Under 49 CFR 391.41(a), a person subject to FMCSA driver qualification rules must not operate a commercial motor vehicle unless medically certified as physically qualified to do so. The examination that leads to this certification is commonly called a DOT physical.
Under 49 CFR 391.43(a), the examination must be performed by a medical examiner listed on the National Registry of Certified Medical Examiners. Under 49 CFR 390.103(a)(1), a medical examiner must be licensed, certified or registered under state law to perform physical examinations and must be an advanced practice nurse, doctor of chiropractic, doctor of medicine, doctor of osteopathy, physician assistant or other medical professional authorized by state law to perform physical examinations.
The examiner checks the driver against the physical qualification standards in 391.41(b). These cover limbs, diabetes treated with insulin, heart and respiratory conditions, high blood pressure, epilepsy and other conditions that can cause loss of control, mental disorders, vision, hearing, drug use and alcoholism.
If the driver is found qualified, the examiner records the results as 49 CFR 391.43 requires. On or after June 23, 2025, the examiner completes a Medical Examiner's Certificate and furnishes it to the person examined, and provides a copy to a requesting prospective or current employing motor carrier, when the person will not be operating a commercial motor vehicle that requires a CDL or commercial learner's permit. For a driver who will operate a CDL or CLP vehicle, the examiner reports the examination results to FMCSA electronically. Under 391.43(i), the examiner keeps the Medical Examination Report and a copy or electronic version of each medical examiner's certificate on file for at least 3 years.
A DOT physical and a DOT drug test are separate. FMCSA guidance states that DOT drug and alcohol testing is not part of the physical qualification examination.
Sources: 49 CFR 391.41, 49 CFR 391.43, 49 CFR 390.103, 89 FR 3892
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