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Clearinghouse

The Annual Clearinghouse Limited Query

The carrier ran a pre-employment query in March and thinks the Clearinghouse is finished until the next hire. Employment has an annual query of its own.

Every 12 months

Not only at hire

Limited until

A record appears

This year's hires

Still in the cycle

Not the MVR

Different database

OQ

Ahmad Qazi

Founder & CEO, O Trucking LLC

Published: October 3, 2026Updated: October 3, 2026

Fact-Checked by O Trucking Owner-Operator Desk

Walks carriers through the annual limited query without rewriting the full-versus-limited guide

5+ Years Experience80+ Carriers ServedIndustry Data Verified

Written by Ahmad Qazi, founder of O Trucking LLC, drawing on 9+ years dispatching for owner-operators. Learn more about us.

Quick Answer
At least once every 12 months, the employer conducts a limited query of the Drug and Alcohol Clearinghouse for each driver it employs, including owner-operators who drive. Consent is still required. A limited query reports whether a record exists. If it does, the employer must conduct a full query within 24 hours and must not use the driver to perform safety-sensitive functions based on the limited result. A driver hired eleven months ago is still inside the annual cycle. You may query everyone on one fleet date or on each driver's anniversary. Either design is compliant if no driver goes past 12 months. Do not invent a third rule. The which-query explanation is full query versus limited query. The program overview is the Clearinghouse guide. This page is the 12-month habit.

Key Takeaways

  • Limited query at least every 12 months for every driver you employ.
  • Hire-day full queries do not replace the annual limited query.
  • A hit means a full query within 24 hours and the driver waits.
  • A single annual date or a per-driver anniversary both work if nobody exceeds 12 months.
  • A driver hired this year is not exempt until their one-year mark if your program uses one fleet date that would skip them past 12 months. Count the months.
  • This is not the annual MVR review.

At least once every 12 months

The annual Clearinghouse duty is a limited query on each driver the employer uses, at least every 12 months. It is not a suggestion for fleets that have a safety department. A carrier with one driver has one query to repeat. A carrier with thirty drivers has thirty, and a missed name is a missed query, not a rounding error.

The pre-employment full query starts the relationship with the database. It does not retire the annual duty. Mark the date of each driver's last query, full or limited, and make sure the next limited query falls inside 12 months. A March hire who is never queried again is out of compliance the following March, even if no new violation exists. The query is how you would know.

Consent for the limited query has to be in place. Many employers collect a consent that covers the annual queries for a stated period. If that consent expires, the next query cannot run until the driver consents again. An expired consent is not a silent pass. Track the consent date next to the query date.

Limited is enough until it is not

As long as the limited query comes back with no record, you have done the annual check that result supports. You do not also owe a full query that year for that driver. Ordering full queries for everyone every year is not required by the annual rule. It is also not a problem if you do it with consent. The violation is the query you skip, not the extra full query you run properly.

A result that says a record exists is a different event. You no longer have a clean annual check. You have a hit. The next section is mandatory. Do not file the yes in a drawer and wait for the following year's batch. The 24-hour clock is already running, and the driver is already out of safety-sensitive work until the full query is done.

Save the no results. An auditor who asks for the annual queries will not accept a statement that everyone was fine. The portal history is the evidence. Download it on the day you run the batch so you are not reconstructing a year from memory.

A yes is not a completed annual query

It is the start of a full query. The driver does not work safety-sensitive functions while that full query is outstanding.

The 24-hour follow-up full query

Obtain specific consent for the full query if you do not already have it, and pull the full query within 24 hours of the limited hit. Read it. If the driver is prohibited, they stay prohibited until the return-to-duty process is complete in the Clearinghouse. If the full query shows the record does not prohibit them, document that and only then return them to safety-sensitive work, assuming the rest of the qualification file is current.

Missing the 24 hours and continuing to dispatch is the failure mode this clock exists to prevent. Do not use the driver's next day off as the moment you get around to it if they are scheduled tomorrow. Pull them off the schedule first, then query. The order matters.

The meaning of full versus limited, in more detail, stays on the full-versus-limited page. Do not copy that article here. The only annual point is that the limited query is the routine, and the full query is the exception you must finish fast.

Drivers hired this year are not exempt from the cycle

A driver hired eleven months ago is still in the annual cycle. The pre-employment query is not a coupon good for eighteen months. If your program uses each driver's anniversary, that driver is due at twelve months from the pre-employment query. If your program uses a single fleet date, you still have to query that driver before any gap exceeds 12 months. A January fleet date does not let a February hire wait until the January after next.

New hires between fleet dates get a full query at hire and then join the next annual run, or get their own reminder, whichever keeps the gap at or under 12 months. Write the choice down. A choice you cannot explain becomes a third, imaginary rule, which is what this page tells you not to invent. Two designs are enough: one calendar for the fleet, with anyone who would exceed 12 months pulled forward, or an anniversary per driver. Pick one. Put the dates where dispatch can see them.

Drivers who leave and return are new uses of the driver. Do not assume last year's limited query covers a rehire. Rehire follows the pre-employment full-query rule before they drive again. The annual page does not swallow the hire rule.

How to run the day without missing a name

Make a roster from the people who actually drive, not from an old payroll sheet. Include the owner if the owner drives. Include part-time drivers. Include anyone who performed a safety-sensitive function in the last year and is still employed. Run the limited queries. Record consent problems the same day. Remove those drivers from the dispatch board until consent and the query exist.

Then look at hits. Full query, same day if you can, and inside 24 hours in every case. Do not leave a hit for the Friday meeting if today is Tuesday and the driver is on a load. Take the load off the driver.

The Clearinghouse guide covers registrations, designations, and reporting. Use that guide when the portal itself is the problem. Use this page when the only question is whether March's hire query lasted all year. It did not.

This is not the annual driving-record review

391.25 wants a state motor vehicle record and a review note at least every 12 months. The Clearinghouse wants a limited query at least every 12 months. They can fall in the same month. They cannot be the same document. A clerk who files the MVR and writes Clearinghouse done on the folder has completed neither the note's job nor the query's job.

Keep the dates on one sheet with two columns if that helps the habit. The columns are not interchangeable. A missed MVR and a missed query are two findings. Doing one early does not fill the other column.

Pro Tip

Once a year is the outside edge, not the target that includes a grace month. If the last limited query was October 3, the next one is due before the following October 3.

Store the result with the driver's drug-and-alcohol records for the retention period those rules require. Do not apply the six-month hours-of-service shred date to Clearinghouse queries. Different part, different clock. When someone leaves the company, keep the queries you ran. The annual duty stops when they are no longer your driver. The record of the queries you already ran does not evaporate with their key.

If a driver is off work for weeks inside the year, the 12-month query does not pause. Employment, not the number of miles, is what puts them on the roster. Query them before they return if the 12 months would lapse while they are out, and do not let the first day back be a safety-sensitive day with a stale query. A medical leave is not a Clearinghouse exemption.

When you change consortium administrators, export the query history before the old login dies. The new vendor cannot invent last year's no-record result. If the history is gone and the 12 months have not been documented, run the queries again and write down the gap rather than backdating a screenshot. A reconstructed date is a false record. A late query you actually run is at least an honest one, and the driver stays off the board until it is done.

Frequently Asked Questions

We ran a full query at hire eight months ago. Is the annual query due yet?

The annual limited query is due before 12 months pass. Eight months means you still have time. It does not mean the hire query counts as the annual query forever.

Our annual date is January and we hired someone in November. Do we skip them until next January?

No, if next January would put them past 12 months from the pre-employment query, and you must not exceed 12 months between queries. Query them by the 12-month mark, or include them in a cycle that never lets any driver pass 12 months. Do not invent a third schedule.

The limited query found a record. Can the driver work tomorrow?

Not on the limited yes. Obtain a full query within 24 hours and do not assign safety-sensitive work until that full query shows the driver is not prohibited.

The driver will not consent to the annual query.

Then you cannot complete the query and you cannot use the driver for safety-sensitive functions. Consent refused is a stop.

Does this replace the yearly MVR?

No. 391.25 is the state driving record and a review note. The Clearinghouse is drug and alcohol information. Keep both clocks.

I am the only driver. Do I still run an annual query on myself?

Yes. Owner-operators who drive are employed drivers for this purpose. Use the consortium or administrator design so the query actually happens. There is no solo exemption.

Put the next limited query on a date inside 12 months.

O Trucking does not run Clearinghouse queries. After authority is ACTIVE, dispatch is a flat weekly fee.

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