The Two-Year Card From an Unlisted Chiropractor
A 54-year-old driver with a Class A CDL and H endorsement goes to a chiropractor for his DOT physical. The chiropractor is licensed in Kansas but is not listed on the FMCSA National Registry of Certified Medical Examiners. The driver's blood pressure is 164/104 on the first reading and 162/102 on the second. He has insulin-treated diabetes, A1C 7.1%, and no severe hypoglycemic episodes in the past 12 months. His treating endocrinologist completed the MCSA-5870 form and says he is stable. The chiropractor issues a two-year medical examiner's certificate, writes 'qualified' on the form, and tells the driver he is 'good to go' until 2027. The driver's current card expired yesterday. He is scheduled to haul a placarded load of Class 8 material at 5 a.m. tomorrow.
1. Is the medical examiner's certificate valid for CDL purposes?
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No. A DOT medical examination for a CDL holder must be performed by a medical examiner listed on the FMCSA National Registry of Certified Medical Examiners. The certificate must include the examiner's registry number. A chiropractor can be a certified medical examiner if he or she meets the qualifications and is listed, but this chiropractor is not listed. That makes the examination invalid, regardless of the examiner's state license or the driver's actual health.
The driver's prior card expired yesterday, so he currently has no valid medical certification. He cannot drive the placarded Class 8 load tomorrow on the strength of this card. The carrier should not dispatch him until he is examined by a registry-listed medical examiner and has a valid certificate.
2. If the driver is examined by a properly listed medical examiner, what certification period should the blood pressure and diabetes support?
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The blood pressure readings of 164/104 and 162/102 fall in the Stage 2 range: systolic 160-179 or diastolic 100-109. Under the FMCSA hypertension guidance, a driver in Stage 2 may be certified for up to 3 months, not two years. The examiner should schedule a recheck rather than issue a long card.
The insulin-treated diabetes adds a separate limit. Since 2018, a certified medical examiner may certify an insulin-treated driver if the driver meets the requirements and the treating clinician provides the MCSA-5870 form. The examiner may issue a certificate for up to 12 months, not 24 months. The shorter limit controls. The correct result here is a certification period of no more than 3 months, with the diabetes documentation reviewed and the blood pressure rechecked.
3. What should the driver and carrier do before the 5 a.m. dispatch?
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The driver should not report for the hazmat run. He should obtain a new examination from a medical examiner listed on the National Registry. He should bring the endocrinologist's MCSA-5870 form so the examiner can evaluate the insulin-treated diabetes. The examiner should document the blood pressure readings and set an appropriate short certification period.
The carrier should verify that the new certificate is valid and issued by a listed examiner before allowing the driver to perform safety-sensitive functions. The carrier should not accept the chiropractor's two-year card or rely on the driver's statement that he is 'good to go.' If the new examiner finds the driver not qualified, the carrier must keep him out of service until he meets the standards. A placarded load does not create an exception to the medical certification rules.