You Ran a Clearinghouse Query. You Still Haven't Checked the Drug & Alcohol BASIC.

A carrier comes through your system with a clean Clearinghouse result. No violations, no refusals, nothing. You note it in your file, move on, and tender the load. Two weeks later, during a quarterly pull on your active carriers, you notice something you missed the first time: their Controlled Substances/Alcohol BASIC is sitting at 81st percentile. When you dig into the underlying inspection violations in SAFER, you find two events in the past 14 months, both tagged 392.4. That's "operating a commercial vehicle under the influence of a controlled substance." One of the drivers is still on the road for that carrier.

Those violations were never going to appear in the Clearinghouse. That's not a bug in the system. That's just how it works.

The FMCSA Drug & Alcohol Clearinghouse and the Controlled Substances/Alcohol BASIC score are measuring completely different things. Most brokers I talk to treat them as redundant — if they're checking one, they think they've covered the category. They haven't. Running one without the other is leaving an identifiable gap in your file, and after Montgomery v. Caribe Transport II, LLC (U.S. Supreme Court, May 2026), that gap belongs to you.

What the Clearinghouse actually captures

The FMCSA Drug & Alcohol Clearinghouse was established under 49 CFR Part 382, Subpart G, and it's an employer-reported system. The trigger is always something that happened inside an employer's FMCSA-mandated testing program: a driver failed a DOT drug test, refused to submit to one, was caught using on-duty by a supervisor, or tested positive in a return-to-duty protocol. When any of those events happen, the employer is required to report them.

The Clearinghouse also requires employers to run an annual query on all current CDL drivers under § 382.215 — they have to check whether anyone driving for them has violations on record from prior employers. That's the piece that makes the Clearinghouse valuable as a hiring screen. It catches the driver who failed a test at their last job, got let go quietly, and is now driving for someone else before their return-to-duty process is complete.

When you query the Clearinghouse as a broker — which you can do as a prospective employer with driver consent for a full query, or as a limited query that just tells you whether violations exist — you're asking: has this carrier's drivers been reported by any employer for drug or alcohol violations? A clean result means no one in the employer pipeline has flagged them.

What the Clearinghouse cannot see: violations that were detected in the field, by inspectors, during a roadside stop. That's a different system entirely.

What the C/A BASIC actually captures

The Controlled Substances/Alcohol BASIC is a CSA metric. It aggregates violations that were recorded during roadside inspections — the kind where a federal or state inspector walks up to a truck, observes impairment, administers a test, and writes a violation. The specific regulations that generate C/A BASIC violations include 49 CFR § 392.4 (no driver shall operate a CMV while under the influence of any controlled substance or narcotic drug) and § 392.5 (no driver shall operate while impaired by alcohol or with a blood alcohol concentration above the limit). Those violations go directly into the carrier's CSA record. They don't automatically go into the Clearinghouse.

The distinction matters because the two enforcement tracks are genuinely separate. Part 382 governs what an employer must do — testing protocols, record-keeping, mandatory reporting. The Clearinghouse enforces Part 382 compliance. CSA and the BASIC scores track what happens in the field, independent of what the employer knows or reports.

A driver can have a clean slate inside an employer's testing program — never failed a random, never refused a test, never triggered a post-accident test — and still carry 392.4 violations on their inspection record. Those two tracks only intersect if the employer finds out about the roadside violation and separately tests the driver, then reports the result.

The scenario I see on actual carrier pulls

This pattern is real. Let me give you a representative example. Carrier DOT-3567102 / MC-1247893 — fictional numbers, real profile type — hauls dry van in the Midwest. When you query the Clearinghouse, the result comes back clean. Full query, driver consent obtained. No violations, no pending RTD requirements. You note it and move on.

What you would find if you pulled the C/A BASIC from SAFER: 78th percentile in the measurement window. Three violations. Two are 392.4 violations from roadside inspections in Illinois and Indiana, dated 14 months and 9 months ago respectively. The third is a § 392.5 alcohol violation from 18 months back. At least two of those incidents involve a driver who had a different carrier on his MC paperwork at the time of the second violation than the first — meaning he bounced from one carrier to another between events.

The second carrier may not have known about the first violation. The Clearinghouse entry that would flag him only exists if the first employer ran the return-to-duty process and reported the result. If the driver simply quit before that happened, or if the employer decided not to pursue it, the violation lives in the BASIC and nowhere else.

You tendered to this carrier. The driver is on a 430-mile run hauling $85,000 worth of electronics. The Clearinghouse query is in your file. The C/A BASIC check isn't.

Why brokers conflate these two systems

The confusion is reasonable on the surface — both involve drugs and alcohol, both involve FMCSA, both are part of a responsible vetting process. But the workflows that generated them are entirely different, and so are the compliance obligations they enforce.

Part 382 is the employer's testing program. It creates the duty to test, defines the circumstances (pre-employment, random, post-accident, reasonable suspicion, return-to-duty), and specifies the record-keeping and reporting requirements. The Clearinghouse is the infrastructure that makes those employer-side reports visible to future employers and to FMCSA.

CSA is what happens when federal and state inspectors pull trucks over. Their job isn't to audit the employer's testing program — that's what compliance reviews are for. Their job is to look at the driver in front of them. When they see signs of impairment, they act on it. The violation gets written, it gets uploaded into the inspection database, and FMCSA's algorithm converts it into the C/A BASIC score.

There's no automatic bridge from the roadside violation to the Clearinghouse. The post-accident testing requirements under § 382.303 help close part of that gap (they're triggered after accidents meeting certain criteria — fatality, medical transport, or disabling damage), but an impaired-driving roadside violation on a routine inspection doesn't automatically trigger any of those. The driver gets put out of service, the employer gets notified, and after that the path varies.

What to make of a high C/A BASIC percentile

FMCSA's official intervention threshold for the C/A BASIC is lower than for some of the other BASICs, and the percentile cutoffs vary by carrier size. But I don't wait for FMCSA to open an investigation before I care. Anything above the 50th percentile gets a second look. Above 65th, I'm pulling the underlying violations before I make an approval decision.

The percentile by itself doesn't tell you much. The violation dates and codes do. A carrier sitting at 60th percentile because of a single event from 30 months ago, with nothing since, is a different conversation from a carrier at 60th percentile with a violation from eight months ago. The measurement window covers 24 months for most violations. Pull the dates.

What you're looking for is pattern versus isolated event. One violation with a documented corrective action — driver separated, new hiring screen implemented, compliance review passed — can be explainable. Two violations from different drivers in the last 18 months means the screening process isn't catching the problem. Three means it's either a bad luck cluster (unlikely) or a culture.

What this gap looks like in discovery

Montgomery v. Caribe Transport II, LLC is now controlling law. Brokers can be sued in state court for negligently selecting a carrier. The question a plaintiff's lawyer will ask is simple: what did you check, and what did you skip?

The C/A BASIC score is publicly available. A plaintiff can pull it in two minutes. If your carrier file shows a Clearinghouse query result but no C/A BASIC check, the next question is: why did you treat those as the same thing? There's no good answer because they're not the same thing, and any broker who's paying attention knows that.

This isn't about perfection. Nobody expects you to have caught everything. The standard is reasonable care — what a prudent professional in your position would do. Checking one out of two available drug/alcohol indicators doesn't clear that bar, especially when the one you skipped is public and free.

How I document this

These are two separate line items in the carrier file because they're two separate checks.

Clearinghouse query: Date run, query type (limited or full), driver consent obtained (yes/no), result. If it returned clean, note that. If it flagged a violation, document what the follow-up was — did you get a full query result, did the carrier provide RTD documentation?

C/A BASIC: Score and percentile at time of approval, pulled directly from SAFER or FMCSA L&I. If the score is above 50th percentile, log each underlying violation with the date, code, and state of inspection. If you're approving a carrier despite an elevated score, write one sentence explaining why: what the violation was, whether the driver is still with the carrier, and what's changed since the event.

That written note is what separates a defensible approval from a gap. "C/A BASIC 74th percentile; two 392.4 violations, one driver no longer employed, one from 28 months ago pre-dating current safety director; trend improving over last three quarters" is a complete record. An empty field next to a clean Clearinghouse result is a half-check.

It's four minutes of work. The Clearinghouse query takes two. Pulling the C/A BASIC violations in SAFER takes another two. That four minutes is the difference between a complete drug and alcohol check and the kind of gap that's visible to anyone looking at your file from the other side of a lawsuit.

Run both. Document both. They're not the same thing.

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— Mason Lavallet

Founder, DOTScreener.com