Medical Certification Requirements for CDL Drivers

Aug 12, 2023 | Business Insurance, Personal Insurance

The Federal Motor Carrier Safety Administration (FMCSA) recently amended its regulations (FMCSRs) to require interstate commercial driver’s license (CDL) holders who are subject to the physical qualification requirements of the FMCSRs to provide the State Driver Licensing Agency (SDLA) that issued their CDL with a current original or copy of their medical certificate. This information must be recorded on the Commercial Driver License Information System (CDLIS) driver record by the SDLA.

The driver must notify the SDLA of the driver category to which he or she is assigned, as defined in the regulation (see below for information on categories). Unless the driver is involved in one of the actions described above, the SDLA must receive this information by January 30, 2014.

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Furthermore, each driver will be required to submit a copy of his or her medical certification to the licensing State DLA by January 30th, 2014. If a driver fails to submit a copy of the medical certificate, his or her CDL license will be downgraded, which means the issuing State will be required to remove the CDL driving privileges from his or her driver license and the driver will no longer be permitted to legally operate a commercial motor vehicle.

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If a driver is exempt from obtaining a medical card, he or she must self-certify with the licensing state using the categories listed below. The CDLIS must receive this information from the states within 10 days of submission.

If a driver applies for a new CDL before January 30, 2012, and expects to operate in interstate or foreign commerce, or is otherwise subject to the medical certifications of 391, he or she must certify that he or she meets the medical qualifications before obtaining a CDL.

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If the driver is not subject to 391’s medical requirements and expects to operate entirely in intrastate commerce, he or she must certify that he or she is not subject to 391.

If a person is a new applicant seeking to obtain a CDL on or after January 30th, 2012, he or she will be required to certify the driver category (Category 1-4, please see below for a description of each Category) in which he or she wishes to obtain the CDL.

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Before obtaining a CDL, each new CDL applicant who certifies that he or she will operate CMVs in non-excepted interstate commerce must provide the State with a copy of a medical examiner’s certificate.


Category 1: Non-Excepted Interstate: A person must certify that she or he operates or expects to operate in interstate commerce, that she or he is subject to and meets the qualification requirements of 49 CFR part 391, and that she or he is required to obtain a medical examiner’s certificate by 391.45.

Drivers in Classes A, B, and C who do not fall into any of the other categories

All Class A, B, and C drivers who have received a medical variance, a federal vision or diabetes exemption, or a Skill Performance Evaluation certificate (SPE) are exempt from this requirement (V restriction)

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Category 2: Excepted Interstate: A person must certify that he or she operates or expects to operate a commercial vehicle in interstate commerce (across state lines), but only for purposes expressly permitted by 49 C.F.R. 390.3(f), 391.2, 391.68, or 398.3. Furthermore, she or he is exempt from all or part of the medical qualification requirements of 49 CFR 391, and thus is not required to obtain a medical examiner’s certificate.

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(1) All school bus operations as defined in Section 390.5;

(2) Transportation provided by the federal government, a state, or a political subdivision of a state

(3) The occasional transportation of personal property by individuals for no monetary gain or to further a commercial enterprise;

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(4) The transportation of human corpses, as well as sick and injured people;

(5) Operation of fire trucks and rescue vehicles during emergency and related operations;

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(6) The operation of commercial motor vehicles designed or used to transport 9 to 15 passengers (including the driver) for no direct remuneration;

(7) The operation of commercial motor vehicles designed or used to transport 9 to 15 passengers (including the driver) for direct compensation, provided the vehicle is not operated beyond a 75-air-mile radius of the driver’s normal work-reporting location.

(8) A driver of a commercial motor vehicle primarily used to transport propane winter heating fuel or a driver of a motor vehicle used to respond to a pipeline emergency;

(9) Farming custom operations;

(10) Apiary industries; or

(11) Farm vehicle driver, unless he or she is driving an articulated (combination) commercial motor vehicle, as defined in 390.5.

Non-Excepted Category 3 Intrastate: A person must certify that she or he only operates in intrastate commerce and is thus subject to State driver qualification requirements.

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Excepted Intrastate:

 A person must certify that she or he operates in intrastate commerce but is solely engaged in transportation or operations that are exempt from all or parts of the State driver qualification requirements.

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Maintaining the status of medical certification

A CDL holder who certifies that he or she will operate CMVs in non-excepted, interstate commerce must provide the State with an original or copy (as required by the State) of each subsequently issued medical examiner’s certificate in order to maintain a medical certification status of “certified.”

if a driver’s medical certification expires, the licensing State must notify the CDL holder of his or her CDL’s “not-certified” medical certification status and that the CDL privilege will be removed from the driver license unless the following conditions are met:

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Within 60 days, the driver submits a current medical certificate. Sends in a current medical exception (diabetes exception, vision exception); or he Changes his or her self-certification to only driving in permitted or intrastate commerce (if permitted by the State).

Downgraded for the purposes of this regulation means that the driver loses the right to operate a CDL-required CMV until he or she submits a current medical certificate, a current medical variance, or changes his or her self-certification as intrastate as discussed above. Downgrading does not imply that the driver’s CDL license will be revoked.

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Certificate of Medical Examination

Interstate drivers subject to CDL regulations and physical qualification requirements will be required by the FMCSA to keep a paper copy of the medical examiner’s certificate until January 30th, 2014. Interstate carriers must also keep a copy of the medical certificate in their driver qualification files.

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If a driver qualifies for the medical examiner’s certificate by obtaining a medical variance from the FMCSA in the form of an exemption letter (diabetes, vision) or a skill performance evaluation certificate, he or she must have a copy of the variance documentation on his or her person at all times while on the job.

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