This guide is brought to you by Driver Pipe — Applicant Tracking, Recruitment Tools, and DQ File Management for smaller carriers.
This information is provided for general informational purposes only and does not constitute legal advice. Regulations change — motor carriers are responsible for verifying and complying with current FMCSA requirements.
When you hire a CDL driver, federal law requires you to look into where they've worked before. Here's what that means in practice — and how to stay compliant without drowning in phone calls and paperwork.
What the Regulation Requires
Federal regulations (49 CFR § 391.23) require you to investigate each driver's safety performance history with DOT-regulated employers where the driver operated a commercial motor vehicle (CMV) within the past 3 years.
This investigation must be completed within 30 days of the driver's start date.
Who You Need to Contact
Only previous employers where the driver operated a CMV under DOT regulation. Non-CMV employers — retail, office work, and the like — don't need to be contacted.
- That the driver was employed or contracted there, including the dates
- Any accidents involving the driver on the employer's accident register (§ 390.15) within the past 3 years
Documenting a Good Faith Effort
You're required to make a good faith effort to reach each previous employer. Every contact attempt — by phone or email — must be documented, even when you never get a response. If an employer never replies, your documented attempts are what demonstrate you met the requirement.
How Driver Pipe Makes It Simple
- Previous employers pull straight from the driver's DOT application — no re-typing
- Send a verification request by email directly to each employer from the system
- Replies are recorded automatically and you're notified by email
- Every request, response, and contact attempt is logged and included in the DQ file download
A Separate Requirement: Drug & Alcohol History
Employment and accident verification is one part of § 391.23. The regulation also requires you to investigate a driver's drug and alcohol violation history — but this is handled through a different process.
As of January 6, 2023, a pre-employment Drug and Alcohol Clearinghouse query satisfies this requirement for FMCSA-regulated employers. You no longer need to ask previous employers whether the driver tested positive or refused a test. The query requires the driver's consent, and if a driver refuses to consent to the Clearinghouse query, you can't let them operate a CMV.
One exception: if the driver worked under a DOT mode other than FMCSA, you still request that drug and alcohol information directly from those employers.
Because this runs through the Clearinghouse rather than a previous-employer email, it sits outside Driver Pipe's verification flow — but it's part of the complete picture, so we mention it here.
When Is the Verification Complete?
You can consider the employment and accident investigation complete once, for every DOT-regulated employer in the past 3 years:
- Employment and dates are verified (or a good faith effort is documented)
- Accident history from the employer's accident register (§ 390.15) has been requested and reviewed
- All contact attempts and responses are documented, including unsuccessful ones
- The investigation was completed in good faith within 30 days of the driver's start date
If a driver has had no previous DOT-regulated employers in the past 3 years, you simply note that in their work history and the requirement is satisfied.
With Driver Pipe, all of this is saved automatically and included as a CSV file in the driver's DQ file — so your documentation is always audit-ready.
Let Driver Pipe Handle the Busywork
Previous employer verification is one of those tasks that's simple in theory and tedious in practice — re-typing employer details, chasing replies, and keeping a paper trail that holds up in an audit. Driver Pipe is built to take that off your plate:
Previous Employer Verification with Driver Pipe
- No data entry — previous employers pull straight from the driver's DOT application
- One-click requests — send a verification email to each employer without leaving the system
- Responses log themselves — replies are recorded automatically and tied to the right driver
- Always audit-ready — every request, response, and attempt is included in the DQ file download
It's part of a complete system for recruiting drivers and managing DQ files — without enterprise software or enterprise pricing.
Stop chasing previous employers by phone.