Whether you are starting a program from nothing or tightening one that grew up informally, the same checklist applies: know which roles are covered by which authority, put the policy in writing and collect the signed receipts, name an employee as your DER, set up the pools, arrange the collection workflow, run the previous-employer inquiries and Clearinghouse queries on every new driver, train the supervisors, and keep the records for the periods the rule sets. This guide walks each item with enough detail to act on.
The short version
- Classify every role: DOT-covered, policy-covered, or not covered
- Write the policy down, have it reviewed before enforcement, and keep each driver's signed certificate of receipt (49 CFR 382.601(d))
- Name your DER: an employee of the company, never a service agent (49 CFR 40.3), and make sure they know it
- Run the previous-employer inquiry and the Clearinghouse query on every new driver before the first safety-sensitive function (49 CFR 40.25, 382.701)
- Set up random pools, collection logistics, and supervisor training (49 CFR 382.305, 382.603)
- Keep every record an auditor could ask for, for the period 49 CFR 382.401 requires