If you have more than one terminal, can you keep your Driver Qualification Files at multiple physical locations? It may seem like a simple question, but depending on how your company is constructed, the answer may not be.
The rules as they are written essentially tell you that you must choose and identify with the DOT one of your terminals as the “principal place of business.” Normally, but not always, this would be a corporate headquarters, where presumably you store all the records for the whole company.
There is considerable flexibility about which terminal you call this principal place of business, but it must feature the appropriate personnel who have high-level access to driver records, especially drug and alcohol and hazmat records. Again, this doesn’t seem very complex, since even companies with multiple terminals can easily function in this capacity.
The rules can be trickier for growing companies who open new terminals or buy smaller ones. If a company looks to expand into a new region a bit further away across the country, it may take some time to attain and go through the Driver Qualification Files for that terminal. Big companies who buy smaller ones might like to allow new terminals some continued autonomy to ease the transition of administration. Some acquirers might keep this set up permanently, since if it’s not broke, there’s no need to fix it. Records may never leave that terminal, especially if some essential safety personnel stay and continue to work there. These scenarios can be problematic if your name is drawn for an audit.
The DOT has no issue with records staying at different locations provided the records:
“...shall be made available for inspection upon request by a special agent or authorized representative of the Federal Motor Carrier Safety Administration at the motor carrier's principal place of business or other location specified by the agent or representative within 48 hours after a request is made.”
FMCSA reg 390.29
Our current age of rushed shipping can make this possible by snail mail, but if the new terminal is in California and your principal company headquarters is in Texas, this might be a logistical problem. The DOT remains unsympathetic to the challenges of running a multiple terminal company; it has a job to do, and doesn’t mind collecting easy fines.
Now more than ever, the easiest solution to this logistical puzzle is to go digital. FMCSA regulations allow keeping copies of documentation in lieu of originals (390.31), which has been widened in the last few years to include electronic copies and electronic signatures. If all of your records are available online, you needn’t worry about where records physically live. Wherever the auditor comes to inspect, they would only need internet access and a password into your company account. Easy-to-configure compliance systems like A-Suite fulfill this need for safety personnel quite well since all of the records are accessible any time from anywhere. One of our clients even reported an audit that took place remotely (a likely trend to increase in the future to save the DOT travel expenses) via the auditor’s work computer that went quickly and smoothly.
Going digital can also help other logistical challenges, such as drivers who relocate to another terminal or the disposal of records you no longer need to retain. Rather than send a big stack of papers down the road to that new terminal and hope they make it there in one piece, you can click a couple of times on the computer and switch that driver over to a new safety manager and terminal. You can delete files that have passed out of their required retention times with a couple of clicks instead of spending hours shredding documents or digging through files deciding if individual pieces of paper should be kept or trashed. Plus, with less physical paperwork, you get to stop worrying about buying and going through paper and ink.
Professional driving has been moving towards total digitalization and will continue to do so to make sweating bullets before an audit a thing of the past. If you have logistic concerns about where your records are, that’s another great reason to consider doing the same. If you save a bit of money and avoid unnecessary fines by getting all of your records into one digital space, why are you still using paper?
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