FMCSR 391.41A: Physical Qualification Violations Explained

It depends on the inspector's finding, but the odds are nearly coin-flip. Across 11,387 all-time citations in our inspection records, 5,654 drivers were placed out of service under 391.41A — a 49.7% OOS rate. That is well above the all-FMCSR average of 31.4%, meaning inspectors treat physical qualification deficiencies as a more serious safety risk than the typical violation. In Iowa, the single heaviest-enforcement state over the last 180 days, the OOS rate climbs to 97.8% on 409 citations. If your medical certification or physical qualification documentation is missing or expired, assume the inspector will pull you from service until the issue is resolved.

391.41A carries a severity weight of 7 on the CSA scale. That weight is then multiplied based on how recent the inspection was: violations in the last 6 months receive a 3× time-weight multiplier, violations between 6 and 12 months ago receive 2×, and violations older than 12 months receive 1×. A fresh 391.41A citation therefore contributes 21 weighted points to the Driver Fitness BASIC before any other factors. Because 391.41A falls in the Driver Fitness BASIC, the points follow the driver's record and surface in carrier SMS scores simultaneously — making timely resolution critical for both parties.

Act on documentation first, then check your whole inspection report for companion violations. Our inspection records show that in the last 90 days, 391.41A frequently appears alongside 396.17C (no proof of periodic inspection, 104 shared inspections), 390.21TB (82 shared inspections), and 392.2RG (operating while ill or fatigued, 79 shared inspections). That pattern means inspectors who find a physical qualification issue often dig deeper.

Immediate steps:

1. Contact your carrier's safety department before moving the vehicle if you were placed OOS.
2. Locate or obtain your valid medical certificate — this is the most common documentation gap.
3. Review the full inspection report for co-cited codes, especially 383.23A2 (no CDL, 76 shared inspections in 90 days).
4. Do not drive until any OOS conditions are formally cleared by an authorized inspector.

Serious — but its OOS rate sits in the middle of the Driver Fitness peer group. Our database shows 391.41A's 49.7% OOS rate is significantly higher than the all-FMCSR average of 31.4%. Among peer codes, 383.23(a)(2) (wrong CDL class) carries a 98.4% OOS rate on 50,385 citations, and 391.41APC (no valid medical certificate) hits 97.1% on 49,539 citations — both far more likely to pull a driver from service. By contrast, related codes like 391.41(a) and 391.41A-MCPC sit at 16.2% and 14.4% OOS rates respectively. At 49.7%, 391.41A lands in a middle tier: enforcement is active and OOS is a real outcome, but not a near-certainty the way missing-CDL violations are.

Yes, DataQs is the correct channel to challenge a 391.41A finding you believe is incorrect. The FMCSA DataQs system (Request for Data Review, or RDR) lets drivers and carriers submit evidence that a citation was issued in error, that documentation was present and valid at the time of inspection, or that the violation was recorded incorrectly. For 391.41A specifically, the most defensible challenges are documentation-based: if your medical certificate was current and on your person but not logged correctly, contemporaneous records such as a copy of the certificate with a matching date are strong supporting evidence. Frivolous challenges rarely succeed — focus your RDR on factual discrepancies, not disagreements with inspector judgment.

Iowa, Illinois, and North Carolina account for the heaviest enforcement activity in our recent data. Over the last 180 days, Iowa led all states with 409 citations and a striking 97.8% OOS rate — meaning nearly every 391.41A stop in Iowa results in the driver being pulled from service. Illinois logged 206 citations with a 72.8% OOS rate, and North Carolina recorded 168 citations at an 86.3% OOS rate. New Mexico added another 107 citations at 73.8%. If your routes regularly pass through these states, having physical qualification documentation current and immediately accessible is not optional — it is a practical road-safety measure.

Treat it as urgent. The last 12 months produced 2,481 citations, and our inspection records show a significant spike in May 2025 with 429 citations in a single month — the highest monthly total in the trailing year, with 349 of those resulting in OOS. Even outside that spike, monthly volumes have held between 126 and 224 citations consistently through the rest of the period. With a 49.7% all-time OOS rate and 418 citations in just the last 90 days, enforcement is active and sustained. Letting a physical qualification deficiency linger means operating with a near-coin-flip chance of being shut down at the next scale or inspection stop.

Both. Under FMCSA's CSA methodology, Driver Fitness BASIC violations are attributed to the driver's PSP (Pre-Employment Screening Program) record and simultaneously roll up into the carrier's Driver Fitness BASIC score. A 391.41A citation with its severity weight of 7 will appear on your personal safety history and affect any carrier that employs you within the CSA look-back window. Carriers with multiple drivers accumulating Driver Fitness citations can see their BASIC percentile deteriorate quickly, which is why fleets like Federal Express Corporation (26 all-time citations, USDOT 86876) and United Parcel Service Inc (12 citations, USDOT 21800) have compliance programs specifically targeting medical certificate tracking.