Is the DOT Physical Form Required in the Driver Qualification (DQ) File?

This is a common question among motor carriers, and the answer might surprise you. According to section 391.51 of the Federal Motor Carrier Safety Regulations (FMCSRs), the DOT physical form—often referred to as the “long form”—is not specifically listed as a required item in the Driver Qualification (DQ) file.

So, what is required?

For non-CDL drivers, motor carriers are required to keep a copy of the medical examiner’s certificate in the DQ file. This certificate serves as proof that the driver is medically qualified to operate a commercial motor vehicle.

For CDL drivers, the rules are a bit different. Instead of keeping the certificate, carriers must obtain a motor vehicle record (MVR) that reflects the driver’s medical certification status. This MVR must be obtained within 15 days of the driver’s DOT physical exam.

Now, what about the long-form physical exam itself?

The medical examiner is responsible for keeping the original long-form on file at their office. If a motor carrier happens to receive a copy, they are not required to keep it in the DQ file. However, many carriers choose to request and review these forms as a best practice. Why? Because at the end of the day, the carrier is responsible for ensuring that only medically qualified drivers are behind the wheel.

If you do decide to request a copy of the long-form physical, be sure to handle it with care. It must be requested, stored, and used in compliance with federal and state privacy and employment laws. This helps protect both the driver’s personal information and your company from potential legal issues.

Also, don’t forget about your mechanics. If they operate commercial motor vehicles (CMVs) on public roads—even occasionally—they must also be properly qualified. This includes meeting the same medical and licensing standards as regular drivers.

To help stay organized and compliant, consider using tools like the FleetMentor Driver Qualification Checklist. It’s a great resource for auditing both new and existing DQ files. And if you operate intrastate, make sure to check your state’s specific requirements under the “Qualification of Drivers” section.

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