In the old days, many facets of trucking were more difficult than they are today. One thing to which this maxim does not apply is DOT (Department of Transportation) medical certificates.
In those fabled “good old days,” drivers were required to carry DOT medical cards and carriers were required to verify that drivers had them. Back then, obtaining a medical certification was fairly easy.
If a driver failed a DOT physical, he or she could simply go down the street to the next clinic and try again. If the DOT physical couldn’t be passed anywhere, certificates could easily be altered by using a bottle of White-Out to change the expiration date on the old one and then making a photocopy to hide the evidence. If that failed, outright forgeries could be made by anyone who could obtain a blank form.
Roadside inspectors had limited resources to check the authenticity of a medical card and were often satisfied if the driver had one at all.
All of that changed in 2012 when the Federal Motor Carrier Safety Administration (FMCSA) began requiring each state’s driver’s licensing agency to keep copies of medical certification cards — and to use the information to suspend the CDLs of drivers who didn’t have a current one. The status of the driver’s medical certification became a part of the state’s Motor Vehicle Report. In some states, a comment is entered that a valid certification is on file, along with the expiration date. In others, the complete medical exam is provided.
Each state enters the driver’s medical status into the CDL License Information System Motor Vehicle Record (CDLIS MVR) that both carriers and law enforcement personnel can access.
The lesson for every CDL holder is that your license will be suspended if your state doesn’t have a current medical card on file — and it’s your responsibility to see that they do. If you fail to do so, your CDL could be suspended or downgraded to a non-CDL operator’s license.
Too often, drivers aren’t aware that their medical certification is expiring until it’s too late. In other cases, the driver might be out of trucking but holding on to a CDL to keep open the option of returning to driving. That’s what happened to Nathan Riley of Texas.
“My CDL was downgraded over a year ago to a class C license, and I had no idea until recently when I went to renew it,” he told The Trucker. “Apparently, once a DOT medical card expires, CDL holders have a 60-day window to renew the DOT card or change the status of their license to ‘maintaining.’”
In Riley’s case, he had moved to a new address and never received the notice sent by the Texas Department of Public Safety, the licensing agency for the state. When he went to renew his CDL, he was informed that he was no longer a CDL holder. It’s unclear whether Riley can have his CDL reinstated with a current medical certification or if he will need to retest to get his CDL back.
Unfortunately, many drivers on the road only receive mail sporadically, if at all. Drivers who fully complied with DOT exam requirements, passed their physicals and obtained a new medical certification can still have their CDL suspended if they don’t ensure their home state receives a copy.
In some states, the medical facility where the physical exam took place may forward a copy to the state licensing agency. Some carriers also submit copies in an attempt to help their drivers stay current. The regulations, however, clearly state that it’s the driver’s responsibility to make sure it happens.
The process for submitting medical certifications to the state agencies varies by state. The FMCSA publishes a list that provides the process for each state, including whether they will accept copies that are faxed or emailed and what file types they will accept. It can be found here.
Further, the regulations require the driver to self-certify in one of four “operation categories.” This is also done through your state’s licensing agency. The four categories are interstate non-excepted, interstate excepted, intrastate non-excepted and intrastate excepted.
Most over-the-road drivers will certify in the “interstate non-excepted” category, meaning you drive in multiple states and must follow the DOT medical card requirements. If all your miles are within the borders of one state, “intrastate non-excepted” means you are required to follow the medical requirements of your state, which may be different than federal requirements.
The “excepted” categories can vary by state and generally mean you are not required to provide copies of your medical card. Some states allow you to specify a “maintenance” category that lets you keep your CDL without medical certification, but only if you aren’t using the license to drive commercially. Some states allow limited use of your CDL without a physical exam for tasks such as operation of a church bus or a truck used for agricultural purposes.
It’s important that every driver understands the requirements of the state that issued the CDL. Federal regulations require that each driver submit a new medical certification to the licensing agency before the old one expires.
When it comes to medical certification, it’s much better to be proactive, even if it means duplication of efforts. It can’t hurt if you and your doctor’s office both submit a medical certification to your state, or even if your carrier sends one, too. When nobody sends one, you are in danger of losing your CDL, either temporarily or permanently.
Current rules at the FMCSA make medical certification a requirement of holding a CDL. If you are pulled over and your CDL isn’t valid, you may not be able to fix the problem in time to continue with that load. Make sure you know your state’s procedure and that your most current medical certification is on file.
Cliff Abbott is an experienced commercial vehicle driver and owner-operator who still holds a CDL in his home state of Alabama. In nearly 40 years in trucking, he’s been an instructor and trainer and has managed safety and recruiting operations for several carriers. Having never lost his love of the road, Cliff has written a book and hundreds of songs and has been writing for The Trucker for more than a decade.
