Over the last several months, we here at STC have been reflecting on our work assisting motor carriers as they build and improve their safety and compliance programs. This process can often include an audit of the motor carrier’s programs. In doing so, we’ve observed several consistent compliance gaps. Because trucking is a community, we thought we’d share some of these to call attention to common problems and what could be simple solutions because, as the safety tide rises, so too do all boats (or trucks, in this case).

This month, we’ll focus on motor carrier drug and alcohol testing programs. A trend we’ve observed here is that in the five years since the implementation of the Federal Motor Carrier Safety Administration’s Drug & Alcohol Clearinghouse, some motor carriers are still missing the boat. In 2024, there were a total of 12,283 safety investigations of motor carriers. These resulted in 83,081 total violations being issued. Of these, over 12% were for failing to comply with Clearinghouse rules. The impacts of these violations can be seen on roadside, where over 4,000 drivers were put out of service in 2024 alone for Clearinghouse violations.

Two of the top five violations resulting from safety investigations are directly related to Clearinghouse compliance, with “failing to conduct a pre-employment query” taking the top spot. The other is for “failing to conduct an annual query” following close behind. In our experience, other than some motor carriers still being unaware of the Clearinghouse rules, many of these violations are associated with faults in the initial and ongoing driver qualification process.

Most often, failing to run an annual query on time is a matter of organization and adherence to compliance dates. With so many expiration dates to monitor (annual MVR, annual review, and medical exam certification, for example), it can be difficult to keep them all straight. To combat this, we recommend that, to the extent practical, motor carriers synchronize their annual review, MVRs and clearinghouse check. Often, the Clearinghouse query can be ordered through the same vendor that provides a carrier’s MVRs and the annual review rules require motor carriers “must consider any evidence the driver has violated any applicable Federal Motor Carrier Safety regulations.” This includes Clearinghouse data.

Sadly, violations for no pre-employment query are often a result of the desire to hire drivers as quickly as possible. An established golden rule is to ensure that drivers are not dispatched without first passing a drug test, often accomplished by making employment contingent on a negative drug test result. But that’s not enough. Before dispatch, the motor carrier must also verify the Clearinghouse shows the driver as not prohibited from operating a commercial motor vehicle too. One way some motor carriers are ensuring compliance is by including the Clearinghouse check earlier in the driver recruitment process. At only $1.25 per query, some find this an affordable way to cull the field by eliminating candidates that are currently prohibited and have not yet begun the return-to-duty process.

While it’s easy to complain that the Clearinghouse is just another burdensome regulation, the benefit of keeping unqualified drivers off the road clearly outweighs the effort required. Simple fixes can help incorporate these checks into the initial and ongoing driver qualification requirements without placing additional stress on the process and the people charged with this