1 The Decision
2 Formation
3 Registration
4 Insurance
5 Compliance
6 Launch

Phase 5: Compliance — Step 2 of 5

Key Takeaways

  • The driver checklist has 10 setup items -- the drug testing consortium and FMCSA Clearinghouse are where most new carriers fail
  • One Clearinghouse screenshot proves three things: you registered as employer, registered as driver, and ran the query. Total cost: $1.25.
  • A positive drug test costs $2,000-$5,000 in direct SAP costs plus months of zero revenue. The consortium that prevents it costs $199/year.
  • Your DQ file is 10 documents in a $20 folder. The auditor will ask for it. Have it ready.
  • Annual driver compliance costs under $520 -- the cheapest checklist to maintain and the most expensive to ignore

Ten items. Most take under 30 minutes each. Total cost: $150-$375. This is the checklist that trips up more new carriers than the other three combined — not because it is hard, but because most carriers do not know about half of it until an auditor asks.

Complete these 10 items before your truck moves

Work through them in this order. Items 1-3 are the ones most carriers miss.

1. Join a drug testing consortium. You cannot test yourself. Even solo. A consortium manages your random testing pool, schedules tests, and handles paperwork. Motor Carrier HQ: $199/year flat, tests included. DOT Compliance Group: $299/year. National Drug Screening: $150-$200/year. Sign up online in 15 minutes. What you get: enrollment certificate PDF emailed within minutes.

2. Register in the FMCSA Clearinghouse — BOTH sides. Go to clearinghouse.fmcsa.dot.gov. Register as an employer using your USDOT number. Then register separately as a driver using your CDL. Two registrations, same portal, 10 minutes each. Free. What you get: dashboard access showing your registered status on both sides.

3. Run a pre-employment Clearinghouse query on yourself. From your employer account, run a full query. Provide consent from your driver account. $1.25. Do this before you drive a single mile under your authority. Penalties for skipping: up to $5,833 per violation. What you get: query result showing “no violations found” (screenshot this — it proves all three Clearinghouse items are done).

4. Take a pre-employment drug test. Through your consortium at a SAMHSA-certified collection site. $50-$80. Results in 1-3 days. Must be negative before you perform any safety-sensitive function. Federal 5-panel: marijuana, cocaine, opiates, amphetamines, PCP. Marijuana is on the panel in all 50 states regardless of state law. What you get: CCF Copy 4 or MRO report showing NEGATIVE result.

5. Get your DOT physical. Current medical certificate from a National Registry examiner. $75-$200. Valid up to 2 years. As of June 2025, results transmit electronically to your state DMV. What you get: medical certificate card (Form MCSA-5876) — photograph the front and back.

6. Have your CDL and endorsements current. Class A for tractor-trailers. Add H (hazmat), N (tanker), T (doubles/triples) as your freight requires. $50-$300 at your state DMV. What you get: your CDL — photograph the front.

7. Build your DQ file. Buy a J.J. Keller kit ($20). Fill in all 10 documents on yourself: employment application, MVR, CDL copy, medical certificate, medical exam report, safety performance history, drug/alcohol records, road test certificate (CDL waives this), annual driving record review, certificate of violations. File it. What you get: a physical folder with 10 tabs, each containing the required document.

8. Write your drug/alcohol policy. Your consortium provides a template. Fill in your company info, sign it, file it in your DQ file. What you get: signed policy PDF.

9. Designate yourself as DER. Designated Employer Representative — the person who receives test results and makes removal decisions. If you are solo, that is you. Note it in your drug policy. Free. What you get: designation letter or notation in your policy.

10. Pull your MVR. $5-$15 from each state where you held a license in the past 3 years. Goes in your DQ file. What you get: motor vehicle record document.

Total setup cost: $150-$375. Total setup time: about one day of focused paperwork.

One Clearinghouse screenshot proves three things at once

Four of the top 10 FMCSA audit violations are the same system:

ViolationCarriers Cited (2025)Maximum Fine
No pre-employment Clearinghouse query2,696Up to $5,833 per violation
No annual Clearinghouse query2,471Up to $5,833 per violation
Employer not registered in Clearinghouse1,057Up to $5,833 per violation
Using driver before receiving query result1,050Up to $5,833 per violation

Total fix cost: $2.50 in query fees and 30 minutes of registration. Failure to comply can result in penalties up to $5,833 per violation.

The carriers who fail are not bad operators. They are operators who did not know about the Clearinghouse, or assumed a solo operation was exempt, or registered as a driver but forgot the employer side.

When you run the pre-employment query (item 3 above), screenshot the result. That one screenshot proves: you registered as an employer, you registered as a driver, and you ran the query. Three audit checkboxes from one image.

Full vs. limited queries

TypeCostConsentWhat It ShowsWhen
Full$1.25Yes (driver electronic consent)Complete violation detailsPre-employment
Limited$1.25NoWhether a violation exists (yes/no)Annual check

Run a full query before you start. Run a limited query every year after. $1.25 per year to avoid penalties up to $5,833 per violation.

Marijuana is on the federal test panel in all 50 states

Federal test. Federal consequences. The DOT has been explicit: “It remains unacceptable for any safety-sensitive employee subject to drug testing under the DOT’s drug testing regulations to use marijuana.”

A positive in Colorado, California, or any legal state triggers the same cascade:

  1. Immediate removal from all safety-sensitive functions
  2. Violation reported to the FMCSA Clearinghouse
  3. CDL automatically downgraded by your state (since November 2024, no hearing required)
  4. Referral to a DOT-qualified Substance Abuse Professional (SAP)
  5. Mandatory treatment program
  6. Return-to-duty test (directly observed)
  7. Minimum 6 follow-up tests over 12 months (SAP can extend to 5 years)

No pending rule change. No exception for medical cards. No exception for off-duty use. No exception for CBD products containing trace THC.

The math: $199/year for a consortium. $2,000-$5,000 for the SAP return-to-duty process, plus two to six months of zero revenue while the truck payment and insurance do not pause. Many owner-operators who go through this process do not survive financially.

The driver calendar — what recurs and when

WhenWhatCost
WeeklyReview HOS logs for errors or unassigned eventsFree
AnnuallyPull MVR from each state$5-$15
AnnuallyAnnual Review of Driving Record (document it)Free
AnnuallyCertificate of Violations (signed self-cert)Free
AnnuallyClearinghouse limited query$1.25
AnnuallyRenew consortium membership$99-$299
Every 2 yearsDOT physical renewal — schedule 1-2 months before expiration$75-$200
As neededPost-accident drug test (within 32 hours drugs, 2-8 hours alcohol)$50-$100
As neededReasonable suspicion test$50-$100

Set calendar reminders for every annual and biennial item. An expired medical card means an expired CDL — there is no grace period.

Annual ongoing cost: under $520. The cheapest compliance bucket and the most expensive to ignore.

Adding your first driver: the same 10 items, applied to someone else

When you hire your first driver, complete all 10 items before they perform any safety-sensitive function:

  1. Employment application (49 CFR 391.21 form, completed and signed)
  2. MVR pull from each state where the driver held a license in past 3 years ($5-$15/MVR)
  3. Safety performance history request — contact previous employers within 30 days (391.23(d))
  4. Clearinghouse full query — $1.25, driver must provide electronic consent
  5. Pre-employment drug test — negative result required before driving ($50-$80)
  6. Copy of CDL — verify class and endorsements
  7. Medical card — verify current and examiner is on the National Registry
  8. Road test or CDL verification — CDL waives the road test requirement
  9. Written drug/alcohol policy — distribute and get signed acknowledgment
  10. Certificate of violations — driver’s signed self-certification of moving violations

Open a DQ file. Insert all 10 documents. Set calendar reminders for annual updates. The same system that works on yourself works on every driver you add.

Last updated:

The Driver Checklist FAQ

Do solo owner-operators need drug and alcohol testing?

Yes. 49 CFR Part 382 has no fleet-size threshold. Every CDL driver performing safety-sensitive functions must enroll in a testing consortium. You cannot test yourself. This is the most common compliance failure in new entrant safety audits, with fines up to $5,833 per violation.

What is the FMCSA Clearinghouse and how do I register?

The Clearinghouse is a federal database tracking CDL driver drug and alcohol violations. As a solo owner-operator, you must register as BOTH an employer (using your USDOT number) and a driver (using your CDL). Run a pre-employment full query on yourself before operating and an annual limited query every year. Cost: $1.25 per query.

What happens if I use marijuana in a state where it is legal?

Federal law controls DOT drug testing. Marijuana remains Schedule I federally. A positive result triggers immediate removal, Clearinghouse reporting, automatic CDL downgrade, and the SAP return-to-duty process costing $2,000-$5,000. No exceptions for medical cards, off-duty use, or CBD products with trace THC.

How many documents go in a Driver Qualification file?

Ten documents per 49 CFR 391.51: employment application, MVR, CDL copy, medical certificate, medical exam report, safety performance history, drug and alcohol records, road test certificate (CDL waives this), annual driving record review, and certificate of violations.

How often do I need a DOT physical?

Every 2 years maximum. The examiner can issue a shorter certificate for medical conditions. Schedule renewal 1-2 months before expiration. Use only examiners on the FMCSA National Registry. As of June 2025, results transmit electronically.

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