Leaves are falling, freight is spiking, and weather’s about to get real. Whether you’re moving holiday parcels, running storm-response crews, or switching to winter service routes, seasonal drivers can make or break Q4/Q1 operations. The key is speed without skipping the DOT and risk-control steps that keep your authority (and brand) protected.
Below is a practical checklist-driven guide—built for mixed fleets—to help you recruit, screen, and onboard seasonal CDL and non-CDL drivers the right way.
Before you post a job, lock in the vehicle profiles you’ll assign and confirm whether each role truly requires a CDL—or can be covered by a non-CDL CMV driver. As a reminder, CDL is generally triggered at 26,001+ GVW/GVWR or when the vehicle requires hazmat placards; non-CDL CMVs (10,001–26,000 GVWR) are still subject to Part 391 when operating in interstate commerce. Getting this wrong is one of the costliest mistakes fleets make.
Why it matters now: Seasonal assignments shift quickly (add a trailer, swap to a tank, move a lift-gate route) and the license/endorsement requirements can change with them. Build postings that specify vehicle class, trailer use, and any endorsements (tank, hazmat, passenger), so candidates self-select accurately.
Don’t trim your application “just because they’re seasonal.” A compliant driver application should capture identity and address history, license numbers and issuing states, detailed driving experience, 3-year crash/violation history, and 7-year CMV employment history prior to the most recent 3 years, plus any suspension/denial disclosures. Ensure the driver certifies completeness and accuracy. This protects you from missed red flags and FCRA issues.
Then verify basics quickly: age 21+ for interstate work, valid CMV license, physical qualification (DOT medical), English proficiency for public/official interactions, and road test certificate (or equivalent). Document these checks in the file.
Season doesn’t waive compliance. Obtain written consent and immediately complete:
MVRs in all states where the driver held a license within the last 3 years.
Prior-employer Safety Performance History (SPH) inquiries for DOT-regulated employers in the last 3 years—track your good-faith contacts and file responses.
FMCSA Drug & Alcohol Clearinghouse full query (CDL only) before safety-sensitive work. Keep documentation in the DQF.
Best-practice adds: CDLIS (license history), PSP (5-year crash/3-year inspection record), and an FCRA-compliant criminal screen.
Remember, FCRA steps (disclosures, Summary of Rights, dispute timelines) still apply. Missing them introduces legal exposure that won’t feel “seasonal” to your counsel.
Every driver needs a Driver Qualification File (DQF) and an SPH (Driver Investigation History) file, and both must be 100% complete within 30 days of employment. Retain DQFs through employment plus 3 years; keep SPH records secure with limited access. Digitizing this process shortens time-to-dispatch and prevents “lost paperwork” during peak season.
DQF must include (at minimum): the DOT application, CDL copy, medical exam report & National Registry verification, road test certificate (or CDL equivalent), and skill performance evaluation if applicable.
Learn more about specific requirements by industry in Foley's full Driver Qualification File Compliance Guide for Mixed Commercial Fleets.
Seasonal gaps often mean expired medical cards, changed licenses, lapsed training, or drivers who were removed from random pools. Before dispatching a rehire, run a concise quick-check:
License & medical: Confirm license class/endorsements match the new assignment; verify med card is current; pull a fresh MVR if there’s any doubt.
Background & testing: Update employer lists and accident/violation declarations; for CDL drivers, complete a Clearinghouse full query, assess whether a pre-employment drug test is required (or document the exception), re-enroll in the random testing pool, and reissue drug/alcohol policy acknowledgments.
Road test if anything changed: New vehicle class, added trailer/towing, or major equipment differences (PTO/hydraulics, lift-gate, bucket).
Training refreshers: Backing/spotter procedures (all industries), plus targeted modules (e.g., PTO & hydraulics for ready-mix/waste, towing and brake checks for landscaping, aerial device/work-zone for utilities, hazmat basics/spill response for fuel oil, lift-gate/high-stop safety for delivery).
With winter approaching, bake in weather-specific refreshers: chain-up rules, cold-start inspections, brake performance in ice/snow, and incident reporting during storm callouts. Document each refresher in the file—if it isn’t documented, it didn’t happen.
Mixed fleets face different hot spots:
Utilities/Telecom: Aerial device use and energized-line proximity, especially on storm response. Keep aerial device training and work-zone certs front-and-center.
Waste & Recycling: High route density with frequent backing and hydraulic pinch points; capture route-specific road tests and spill-response acknowledgments.
Delivery/Courier: High-frequency stops, lift-gate injuries, and cargo claims; require lift-gate training and parcel securement SOP sign-offs.
Fuel/Oil & Hazmat: Surge/baffle handling in slick conditions; verify tank/hazmat endorsements and hazmat training records.
Align winter dispatch plans (short-haul vs. ELD duty, personal conveyance/yard move rules) and ensure device/app access is configured before first shift.
Compliance isn’t one-and-done when the snow flies. Monitor expirations (CDLs, med cards, endorsements) and set 30/60/90-day alerts for anything due during the season. Perform the annual MVR and review, refresh violation lists, and run quick internal audits to confirm DQF/SPH completeness and access controls. Automating pulls and alerts eliminates spreadsheet chaos when your operations team is busiest.
Learn Why Continuous MVR Monitoring Isn't Optional for Employers in 2025.
Scrutinize histories for on-duty drug/alcohol violations, hit-and-run in a CMV, felony involving a CMV, or suspended/revoked CMV licenses. Don’t rely on memory of last season—situations change. If a driver can’t clear these checks, don’t dispatch.
Seasonal drivers help you scale safely through holiday peaks and winter weather—but only if your screening and files are airtight. The formula is simple: define license needs accurately, hire and screen with discipline, complete DQF + SPH within 30 days, re-qualify returning drivers with a tight checklist, and document training tailored to winter realities and your industry risks. Digitize what you can, and keep proof at your fingertips for audits, insurance, and—worst case—litigation.
Foley’s all-in-one platform streamlines applications, automates MVR pulls and renewal alerts, manages Clearinghouse queries, and keeps mixed-fleet DQFs audit-ready—so you can onboard seasonal CDL and non-CDL drivers faster and safer.
See firsthand how to simplify compliance with a personalized demo.