Physical examinations are mandatory for commercial motor vehicle (CMV) drivers to ensure they are physically qualified to drive. Such exams must be repeated at least every two years, although medical examiners (MEs) can choose to set a more frequent renewal cycle based on a driver’s medical condition. A successful medical exam results in the issuance of a Medical Examiner’s Certificate (MEC) — also known as the wallet card or med card — that serves as the driver’s proof of being physically qualified.

At all times, drivers and the motor carriers employing them must be able to show proof of being physically qualified to drive. This is achieved either through the med card, or for drivers with a commercial driver’s license (CDL) by means of a current driving record from the state.

• Every driver of a CMV involved in interstate commerce must meet the mandatory conditions to be medically eligible.
• Physical qualification requirements for drivers are outlined in 13 standards.

The medical qualification requirements contained in 49 CFR Part 391 apply to all drivers of commercial motor vehicles (CMVs) involved in interstate commerce. A CMV is defined as follows:

• Has a gross vehicle weight or gross vehicle weight rating, or gross combination weight or gross combination weight rating, of 10,001 pounds or more;
• Is designed or used to transport more than eight passengers (including the driver) for compensation;
• Is designed to transport more than 15 people; or
• Transports hazardous materials of a type and quantity that require placarding.

States also have driver qualification requirements for intrastate operations, either by adopting the federal rules or by establishing their own rules.

How often are exams required?

A medical exam, conducted by a licensed medical examiner who is familiar with the regulations, is required if a driver:

• Has not been medically examined and physically qualified to drive a commercial motor vehicle (CMV),
• Has not had a medical exam in the past 24 months, or
• Has suffered a physical or mental disease or injury that affected the driver’s ability to drive a CMV.

What are the requirements?

The physical qualification requirements consist of the following 13 standards listed in 391.41(b):

• Has no loss of a foot, leg, hand, or arm, or has been granted a waiver pursuant to 391.49. (391.41(b)(1))
• Has no impairment of:
  • A hand or finger that interferes with prehension or power grasping; or
  • An arm, foot, or leg that interferes with the ability to perform normal tasks associated with operating a motor vehicle; or any other significant limb defect or limitation that interferes with the ability to perform normal tasks associated with operating a motor vehicle; or has been granted a waiver pursuant to 391.49. (391.41(b)(2))
• Has no established medical history or clinical diagnosis of diabetes mellitus currently treated with insulin for control, unless the person meets the requirements in 391.46. (391.41(b)(3))
• Has no current clinical diagnosis of myocardial infarction, angina pectoris, coronary insufficiency, thrombosis, or any other cardiovascular disease of a variety known to be accompanied by syncope, dyspnea, collapse, or congestive cardiac failure. (391.41(b)(4))
• Has no established medical history or clinical diagnosis of a respiratory dysfunction likely to interfere with his or her ability to control and drive a motor vehicle safely. (391.41(b)(5))
• Has no current clinical diagnosis of high blood pressure likely to interfere with his or her ability to operate a motor vehicle safely. (391.41(b)(6))
• Has no established medical history or clinical diagnosis of rheumatic, arthritic, orthopedic, muscular, neuromuscular, or vascular disease that interferes with his or her ability to control and operate a motor vehicle safely. (391.41(b)(7))
• Has no established medical history or clinical diagnosis of epilepsy or any other condition that is likely to cause loss of consciousness or any loss of ability to control a motor vehicle. (391.41(b)(8))
• Has no mental, nervous, organic, or functional disease or psychiatric disorder likely to interfere with his or her ability to drive a motor vehicle safely. (391.41(b)(9))
• Has distant visual acuity of at least 20/40 (Snellen) in each eye without corrective lenses or visual acuity separately corrected to 20/40 (Snellen) or better with corrective lenses, distant binocular acuity of at least 20/40 (Snellen) in both eyes with or without corrective lenses, field of vision of at least 70 degrees in the horizontal meridian in each eye, and the ability to recognize the colors of traffic signals and devices showing standard red, green, and amber. (391.41(b)(10))
  • The alternative vision standard in 391.44 allows a driver to qualify for the vision portion of the exam based on vision in the better eye, if the person does not satisfy with both eyes, either the distant visual acuity standard with corrective lenses or the field of vision standard, or both, as noted above. The carrier must administer a road test if the driver uses the alternative vision standard for the first time unless the driver meets an exception in 391.44(d)(3).
• First perceives a forced whispered voice in the better ear at not less than 5 feet with or without the use of a hearing aid or, if tested by use of an audiometric device, does not have an average hearing loss in the better ear greater than 40 decibels at 500 Hz, 1,000 Hz, and 2,000 Hz with or without a hearing aid when the audiometric device is calibrated to American National Standard (formerly ASA Standard) Z24.5-1951. (391.41(b)(11))
• Does not use any drug or substance identified in 21 CFR 1308.11 Schedule I, an amphetamine, a narcotic, or other habit-forming drug; and does not use any non-Schedule I drug or substance that is identified in the other Schedules in 21 Part 1308 except when the use is prescribed by a licensed medical practitioner, as defined in 382.107, who is familiar with the driver’s medical history and has advised the driver that the substance will not adversely affect the driver’s ability to safely operate a commercial motor vehicle. (391.41(b)(12))
• Has no current clinical diagnosis of alcoholism. (391.41(b)(13))

Medical advisory criteria

The FMCSA provides “Medical Advisory Criteria” as guidelines to aid medical examiners in determining if drivers are qualified. These medical criteria are found in Appendix A to Part 391.

• Definitions for terms associated with physical exams for drivers can aid in understanding of the process.

Carrier: Also known as a “motor carrier,” this is a company that uses commercial vehicles in the course of conducting business.

Commercial driver’s license (CDL): A special classified license required for a driver who operates a vehicle that weighs (rated or actual) 26,001 pounds or more, a combination of vehicles weighing or rated at 26,001 pounds or more pulling a trailer with a rated or actual weight of 10,001 pounds or more, a vehicle required to be placarded for hazardous materials, or a passenger vehicle designed to seat 16 or more.

Medical card: A certificate issued to the driver by the examiner after the driver passes a U.S. Department of Transportation (DOT) physical exam (also known as a Medical Examiner’s Certificate, or MEC).

• Exams for drivers address a variety of physical conditions that could impair driving performance or disqualify drivers.
• The medical exam procedures look for some conditions, while others may require additional medical tests or monitoring performed outside of the FMCSA driver exam.
• Certain drivers may receive waivers or exemptions from medical standards. The FMCSA provides guidelines for medical examiners to verify if drivers meet qualifications.

Urinalysis

The numeric readings must capture the specific gravity, protein, blood, and sugars in the driver’s urine. Results may be an indication for further testing to rule out any underlying medical problem.

Hypertension

A common physical condition requiring a test is hypertension (high blood pressure). If a driver has high blood pressure or is being treated for it, the medical examiner will require examinations that are more frequent than every 24 months.

Stage 1. If diagnosed with Stage 1 hypertension (blood pressure between 140/90 and 159/99), a driver may be medically certified for one year. At recertification, if the driver’s blood pressure is equal to or less than 140/90, that driver may be recertified for one year. At recertification, if blood pressure is between 140/90 and 159/99, a one-time, three-month certificate may be issued.

Stage 2. If diagnosed with Stage 2 hypertension (blood pressure between 160/100 and 179/109), a driver should be treated and may be issued a one-time, three-month certificate. Once blood pressure is reduced to 140/90 or less, annual recertification may be possible.

Stage 3. If diagnosed with Stage 3 hypertension (blood pressure is 180/110 or higher), a driver should not be certified until blood pressure is reduced to 140/90 or below, and then recertification every six months may be needed.

Diabetes

The use of insulin to control diabetes mellitus is normally disqualifying, but 391.46 offers a path to annual certification. A driver must first obtain a completed Insulin-Treated Diabetes Mellitus Assessment Form, MCSA–5870, from the driver’s treating clinician. The form is available from the Federal Motor Carrier Safety Administration (FMCSA).

To be certified for a full year, the driver must use an electronic glucometer and give the treating clinician at least the preceding three months’ worth of blood-glucose data. The driver must then bring the completed form MCSA-5870 to, and be examined by, a Federal Motor Carrier Safety Administration (FMCSA) certified medical examiner within 45 days. The DOT medical examiner has discretion to make the final certification decision.

Vision

One of the more common standards a driver needs to meet as part of the physical exam is the vision standard. To meet the vision qualifications, the driver must have visual acuity of at least 20/40 (Snellen) in each eye with or without corrective lenses. The field of vision (the ability to see side to side) has to be at least 70 degrees in each eye. The driver also has to be able to recognize the colors of traffic signals (red, green, and amber).

Criteria for the alternate vision standard can be found in 391.44.

Hearing

Hearing can be tested using either a whisper or audiometric test.

A driver (with or without the use of a hearing aid) must:

• Be able to hear a forced whisper from five feet away in at least one ear.
• Not have an average hearing loss in the better ear greater than 40 decibels at 500 Hz, 1,000 Hz, and 2,000 Hz.

Waivers and exemptions

In some cases, drivers may be granted waivers or exemptions from certain medical standards. The FMCSA offers several types of special exemptions or waivers for specific medical conditions. Though 391.49 and 391.64 address exemptions for drivers seeking the Skill Performance Evaluation Certificate and the vision waiver study program respectively, information about most waivers is not found in the regulations.

On a case-by-case basis, the FMCSA is granting waivers from most medical standards, including those for hearing, epilepsy/seizures, and limb disorders. In some cases, a specific waiver application is to be used. For more information about applying for a waiver, refer to the medical information on the FMCSA website.

• Interstate drivers should use the services of an examiner listed on the National Registry of Certified Medical Examiners.
• Whether drivers or carriers pay for medical exams depends on the carrier’s decision or the laws in states where the carrier operates.

Driver medical examinations must be performed by licensed medical examiners who are properly qualified to perform driver physical exams. For interstate drivers in particular, this means using an examiner who is listed on the National Registry of Certified Medical Examiners.

The National Registry is an online listing of medical examiners who have taken steps necessary to become certified to perform medical exams for commercial drivers. As of May 21, 2014, motor carriers and drivers may only use medical examiners listed on the Registry to conduct driver physical exams, and each driver’s qualification file must include a document showing that the employer verified that the driver was examined by someone appearing on the Registry.

This verification can be accomplished by getting the Registry number from the driver’s medical certificate or driving record and searching for it on the Registry website to verify its validity. This must be done for every new medical certificate received.

The Registry is available online at nationalregistry.fmcsa.dot.gov. Qualifications necessary for an examiner to be added to the Registry can be found in Part 390 Subpart D.

Note that this requirement specifically applies to interstate commercial motor vehicle (CMV) drivers. States may or may not require use of the Registry for their intrastate drivers.

Qualified examiners appearing on the Registry may include any person who is licensed, certified, and/or registered in accordance with applicable state laws and regulations to perform physical exams. This includes, but is not limited to:

• Doctors of medicine
• Doctors of osteopathy
• Physician assistants
• Advanced practice nurses
• Doctors of chiropractic

Certified medical examiners from the Department of Veterans Affairs (VA) may perform driver medical exams, but only for veterans enrolled in the VA healthcare system.

A licensed optometrist may perform the vision portion of the exam.

Other considerations

A carrier may require drivers to use a preferred certified medical examiner instead of a driver’s personal doctor (even if that doctor is on the National Registry of Certified Medical Examiners). Because carriers are responsible for the actions of examiners, many prefer to send drivers to established examiners with whom the carriers have history.

The Federal Motor Carrier Safety Administration (FMCSA) does not address whether drivers or carriers are responsible for the cost of medical exams. Many carriers do choose to pay for the exams, especially when they dictate which examiner must be used, but it is not required.

In addition, many states have laws dictating whether carriers must pay for medical exams, so carriers should be sure to know the laws of the states in which they operate.

In Canada, the requirement for a commercial vehicle driver to have a physical examination is not dependent on whether the vehicle the driver is operating is a commercial motor vehicle by definition. Whether physical examinations in Canada are required for commercial drivers depends on the type of driver’s license the driver holds. Typically, physical examinations are required only for drivers in certain classes of licenses. In most Canadian jurisdictions, these are license classes 1 – 4 (Class A, B, C, D, E, and F in Ontario). There are variances among the jurisdictions, however.