Who this is for: fleet managers, compliance assistants
Road Test Certificate for CDL Drivers — Basics
Carriers must administer a road test to each new driver before CMV operation, unless the driver holds a valid CDL for the class of vehicle to be operated. If a CDL substitutes for the road test, document the CDL details in the DQ file.
When a road test is required
49 CFR 391.31 requires carriers to administer a road test to each new driver before operating a CMV. The road test must be conducted on a vehicle representative of the type the driver will operate. The carrier designates the road test examiner, who must be a qualified licensed driver.
When a CDL substitutes for the road test
Under 49 CFR 391.33, a valid CDL for the class of vehicle to be operated may substitute for the road test. If you accept the CDL as a substitute, you must note the CDL number, class, endorsements, and issuing state in the DQ file. This is a standard practice for most carriers hiring drivers with existing CDLs.
Road test certificate contents
If a road test is given (not substituted by CDL), the certificate must include: the driver's name and address, the date of the test, the vehicle's license number and type, the route used, and the examiner's name and signature. Both the driver and the examiner sign the certificate. The certificate is then filed in the DQ file where it stays for 3 years after the driver leaves.
Who qualifies to conduct the road test
49 CFR 391.31(d) requires the road test examiner to be a licensed driver with at least 2 years of experience operating the type of CMV the applicant will be driving. The examiner does not need to be a government official or certified third-party tester — a carrier's safety director, dispatcher, or experienced driver may serve as examiner if they meet the experience requirement. Document the examiner's qualifications and retain that documentation in your records.
CDL substitution in practice — how to document it
When a valid CDL substitutes for the road test under 49 CFR 391.33, the carrier must note the CDL number, class, endorsements, and issuing state in the DQ file. Some carriers do this on a simple form; others add a notation to the driver application or DQ file cover sheet. The notation must be present — skipping this step means the DQ file has no documented road test or CDL waiver, which is a deficiency. The CDL class must match the vehicle the driver will operate; a Class B CDL does not substitute for a Class A road test.
Common documentation mistakes with CDL substitutions
Carriers frequently forget to document the CDL substitution even when they've clearly accepted the CDL and the driver has been operating for weeks. If an investigator opens a DQ file and finds no road test certificate and no notation of a CDL substitution, that's a deficiency — regardless of whether a copy of the CDL is in the file. The presence of the CDL copy doesn't speak for itself; the substitution notation has to be there explicitly. A brief written record — CDL number, class, endorsements, issuing state, the date it was reviewed, and who reviewed it — is all that's needed. Create it on day one and it won't be a problem later.
Frequently Asked Questions
Can a CDL with restrictions substitute for the road test?
Yes, but the CDL must be for the class of vehicle to be operated. A CDL with a restriction that prevents operation of the vehicle (such as the air brake restriction on a truck with air brakes) does not substitute — the carrier would need to conduct a road test in a vehicle appropriate to the driver's actual CDL.
What if the driver has a CDL but has never driven that specific type of vehicle?
A valid CDL of the appropriate class is a legal substitute for the road test under 49 CFR 391.33, even if the driver hasn't operated that specific vehicle or configuration before. The regulation permits the substitution. Whether you choose to conduct a road test anyway — for operational rather than regulatory reasons — is a carrier policy decision.
How long must the road test certificate be kept in the DQ file?
Under 49 CFR 391.51, the road test certificate — or the CDL substitution notation — must be retained for 3 years after the driver leaves the company. If you accepted the CDL as a substitute and made a written notation, keep that notation for the same period. An FMCSA investigator reviewing a file for a driver who left two years ago still needs to find the road test documentation.
If the carrier administers the road test but discovers the driver performed poorly, can they still certify them and document the result?
The road test examiner must certify that the driver demonstrated the ability to safely operate the vehicle. If the driver performed unsatisfactorily, the examiner should not certify the test. Document the failed test in the DQ file, do not allow the driver to operate in a CDL-required role, and determine next steps — which may include additional training and a retested certificate or declining to hire.