Commercial Driver License Medical Eligibility & Exams

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Commercial drivers, firefighters, and noncommercial drivers with Class A and Class B licenses are required to meet federal medical standards in order to operate commercial motor vehicles. 

Drivers of Class A, Class B, and commercial Class C vehicles must meet medical requirements established by the federal government and Department of Motor Vehicles (DMV). This applies to:

  • All Class A, Class B, and commercial Class C driver license (DL) holders.
  • All commercial drivers who drive interstate.
  • Firefighters who operate fire equipment, any class C vehicle, or any other vehicle in their capacity as a firefighter.
    • If the firefighter has a physical or mental condition which would otherwise disqualify them from driving a commercial vehicle, a license may be issued as long as they do not transport passengers when driving commercially or materials requiring placards/markings. California Vehicle Code (CVC) §27903
  • Drivers hauling hazardous agricultural material (HAM). California Vehicle Code (CVC) §12804.2

Purpose

Operating commercial vehicles, commercial Class C vehicles, noncommercial Class A and Class B vehicles, fire vehicles and equipment, and vehicles hauling HAM is more physically and mentally demanding than operating other types of vehicles, which creates an increased risk to public safety. Additionally, challenging driving conditions make it difficult for drivers to adequately provide for any special medical, diet, exercise, or rest needs associated with a medical condition or physical impairment.

For these reasons, CDLs are generally denied to drivers who do not meet the federal medical standards. However, in accordance with statute and court decisions, each case must be considered individually to determine if the driver compensates adequately for any medical condition or physical impairment and if any restrictions apply (see Exceptions and Review Process below).

The Federal Motor Carrier Safety Regulations (FMCSR) establish the criteria to determine when a person is physically qualified to drive a commercial vehicle (see 391.41 FMCSR). The following guidelines are provided as they apply to various medical conditions.

ConditionDrive is qualified if:Exceptions/Considerations
Loss of or limited use of extremitiesLoss or impairment of an extremity or any significant limb defect or limitation does not interfere with the ability to perform normal tasks associated with operating a motor vehicle.The driver may be granted a waiver if it is determined that the impairment will not interfere with the driver’s ability to control and safely operate a motor vehicle. Exceptions may be made and a restricted commercial license may be issued. The driver must take a drive test in the applicable type of vehicle, unless they were previously tested and qualified.
Insulin-Dependent DiabetesThey have no established medical history or clinical diagnosis of diabetes mellitus currently requiring insulin for control.A commercial driver generally is not in a position to balance dietary and rest needs. Injury, emotional stress, unrelated illness, diarrhea, vomiting, or infection may also affect control of the diabetic condition. Additionally, residual effects of the disease may include nerve and vascular damage causing pain or numbness in the extremities and/or vision deterioration. When evaluating the condition of any diabetic, residual effects of the disease should not be overlooked. Individuals who control their diabetes with diet or oral medication are usually issued a commercial license. However, they may also be affected by these residual effects.

Thorough review of the reports for vision and extremities on the medical report, along with urinalysis, is required. Indications from urinalysis of uncontrolled diabetes may disqualify an applicant from operating a commercial vehicle.

For the above reasons, the circumstances in which an insulin dependent diabetic may be qualified for a restricted intrastate commercial license will be very rare.

Under federal standards, a diabetic on insulin therapy, regardless of the degree of control, does not qualify for interstate driving, unless they were issued a federal waiver or exemption.
Cardiovascular systemThey have no clinical diagnosis of any cardiovascular disease which is accompanied by syncope, dyspnea (shortness of breath), collapse, or congestive cardiac failure.The concern is whether there is a current clinical diagnosis or history of an uncontrolled cardiovascular disease, which is accompanied by and likely to cause symptoms of fainting, labored breathing, collapse, congestive cardiac failure, or sudden death.
Respiratory systemThey have no established medical history or clinical diagnosis of a respiratory condition that would interfere with the ability to control and drive a motor vehicle safely.The concern is whether a respiratory condition may result in a lapse of consciousness, dizziness, fatigue, or decreased mental awareness which may interfere with the ability to safely operate a motor vehicle.
Blood pressureThey have no clinical diagnosis of high blood pressure likely to interfere with their ability to operate a motor vehicle safely.The complications that may arise from sustained hypertension such as damage to the heart, eyes, kidneys, and brain are unacceptable for highway safety. Uncontrollable malignant (very dangerous) hypertension that is rapidly progressive is disqualifying.
Musculo-skeletal systemThey have no established medical history or clinical diagnosis of rheumatic, arthritic, orthopedic, muscular, neuromuscular, or vascular disease that interferes with their ability to control and operate a motor vehicle safely.A driver with an established medical history or clinical diagnosis of any of these conditions, and who cannot demonstrate compensation through a drive test, does not qualify for a commercial driver license.
Seizure or loss of conscious-ness/controlThey have no established medical history or clinical diagnosis of epilepsy or any other condition which is likely to cause loss of consciousness or any loss of ability to control a motor vehicle.Clinical diagnosis of epilepsy is a key medical factor for determining whether an individual is qualified to obtain a commercial license. A clinical diagnosis of epilepsy will usually require a controlling anti-convulsant medication and the driver will not qualify for interstate driving. Blackouts of known cause, when the cause is no longer present nor likely to recur, may not be disqualifying (such as a lapse of consciousness due to pregnancy, high fever, allergic reaction to prescribed medication, or insect bite). The physician should withhold certification until the driver has fully recovered from the condition.
Mental or functional disorderThey have no mental, nervous, organic, or functional disease or psychiatric disorder likely to interfere with their ability to drive a motor vehicle safely.Emotional or adjustment problems contribute directly to an individual’s level of memory, reasoning, attention, and judgment. Physical disorders often underlie these problems. A variety of functional disorders can cause drowsiness, dizziness, confusion, weakness, or paralysis that may lead to poor coordination, inattention, loss of control, and susceptibility to accidents while driving. Physical fatigue, headache, impaired coordination, recurring physical ailments, and chronic pain may be present to such a degree that certification for commercial driving is inadvisable. Medications taken to relieve these disorders, such as pain relievers, tranquilizers, and mood elevators, may produce side effects which would also preclude commercial licensing. Refer to the “Drugs” section in this table.
VisionThey have at least:

– 20/40 (Snellen) distant vision in each eye without corrective lenses, or corrected to 20/40 (Snellen) or better with corrective lenses.

– 20/40 distant binocular acuity (Snellen) in both eyes with or without corrective lenses.

– Field of vision of at least 70º in the horizontal meridian in each eye.

– The ability to recognize the colors of traffic signals and devices showing standard red, green, and amber.
Interstate drivers must have 20/40 vision or better in each eye and in both eyes together, with or without corrective lenses.

Color blind applicants may qualify for both interstate and intrastate commercial driving if the examining doctor determines they are able to distinguish the traffic light colors of red, green, and amber, even if perceived in shades of gray. Restrictions (may not transport passengers or hazardous materials requiring placards, or limited to intrastate commercial driving only) are not applied if the doctor determines the driver meets the color vision standard.
HearingThey can first perceive a forced whispered voice at not less than five ft in their better ear with or without the use of a hearing aid. If tested with an audiometric device, they do not have an average hearing loss greater than 40 decibels at 500 Hz, 1,000 Hz, and 2,000 Hz in the better ear with or without a hearing aid.Applicants who have a hearing loss in both ears that cannot be corrected to the federal requirements do not qualify for an interstate license, but may qualify for a restricted intrastate license (may not transport passengers or hazardous materials requiring placards), if a driving test shows adequate compensation for the deficit.

If the driver meets the criteria by using a hearing aid, the driver must wear the hearing aid and have it in operation at all times while driving, and have a spare power source for the hearing aid in possession.
DrugsThey do not use an amphetamine, narcotic, or any habit-forming drug.The driver does not have to be addicted or a habitual user to be found unqualified. A person who takes a drug identified as a Schedule 1 drug in FMCSR Appendix D is disqualified from driving a commercial motor vehicle, except under limited circumstances.
AlcoholismThey have no current clinical diagnosis of alcoholism.Current clinical diagnosis is designed to include a current alcoholic illness or those instances where the individual’s physical condition has not fully stabilized, regardless of the time element. The person must have ceased drinking for a sufficient period of time to:
– Have regained good judgment.
– Have no withdrawal effects, such as alcohol withdrawal seizures.
– No longer be physically or mentally unable to operate a motor vehicle safely.

Long term use of alcohol may lead to permanent deterioration of mental or physical function. If there is a history of past alcohol abuse, the overall physical condition of the driver should be carefully reviewed.

California Standards

CVC §12804.9 requires that DMV determine whether the applicant is mentally and physically fit to operate a motor vehicle, and permits us to consider the standards required by federal regulations in establishing California medical requirements for commercial driver licenses. It also provides that any physical defect of the applicant which, in the opinion of DMV, is compensated for to ensure safe driving ability, will not prevent the issuance of the license. CVC §12809 authorizes DMV to refuse to issue a CDL to any person not meeting the medical requirements.

California Regulations

Title 13, Article 2.1, 28.18 and 28.19, of the California Code of Regulations (CCR) provides the minimum physical and medical requirements for Class A, B, or commercial Class C driver licenses. These are the same standards required of motor carrier drivers by the Federal Highway Administration of the Department of Transportation.

Drivers who are required to meet medical standards must certify that they meet the requirements when they apply for their license and every two years thereafter. 

Commercial Drivers

Commercial drivers must submit a completed Medical Examination Report (MER) Form (MCSA 5875) and Medical Examiner’s Certificate (MEC) (MCSA 5876) (see “Medical Examination Report” in Commercial Driver Licenses).

The MER (MCSA 5875) must be completed and signed by a health care professional who is licensed, certified, or registered in accordance with applicable state laws and regulations to practice medicine and perform physical examinations in the United States (U.S.). Health care professionals are doctors of medicine, doctors of osteopathy, physicians assistants, and advanced practice nurses, or doctors of chiropractic who are clinically competent to perform the examination. An optometrist (O.D.) may perform the vision portion of the exam. Drivers who wish to perform interstate commerce must have their exam completed by a medical professional on the National Registry of Certified Medical Examiners and the certification number must be present on the form.

For 15 days after being issued a MEC (MCSA 5876), commercial drivers must have a copy of the MEC, signed by a health care professional, in their possession when operating any commercial motor vehicle. CCR §391.41(a)(2) After 15 days have passed, the driver no longer needs to carry it on their person. DMV is authorized to issue the Medical Certificate (form DL 51B), pursuant to CCR 28.19.

Noncommercial Class A and B Drivers, Firefighters, and Drivers Hauling HAM

Noncommercial Class A and B drivers must complete a Physician’s Health Report (DL 546A) to certify that they meet the required medical standards. This form must be completed by a physician as it includes details concerning drivers’ vision and any physical impairments they may have.

Firefighters and drivers hauling HAM must complete a Health Questionnaire (DL 546). This form is completed by the applicant, but does not require a physician’s signature to verify driver information.

DMV reviews the medical report for completeness, legibility, and compliance withmedical standards.

If the driver does not meet the medical standards or does not adequately compensate for a loss or impairment, the driver may be scheduled for a reexamination or issued an Order of Refusal. In certain instances, we may also issue the following outcomes:

  • Medically qualified with conditions: When evidence proves the driver may not be medically qualified to drive a commercial motor vehicle, but the condition appears correctable, the driver will be contacted for further information or a reexamination will be scheduled.
  • Medically qualified with restrictions: Applicants with conditions that are waivable under federal standards (vision, hearing, and loss or impairment of limb), or previously licensed commercial drivers with other conditions, may be eligible for a CDL with appropriate restrictions. If the applicant adequately demonstrates compensation, a CDL may be approved with the following restrictions:
    • No passengers when driving commercially or transporting material requiring placards/markings. California Vehicle Code (CVC) §27903
    • May not drive in interstate commerce.
  • Medically disqualified for CDL only: When evidence proves the driver is not qualified to drive a commercial motor vehicle, but does qualify for a Class C noncommercial driver license, the driver will be issued only a Class C license.
  • Medically disqualified for any class driver license: When a medical report indicates the driver does not qualify to drive any motor vehicle safely, revocation of the entire driving privilege is required.

Drive Test

DMV will conduct a drive test to determine whether the driver compensates for a condition that is waivable under federal standards (if the driver has not previously demonstrated compensation). If the driver compensates for the condition, DMV will issue a restricted license.

In certain circumstances, DMV may make exceptions to the medical standards for a commercial driver license.

Original Application

On original CDL applications, DMV may make rare exceptions to the medical requirements when the driver is able to demonstrate a history of adequate compensation. The commercial drive test will determine if the driver adequately compensates for any loss or impairment of a limb, vision, or hearing. If a CDL is issued, it will be restricted to driving intrastate only (within California), and without passengers or HazMat.

Factors DMV considers to determine if the medical condition will affect driving include (but are not limited to) the following:

  • History and length of medical condition.
  • Scope of commercial driving.
  • Hours of operation.
  • Driving record history.
  • Scope of employment.
  • Side effects of condition.
  • Geographic location.
  • Type of vehicle.

Commercial License Renewal

If the driver has been driving safely with the disqualifying medical condition, DMV may make exceptions from federal standards to allow the driver, when renewing a Class A or B license, to operate a commercial vehicle. However, the license must be restricted to driving intrastate only and without passengers or hazardous materials.

If the medical condition or physical impairment would affect coordination, strength, vision, hearing, or judgment, a drive test may be required to determine the adequacy of compensation.

Interstate Waivers and Exemptions

Occasionally a driver will contact DMV seeking a federal waiver or exemption. Such drivers may qualify for a federal waiver if they are employed driving in interstate commerce. The federal waiver and exemption program is designed to allow persons with specific conditions listed in FMCSR §391.41 to qualify under the FMCSR. Restrictions may be included on individual waivers when the Regional Federal Highway Administrator determines they are necessary for public safety.

If the driver is found otherwise medically qualified, the examining physician must include the statement “medically unqualified for interstate commerce unless accompanied by a waiver” on the medical certificate.

The driver should send the waiver request to:

U.S. Department of Transportation
1200 New Jersey Avenue, SE
Room W64-224
Washington, DC 20590

If a driver fails to qualify for a new medical certificate (per CVC §14606(b)), the driver’s employer is required to report it to DMV immediately using one of the following:

DMV will review the Report of Medical Exam Failure, Health Questionnaire, or letter to determine if the driver’s physical or mental condition may preclude safe operation of a commercial vehicle. The driving record is analyzed for potential problems that may be related to the physical or mental condition (violations, accidents, suspension, revocation).

If the review indicates further investigation is needed, a reexamination may be scheduled.

If the evidence warrants revocation of the driving privilege because of an immediate driving hazard, the CDL will be revoked without first reexamining the driver (per CVC §13953).

Reexamination

A hearing officer may order a reexamination based on information such as medical reports, law enforcement or court referrals, Department of Health Services Confidential Morbidity Reports (CMR), or other contacts.  California Vehicle Code (CVC) §13800

The hearing officer will consider the following factors in the reexamination:

  • A detailed description of the medical condition or physical impairment and any related effects.
  • How it affects safe driving, if at all.
  • The medical regimen, if any.
  • The prognosis of the medical condition or physical impairment.
  • The scope of the driving.
  • The driving record and how it relates to the medical condition or physical impairment, if at all.
  • How compensation for the medical condition or physical impairment (or lack of compensation) was determined.
  • Any restrictions and the reasons the restrictions were imposed.

The hearing officer will make a decision following the reexamination to take no action, or, if action is required, find that the driving privilege should be:

  • Revoked.
  • Restricted to a Class C non-commercial driver license.
  • Restricted to intrastate driving only, with no passengers and no hazardous materials requiring placards.
  • Restricted to scope or geographical area of employment.
  • Placed on probation based on a physical or mental condition.

Hearings

A driver can request a hearing if DMV has:

  • Refused to issue a CDL.
  • Restricted an already issued Class A or B, or C CDL to a Class C noncommercial license.
  • Revoked the driving privilege of a commercial applicant.

When DMV has refused, restricted, or revoked a CDL, the hearing officer must determine if the action is supported by the evidence. If the action is not supported and should be modified, the hearing officer must determine which, if any, restrictions should be imposed.

In determining whether the driver qualifies for a CDL, the hearing officer must consider the evidence received, which may include the following:

FactorsConsiderations
Hours of Work– Are the hours stable and regular?
– Are they compatible with the health needs and medical regimen required by the driver’s medical condition or physical impairment?
– If not, how has the driver dealt with unstable irregular hours in the past? How successfully?
Scope of Driving– Road and traffic conditions?
– Type of vehicle driven?
– Levels of stress and physical exertion within reasonable limits, considering the driver’s limitations?
– What are the most stressful conditions under which the driver must drive?
– How does driving under these stressful conditions affect the driver?
Mileage– How large an area does or will the driver need to cover?
– Are area or destination restrictions appropriate?
Driving Record– Does the driving record show any accidents? In a commercial vehicle? Related to the medical condition or physical impairment?
– Does the driving record show any traffic law violations? In a commercial vehicle? Related to the medical condition or physical impairment?
Health Needs– What is the medical regimen required of the driver?
– How well has the driver been able to adhere to it while driving?
– If already driving a commercial vehicle, how has the driver adjusted his driving or medical regimen?
– Have the adjustments been approved by his/her physician?
– Is strict adherence to the medical regimen compatible with the scope of employment.
– What is the prognosis of the medical condition or physical impairment?
– Are there effects related to the medical condition or physical impairment which may affect driving?
– Is there more than one medical condition or physical impairment?
– What medication(s) does the driver use and what are their side effects?
– How long has the driver been employed as a driver?
– How long has the driver been driving a commercial vehicle with the medical problem or physical impairment?
– When was the last episode, if any? Any episodes during working hours? Frequency of episodes?

Hearing Decision

The hearing officer will make a determination regarding whether the driver is competent to drive a particular commercial vehicle in specific circumstances. The hearing officer must consider the facts in each case on an individual basis, balancing the driver’s needs with the requirements of public safety. Possible determinations include:

  • Probation: Probation may be appropriate in instances when a driver is currently qualified, but the hearing officer determines that regular medical reports are warranted. The scope of driving will be restricted, and the driver must remain under medical supervision.
  • Intrastate exception: If the hearing officer restricts the driver to intrastate driving only, a scope of employment restriction tailored to the individual’s current use may be appropriate. Examples:
    • May operate a Class A or B vehicle only within the scope of employment as a mechanic.
    • When operating Class B vehicles, driver is restricted to a three axle dump truck in the municipality of (location).

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