Compliance advisors are telling carriers to stop assuming their rosters are clean and start proving it. As FreightWaves reported, the safest move right now is to audit every driver — not just new hires — to confirm licensing, medical, and eligibility status before the next load leaves the yard. The reason is simple: multiple federal changes are converging, and paperwork gaps are quickly turning into out‑of‑service orders and liability exposure.
One of the biggest pressure points emerged this week. On October 9, the Federal Motor Carrier Safety Administration re‑issued a temporary waiver that will let interstate CDL and CLP holders — and their carriers — rely on a paper medical examiner’s certificate for up to 60 days after the exam while state systems catch up with the new electronic process. The waiver runs October 13, 2025 through January 10, 2026. That buys time, but it doesn’t eliminate risk: if an MVR still shows an expired or missing medical status, a driver can be flagged at the roadside and the company’s decision to dispatch that driver can become Exhibit A in a negligent‑entrustment claim.
Why the waiver matters: the medical certification pipeline is mid‑transition to FMCSA’s NRII “no paper cards” model. As of October 9, industry reporting indicates only 38 states and the District of Columbia have fully implemented NRII, leaving a dozen states still relying on paper in whole or in part. That uneven adoption is exactly where compliance cracks open — a clean physical in the cab, a lagging update in the database, and a motor carrier that can’t prove real‑time due diligence when something goes wrong.
There’s also a market angle to this administrative risk. Fresh FMCSA operating‑authority data analyzed this week shows more carriers exited than entered the market in Q3, with September marking the lowest new‑authority grants since February. In a capacity environment that’s already thinning, losing drivers to avoidable credential hiccups is an own‑goal fleets can’t afford — and one shippers will remember at bid time.
What an “all‑drivers” audit should cover right now:
– Pull current MVRs and verify CDL class, endorsements, restrictions, and medical status for every driver — including slip‑seat, casual, temp, and leased‑on owner‑operators. Document any use of the paper medical certificate during the 60‑day window and set automated reminders to confirm when the MVR reflects the electronic update.
– Re‑run annual Drug & Alcohol Clearinghouse queries early for the entire roster, and confirm return‑to‑duty progress where applicable. Given state‑level downgrades tied to Clearinghouse “prohibited” status, a stale query is a liability multiplier.
– Validate onboarding and file maintenance disciplines: ELDT certificates, road tests, prior‑employer safety history, and right‑to‑work documentation where applicable. Make sure your DQF indexes make it obvious — to auditors and plaintiffs — that you knew the status of each driver on the day you dispatched them.
– Close the loop with operations. If dispatchers or planners are judged on loads covered but not on driver eligibility compliance, you have a policy gap. Tie load assignment permissions to live eligibility checks so an out‑of‑status driver simply can’t be assigned.
The bottom line for safety leaders: the waiver reduces friction while NRII matures, but it also shifts the burden onto carriers to prove continuous monitoring. That’s why the advice to “audit everyone” isn’t overkill; it’s how you keep a clerical lag from turning into a roadside out‑of‑service, a canceled load, or a lawsuit you didn’t need to fight.
Sources: FreightWaves, FMCSA, Trucking Dive, CDLLife
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