The Clearinghouse began in January 2020: queries before hire and every year are required, and a social-media post saying "he's clean" does not count

What the final rule actually set up

Our safety manager opens the query because that is the legal obligation. MAP-21 called for a national database of drug and alcohol violations by CDL holders, and the final rule obliges employers to query it before hiring and once a year afterward.

MROs, SAPs and TPAs are the ones who report positives, refusals and return-to-duty steps. A driver has to consent before a full query is run. The database went live in January 2020, three years after the rule took effect.

Before the Clearinghouse, a driver could fail a test at Carrier A and start work at Carrier B if B never found out. Closing that gap is the whole reason for the database. The same rule also gives drivers the right to consent and to view their own record at no charge.

A previous employer's note saying "he was fine" is no replacement. A query means a query.

The 2026 IDEMIA step concerns identity-proofing for professional users. It did not create the duty to query, and it did not repeal 391.23. A walk-through of registration is covered in a separate article, and this one explains the duty itself.

What this means for you now

We run the query. If the Clearinghouse comes back with a no, our answer is no. A start date does not excuse skipping consent, and a screenshot does not excuse skipping the database.

For drivers in return-to-duty, the regulation applies as written, and there is no workaround. We will not create a side channel because a candidate could not finish the portal steps.

On the 2026 identity-proofing, read the IDEMIA article. On how to log in, see when registration opened. On the gap this system closed, see the 2014 proposal.

If you are eligible, apply through Open seats. Our safety team owns the file. The phone number is +1 (224) 877-0350.

Where we stand

We query before every safety-sensitive hire and once a year after that. A screenshot or a "he was fine" letter will never stand in for the database.

If consent fails, we do not invent a side channel. Owner-operators still query themselves in their role as the employer.

Start at the portal, then come to us. If you are eligible and your query comes back clean, call +1 (224) 877-0350 and you will get a person, not a social-media inbox.