Who must have a medical exam and certification?

The medical exam is often thought to go hand-in-hand with the commercial driver’s license (CDL). A misconception is that only those drivers who need CDLs are subject to the medical exam requirements. That is wrong! For interstate drivers, this is definitely not the case. For intrastate drivers, it may or may not be the case. Following are the requirements for who needs a medical exam.

Drivers operating the following vehicles in interstate commerce need to have a medical exam and carry a valid medical certificate:

• Vehicles with a gross vehicle weight (GVW) or gross vehicle weight rating (GVWR), or gross combination weight (GCW) or gross combination weight rating (GCWR) of 10,001 pounds or more; or
• Vehicles designed to transport more than 8 people (including the driver) for compensation, or more than 15 people (including the driver) not for compensation; or
• Vehicles transporting hazardous materials that require the vehicle to be placarded.

The criterion in this definition that causes confusion is the vehicle weight. The general weight criterion for which a CDL is needed is 26,001 pounds. The weight criterion for which a physical is needed is 10,001 pounds. So, interstate drivers of vehicles between 10,001 and 26,001 pounds (not hauling hazmat) need to have a medical exam but do not need to have a CDL. (The other driver qualification requirements apply as well.)

For intrastate drivers, it depends on what the state has adopted for the weight criterion. A number of states use the same 10,001 pound criterion as is found in the Federal Motor Carrier Safety Regulations. Other states have a weight limit to anywhere from 10,001 pounds up to 26,001 pounds (which does coincide with the CDL requirements). A few states also have grandfather clauses or other exemptions that may except certain drivers from the medical requirement.

Non-CDL drivers who are subject to the medical exam requirement must have a valid medical certificate in their possession while driving. Carriers must also have a copy of that certificate in the driver’s qualification file.

CDL drivers are not required to carry proof of medical certification after their latest medical certification information is reflected on the CDLIS MVR.

Note, however, a copy of the completed medical examination report, or “long form,” is not required in the driver’s qualification file. The medical examiner’s certificate or a CDL driver's MVR with medical certification information are required to be in the file.

Drivers required to hold a commercial driver’s license (CDL), until no later than June 23, 2025 or the date by which their state licensing authority receives direct updates from the National Registry of Certified Medical Examiners, are required to submit their medical examiner’s certificate to the state do not need to carry a copy of the certificate once their MVR reflects the new certification information. Until June 23, 2025, that period is not for more than 15 days after issuance.