Driver files,audit‑ready.Every renewal tracked.

Per 49 CFR § 391.51(b), every DQ file must contain: the driver’s employment application (§ 391.21), the pre-employment Motor Vehicle Record received from each State of licensure (§ 391.23(a)(1)), the road test certificate or equivalent license/CDL (§ 391.31(e) or § 391.33), the current Medical Examiner’s Certificate (§ 391.43(g)), the annual MVR (§ 391.25(a)), a note documenting the annual review of the driver’s driving record (§ 391.25(c)(2)), any Skill Performance Evaluation Certificate or medical variance (§ 391.49 / part 381), and the National Registry of Certified Medical Examiners verification note (§ 391.23(m)). Past-employer safety-performance inquiry records required by § 391.23(a)(2) are not part of the DQ file itself — they go in the separate driver investigation history file under § 391.53. For CDL drivers, the FMCSA Clearinghouse pre-employment full query under § 382.701 is typically filed alongside.

Per 49 CFR § 391.51(c), the DQ file as a whole must be retained for as long as the driver is employed by the motor carrier and for three years thereafter. While the driver is still employed, § 391.51(d) allows certain records to be removed from the file three years after the date of execution: the annual MVR (§ 391.51(d)(1)), the annual driving-record review note (§ 391.51(d)(2)), the medical examiner’s certificate (§ 391.51(d)(3)), any FMCSA medical variance or Skill Performance Evaluation Certificate (§ 391.51(d)(4)), and the National Registry verification note (§ 391.51(d)(5)). The current/valid certificate and the foundational records (employment application, pre-employment MVR, road test certificate) stay in the file for the full employment duration plus three years.

Annually. Per 49 CFR § 391.25(a), motor carriers must request an MVR from every State in which the driver held a license or permit during the prior 12 months. Per § 391.25(c)(2), a designated company representative must then conduct an annual review of the driver’s driving record and document the review in writing — the review is a separate signed and dated assessment, not the MVR itself.

Up to two years. Per 49 CFR § 391.43(g), the certificate may be valid for up to 24 months. The medical examiner may issue a shorter certificate — one year, six months, or three months — when a medical condition requires more frequent monitoring (for example, hypertension or insulin-treated diabetes mellitus). The shorter date on the certificate controls; that is the date the file must track for renewal.

The query itself is mandated by 49 CFR § 382.701 (Part 382 Subpart G — Drug & Alcohol Clearinghouse), not by Part 391. However, the documented results of the pre-employment full query and each subsequent annual limited query are commonly filed inside or adjacent to the DQ file so they are accessible during a Compliance Review. Query records must be retained per the Clearinghouse rule’s recordkeeping provisions in 49 CFR Part 382 Subpart G.

Yes. Part 391 applies to every driver of a commercial motor vehicle in interstate commerce regardless of employment status. An owner-operator running under their own authority must satisfy every § 391.11 driver qualification and document every § 391.51 record on themselves. An owner-operator leased to another carrier under 49 CFR Part 376 is typically carried in the lessee carrier’s DQ file unless the lease assigns the responsibility differently.