it, with expirations tracked ahead of the date rather than discovered after it.
Three years after the driver's employment ends for the qualification records. Some related records, including drug and alcohol testing records, carry their own retention periods, so do not purge the whole file on one clock.
If they operate a commercial motor vehicle as FMCSA defines it, generally yes. The Clearinghouse requirements are CDL-specific, but driver qualification under Part 391 reaches further than many carriers assume. This catches a lot of contractors off guard.
A full query returns detailed information and requires the driver's specific electronic consent; it is required pre-employment. A limited query only tells you whether information exists, requires general consent, and satisfies the annual requirement unless it comes back indicating records are present.
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