The checks do not stop at hiring. § 391.25(a) requires each carrier, at least once every 12 months, to make an inquiry obtaining the motor vehicle record of each driver it employs, covering at least the preceding 12 months, from each driver licensing authority where the driver held a commercial motor vehicle operator’s license or permit during that period. That is the gathering half, and it happens whether or not anything has gone wrong.

§ 391.25(b) is the half drivers tend not to know exists. At least once every 12 months, the carrier must REVIEW that record to determine whether the driver meets minimum requirements for safe driving, or is disqualified to drive under § 391.15. In making that determination the carrier must consider any evidence that the driver has violated any applicable Federal Motor Carrier Safety Regulations in this subchapter or the Hazardous Materials Regulations, alongside the other matters the section directs it to weigh. This is a judgment, made annually, about whether you may keep driving — and it is made from a record you did not compile and may not have seen.

Two consequences follow for a working driver. The first is that a violation recorded against you surfaces at review time even if nothing was said when it happened. The second is that the annual review is itself a document: § 391.51 requires a note relating to it in the driver qualification file, so the review leaves a trace that outlasts the year it covers.