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Understanding DOT physical exams & med cards

In order for an individual to be qualified to operate a commercial motor vehicle (CMV), he/she must meet the minimum qualification standards set forth in Part 391 of the federal motor carrier safety rules, and motor carriers that employ or engage drivers have a responsibility to ensure that their drivers are and remain qualified under those rules. One of those minimum qualification standards warrants additional attention and it’s the one that says that drivers must be physically qualified to operate a CMV.

In this article, we’ll first explore exactly what it means for a driver to be physically qualified to operate a CMV. We’ll then address how it is that drivers are deemed to be physically qualified by a DOT medical examiner, and what evidence drivers must have to prove that they are, in fact, physically qualified. And then we’ll wrap up with a look at some unique issues that can arise with respect to physical qualification.

If we think about this conceptually, it should be pretty clear why the Federal Motor Carrier Safety Administration (FMCSA) would want to ensure that commercial drivers are physically qualified to operate a CMV before they do so. The last thing anybody wants to do is to place someone with a serious medical issue that has the potential of impairing his/her ability to safely operate a vehicle behind the wheel of an 80,000 lb. tractor-trailer. That’s just asking for trouble. So, the federal safety regulations contain a few sections that are specifically devoted to the minimum physical qualifications for commercial drivers. Drivers who don’t meet these minimum standards are not qualified to operate a CMV.

What are the minimum physical standards for commercial drivers?

The list of physical qualifications is found in 49 C.F.R. 391.41. Notably, Section 391.41 says that a driver is physically qualified to drive a CMV if that person has no loss of a foot, a leg, a hand, or an arm, or has been granted a skills performance evaluation certificate, which we’ll discuss a little later. Other examples of physical qualifications on this list are that drivers must have no established medical history or clinical diagnosis of insulin-treated diabetes, or certain hearty conditions.

Additionally, drivers must have a visual acuity of at least 20/40 in each eye with or without corrective lenses and a field of vision of at least 70 degrees in each eye. They must be able to perceive a forced whisper in their better ear at not less than 5 feet with or without the use of a hearing aid. They must also not use any Schedule I drug, amphetamine, narcotic, or other habit-forming drug, or any non-Schedule I drug except when the use is prescribed by a licensed doctor who is familiar with the driver’s medical history and has advised that the substance will not adversely affect the driver’s ability to safely operate a CMV. And lastly, a driver must have no current clinical diagnosis of alcoholism.

What must carriers do to ensure drivers are qualified?

The obvious question is how is that motor carriers, assuming they have no doctors on staff, confirm their drivers meet these physical qualifications. Well, the FMCSA’s regulations specify that CMV drivers must be medically certified to meet these minimum standards by a medical examiner who is knowledgeable of the specific physical and mental demands associated with operate a CMV as well as these regulatory standards.

In other words, CMV drivers must undergo DOT medical exams administered by a medical examiner who is listed on the FMCSA’s National Registry of Certified Medical Examiners. These medical exams must occur at least every 2 years for each driver. During the exams, the medical examiner performs the evaluation and documents the results on Form MCSA-5875, which is sometimes called a long-form physical examination form. If, after the exam, the examiner determines the driver meets the physical qualification standards, he/she will issue the driver a Medical Examiner Certificate also called a medical card, and that medical card serves as proof that the driver meets the minimum physical standards. These cards are valid for the time period prescribed by the examiner but not to exceed 2 years.

Sample Medical Card

Drivers must provide a copy of the medical card to their carrier and should also keep a copy with them while operating. In addition, for CDL drivers, specifically, they must provide evidence of their updated medical cards to their state licensing agency, and information about that exam will be included in his/her CDL driving record. Further, carriers that engage CDL drivers must take the extra step of running a new MVR within 15 days after a CDL driver obtains a new medical card in order to ensure that the new medical card details have been uploaded to the state system. If they haven’t—in other words, if a CDL driver’s medical card expires and the state hasn’t uploaded information about a renewed card—then the state will take action to downgrade the CDL holder’s license, which would obviously cause problems. So, the point of this extra step for carriers that engage CDL drivers is so that they can ensure that a driver’s CDL hasn’t been downgraded for failing to present the new medical card information to the state licensing agency.

Special cases

We'll wrap up this article with a brief look at some special cases, the first of which are insulin-dependent diabetic drivers. Recall that under the FMCSA’s minimum physical qualification standards, a driver is normally not physically qualified if he/she has a clinical diagnosis of insulin-treated diabetes. However, understanding that this is a fairly common condition, the FMCSA’s regulations set up a system where insulin-dependent diabetic drivers can become qualified to operate a CMV—they just have to jump through some additional hoops. Specifically, in order to be qualified, the insulin-dependent driver is required to undergo a special assessment from a DOT medical examiner who must receive documentation from the driver’s treating physician concerning the driver’s medical treatment for diabetes and attesting that the driver has a stable insulin regiment and properly controlled diabetes. If the DOT medical examiner is satisfied that the driver can safely operate a CMV, he/she will issue a special assessment form along with the medical card, and will require that the driver submit to new DOT medical exams at least once every 12 months.

Another special case has to do with drivers with certain impairments that would otherwise render them unqualified under the FMCSA’s physical standards. For example, drivers with impaired hearing or vision that would normally prevent them from obtaining a medical card can apply for a special exemption or waiver from the minimum hearing or vision standards with the FMCSA. This exemption process requires drivers to complete a detailed application, complete with information about the driver’s medical history and driving history. For its part, the FMCSA reviews these applications and must determine whether, in its estimation, the drivers are capable of maintaining a level of safety that is equivalent to or greater than the level achieved without the exemption. If so, the agency will grant the exemption and the driver will be cleared to obtain a medical card in order to operate a CMV.

Lastly, for drivers with missing or impaired limbs, the FMCSA has a program in place called the skills performance evaluation certificate program or SPE program for short. The program allows drivers to become qualified to operate a CMV if they have been fitted with and are wearing the right prosthetic device and the driver can demonstrate the ability to safely operate by completing on and off road activities. If the driver passes the driving test, he/she will receive an SPE certificate and will be cleared to operate so long as they are otherwise qualified.


For an even more in-depth discussion of driver qualification requirements, be sure to check out our recent webinar where we offered practical tips for minimizing exposure through the DQ process. And for even more comprehensive training on these types of topics, check out our innovative online compliance courses for safety managers and drivers at

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