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Blog-FMCSA Compliance-49 CFR 391.46

Is There an A1C Limit for a DOT Physical?

Last updated October 28, 2026

Quick Answer

No. Federal rules set no A1C number for a DOT physical. A driver with diabetes managed without insulin is judged by the medical examiner like any other condition. A driver on insulin qualifies under 49 CFR 391.46: a treating clinician completes Form MCSA-5870 within 45 days before the exam, and the certificate lasts at most 12 months.

What the examiner looks at

The examiner checks for severe diabetic retinopathy under 49 CFR 391.41(b)(3) and 391.46. For a driver on insulin, the examiner needs the MCSA-5870 and the glucometer records. Three months of records are needed for a full 12-month certificate.

Can an examiner still ask for an A1C?

An examiner may ask for any test needed to decide whether the condition is controlled; the number they act on is their medical judgement, not a federal cutoff.

How long the card lasts

A driver may be certified for up to 24 months. For insulin-treated diabetes the maximum is 12 months (49 CFR 391.45).

What the carrier keeps

The carrier keeps the medical certification in the driver qualification file (49 CFR 391.51(b)).

For the insulin standard in full, read DOT Physical and Diabetes: Insulin, the ITDM Standard, and the MCSA-5870. For tracking the expiration date once the card is issued, read CDL Medical Card Expiration Tracking.

Written by The FileFlo compliance team. Reviewed October 28, 2026. FileFlo is a compliance records service, not legal advice.

Questions

Frequently Asked Questions

No. Federal rules set no A1C number for a DOT physical. A driver with diabetes managed without insulin is judged by the medical examiner like any other condition. A driver on insulin qualifies under 49 CFR 391.46: a treating clinician completes Form MCSA-5870 within 45 days before the exam, and the certificate lasts at most 12 months.

No, not since the 2018 rule: an insulin-treated driver can be certified under 49 CFR 391.46 for up to 12 months.

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