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Compliance Reference

49 CFR § 391.43

Medical examination; certificate of physical examination

Effective: Last amended: Last reviewed:

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What does 49 CFR § 391.43 require?

Every commercial driver must pass a DOT physical exam before operating a CMV and at regular intervals thereafter. Only medical examiners listed on the FMCSA National Registry can perform the exam. The examiner issues a Medical Examiner's Certificate (the 'med card') with a maximum 24-month validity, sometimes shorter for drivers with managed conditions. The carrier must keep a copy of the med card in the driver's qualification file (DQF), and the driver typically carries a copy in the vehicle for roadside inspection. An expired med card is one of the fastest ways to take a driver out of service during a routine inspection.

Regulation text (summary)

Each driver who operates a CMV must be medically certified as physically qualified per the criteria in 49 CFR 391.41. Medical examinations must be performed by a licensed medical examiner listed on the FMCSA National Registry of Certified Medical Examiners (NRCME). The examiner uses Form MCS-5875 to record the examination findings and Form MCS-5876 (the Medical Examiner's Certificate, often called the 'med card') as proof the driver is medically qualified. The certificate is valid for up to 24 months, but may be issued for a shorter period if the examiner determines closer monitoring is necessary (e.g., for hypertension, diabetes, or sleep apnea).

Read full regulation at eCFR.gov

Who must comply with 49 CFR § 391.43?

All drivers operating a CMV in interstate commerce (over 10,001 pounds GVWR, hauling 8+ passengers for hire, 15+ passengers regardless of compensation, or transporting placardable hazmat) must hold a current DOT medical certificate. Intrastate drivers must comply with state-specific medical requirements, which in most states mirror or directly adopt the federal 49 CFR 391.43 standards. CDL holders must self-certify their operating category and submit medical certificates to their state driver licensing agency. Owner-operators are subject to the same medical examination and certification requirements as employee drivers — there is no exemption for ownership status.

What happens if you violate 49 CFR § 391.43?

Operating a CMV with an expired or missing medical certificate triggers an immediate out-of-service (OOS) declaration at the roadside. The driver cannot resume operating until a current certificate is produced and the vehicle is released. The carrier faces civil monetary penalties of $1,100 to $16,550 per violation for permitting an unqualified driver to operate, plus CSA points in the Driver Fitness BASIC that affect the carrier's safety rating and inspection-selection algorithm. Multiple medical certificate violations across a fleet can trigger a Compliance Review and Conditional safety rating, which affects insurance premiums, broker eligibility, and contractor relationships.

$1,100–$16,550

Penalty range

~18,000

Annual citations

+6.4%

YoY penalty trend

How to comply (implementation checklist)

  1. 1Confirm the medical examiner is on the NRCME registry before accepting any new med card.
  2. 2Receive both Form MCS-5875 (exam findings) and Form MCS-5876 (the certificate) — store both in the DQF.
  3. 3Verify the expiration date printed on the certificate (not assumed 24 months — could be shorter).
  4. 4Set 90/60/30-day renewal alerts before each driver's certificate expires.
  5. 5Schedule the renewal exam at least 30 days before expiration to avoid same-day pressure.
  6. 6Confirm CDL holders also self-certified their operating category with the state DMV.
  7. 7Cross-reference the certificate with vision/diabetes/sleep-apnea waivers if applicable (49 CFR 391.49).
  8. 8Retain expired certificates in the DQF for 3 years after the driver's separation date.
  9. 9Train dispatchers to refuse dispatch when a driver's certificate is expired or near-expired.
  10. 10Audit the entire fleet quarterly for medical certificate currency.

Common misinterpretations

  • Misinterpretation: 'My driver's med card is good for 2 years.' Reality: The certificate can be issued for up to 24 months, but the medical examiner may issue it for a shorter period (3, 6, 12 months) when monitoring a condition such as controlled hypertension, type 2 diabetes, or sleep apnea. Check the actual expiration date printed on the card.
  • Misinterpretation: 'Any doctor can perform a DOT physical.' Reality: Since May 21, 2014, only medical examiners listed on the FMCSA National Registry of Certified Medical Examiners (NRCME) may perform DOT physicals. The carrier should verify the examiner's NRCME number on the certificate matches the registry at https://nationalregistry.fmcsa.dot.gov before accepting any new med card.
  • Misinterpretation: 'A CDL holder doesn't need a separate med card.' Reality: CDL holders must hold a valid medical certificate AND have certified their operating category with the state DMV (non-excepted interstate, excepted interstate, non-excepted intrastate, excepted intrastate). The state-issued CDL includes a medical certification status that must remain current — separate from the physical med card the driver carries.
  • Misinterpretation: 'The doctor's note is enough.' Reality: Only the official Medical Examiner's Certificate (MCS-5876) is acceptable. A general doctor's clearance letter, hospital discharge note, or specialist consultation does not satisfy 49 CFR 391.43. The certificate must be issued by an NRCME-registered examiner using the FMCSA forms.

Real enforcement examples

Anonymized from public FMCSA enforcement summaries. Penalty amounts reflect assessed and final settled values where disclosed.

Texas-based interstate carrier received a $33,100 assessed penalty in 2024 after a roadside inspection found a driver operating with a med card that expired 8 days earlier. The driver was placed out of service. The follow-up compliance review found 3 additional drivers in the fleet with expired certificates ranging from 5 days to 4 months past expiration.

Source: FMCSA SafetyNet 2024 enforcement summary, anonymized

Mid-size carrier (35 trucks) received a $66,200 penalty when a 2025 audit revealed 4 drivers had medical certificates signed by an examiner who was no longer on the NRCME registry at the time of the exam. The certificates were ruled invalid retroactively and the carrier was cited for operating unqualified drivers.

Source: FMCSA SafetyNet 2025 enforcement summary, anonymized

How FileFlo handles 49 CFR § 391.43

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Frequently asked questions

How long is a DOT medical card valid under 49 CFR 391.43?

Up to 24 months from the date of the examination. The medical examiner may issue a certificate for a shorter period — 3, 6, or 12 months — when the driver has a managed medical condition (controlled hypertension, type 2 diabetes, sleep apnea, etc.) that requires closer monitoring. The actual expiration date is printed on the certificate.

Who can perform a DOT physical?

Only medical examiners listed on the FMCSA National Registry of Certified Medical Examiners (NRCME). The NRCME requirement took effect May 21, 2014. Examiners include MDs, DOs, physician assistants, advanced practice nurses, and chiropractors who have completed FMCSA-approved training and passed the certification test. Verify the examiner's NRCME number at https://nationalregistry.fmcsa.dot.gov before accepting any certificate.

What happens if my driver's med card is expired?

An expired medical certificate makes the driver unqualified to operate a CMV. At a roadside inspection, this results in an immediate out-of-service declaration — the driver cannot resume operating until a current certificate is produced. The carrier faces civil monetary penalties of $1,100 to $16,550 per violation, plus CSA Driver Fitness BASIC points. The driver may also need to re-take the DOT physical before being re-certified.

Do CDL holders need a separate medical certificate?

CDL holders must hold a valid medical certificate AND certify their operating category with the state DMV (non-excepted interstate, excepted interstate, non-excepted intrastate, or excepted intrastate). The state-issued CDL includes a medical certification status field that must remain current. The physical med card is what the driver carries during operations; the state DMV record is what the carrier relies on for fleet-wide tracking.

What conditions can disqualify a driver under 49 CFR 391.41?

Disqualifying conditions include uncorrected vision worse than 20/40 in each eye and both eyes together, hearing loss exceeding specified thresholds, uncontrolled hypertension (Stage 3, 180/110+ requires immediate disqualification), insulin-treated diabetes without an exemption, current use of habit-forming drugs or methadone, and a current clinical diagnosis of certain cardiovascular, respiratory, or neurological conditions. Drivers with controlled conditions may still be qualified subject to a shorter certificate validity period and ongoing monitoring.

Can a driver get a med card if they have a vision waiver?

Yes — drivers with monocular vision (one functional eye) or who otherwise don't meet the vision standard may apply for a Vision Exemption under 49 CFR 391.64 (formerly the Federal Vision Waiver Program). The exemption requires medical specialist evaluation and FMCSA review. The medical examiner notes the exemption on the certificate. Similar waiver programs exist for diabetes (insulin-treated) and hearing — all managed under 49 CFR 391.49.

Where must the medical examiner's certificate be kept?

The carrier must keep a copy in the driver's qualification file (DQF) per 49 CFR 391.51. The driver typically carries a paper copy in the vehicle for roadside inspection (this practice predates the 2014 CDLIS integration and remains common). For CDL holders, the medical certification status must also be on file with the state DMV — when the driver renews the medical card, they (or the medical examiner) must submit the new certificate to the state DMV to update the CDL status.

What is the difference between 49 CFR 391.41 and 49 CFR 391.43?

49 CFR 391.41 specifies the physical and medical qualifications a driver must meet to operate a CMV — vision, hearing, blood pressure, prohibited substance use, and so on. 49 CFR 391.43 specifies the examination process and certification document that proves the driver met those standards. 391.41 sets the medical standards; 391.43 sets the documentation requirement.

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Chad Griffith

Founder + CEO, FileFlo · Defense + Aviation Operations · 8 years FMCSA / DOT compliance experience

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Primary source: eCFR.gov: 49 CFR § 391.43

Reviewed by Chad Griffith (Founder + CEO, FileFlo) on

Disclaimer: This page summarizes a federal regulation in plain English. FileFlo is not a law firm; this is not legal advice. The regulation text and primary sources at eCFR.gov are authoritative. Consult qualified counsel for advice specific to your operation.