FMCSR 391.41APC: Medical Certificate Violations Explained

Almost certainly yes. Across all-time records, 391.41APC carries a 97.1% out-of-service rate — 48,126 of 49,539 total citations resulted in an OOS order. That is nearly three times the all-FMCSR average OOS rate of 31.4%. In high-enforcement states the numbers are even sharper: New York hits 99.7% OOS, Georgia 99.9%, and Maryland 99.9% over the last 180 days. If an inspector finds you operating without a valid medical certificate in possession or on file with your state licensing agency, the odds are overwhelming that your vehicle will be parked until the issue is resolved.

391.41APC falls under the Driver Fitness BASIC in the CSA scoring system. A severity weight specific to this code is not published in the available data, but violations in the Driver Fitness BASIC are weighted on a scale of 1–10 and carry a time-based multiplier: citations from the most recent 6 months count at full weight, those from 6–12 months count at 2/3 weight, and those from 12–24 months count at 1/3 weight. Because this violation has a 97.1% OOS rate in our inspection records, any resulting OOS finding will also trigger an additional OOS severity multiplier in your CSA score. Contact FMCSA's DataQs system promptly if any detail on the inspection report is inaccurate.

Get your documentation in order before you move the vehicle. Here is the priority sequence:

1. Locate or obtain your valid medical certificate — contact your certified medical examiner immediately if you need a copy.
2. Check for companion violations. Our inspection records show that in the last 90 days, 391.41APC appeared alongside 396.17C-PI (no proof of periodic inspection) in 1,982 shared inspections, and with 383.23A2-LCDLN (operating without a valid CDL) in 1,372 shared inspections. Resolve all cited items before requesting a reinspection.
3. Notify your fleet safety manager or dispatcher so they can update the driver qualification file.
4. Request a signed copy of the inspection report from the officer for your DataQs file.

Yes — it is one of the most enforcement-heavy and highest-OOS codes in its category. Our inspection records rank 391.41APC #64 out of 3,036 FMCSR codes by citation volume, with 49,539 all-time citations. Its 97.1% OOS rate dwarfs most Driver Fitness peers: the related code 391.41(a) (physical qualification — general) has a 16.2% OOS rate, and 391.41A-MCPC sits at 14.4%. Even compared to CDL-related peer codes like 383.23A2-LCDLN at 98.6%, the practical enforcement outcome for 391.41APC is nearly identical. The data makes clear that inspectors treat a missing medical certificate as an automatic stop-the-truck situation.

Yes, you can submit a Request for Data Review (RDR) through FMCSA's DataQs system. Because 391.41APC is a documentation violation — not an equipment defect — the most viable grounds for a successful challenge are factual errors on the inspection report, such as a wrong certificate number, incorrect expiration date, or proof that a valid certificate was on file with the state licensing agency at the time of the inspection. If you have documentary evidence (a timestamped copy of the certificate, state licensing agency records), gather it before filing. DataQs challenges that include supporting documents are generally more successful than unsupported claims. Submit your RDR at the FMCSA DataQs portal; the reviewing agency is typically the state patrol or enforcement body that issued the citation.

New York, Texas, and Georgia are the top three enforcement states. Over the last 180 days our inspection records show New York issued 2,736 citations with a 99.7% OOS rate, Texas issued 2,369 citations with a 92.7% OOS rate, and Georgia issued 1,901 citations with a 99.9% OOS rate. Maryland (1,493 citations) and Pennsylvania (1,167 citations) round out the top five. If your routes regularly pass through any of these states, ensuring your medical certificate is current and physically in your possession — or confirmed on file with your state DMV — is non-negotiable.

Treat it as an immediate compliance priority. The 97.1% all-time OOS rate alone makes this urgent, but the volume trend reinforces it. Our inspection records show citations climbed from 1,285 in April 2025 to a 12-month peak of 5,006 in September 2025, and enforcement has remained elevated — 3,784 citations in February 2026 and 4,241 in March 2026. Over the last 90 days alone there were 9,288 citations. This is not a paperwork technicality that inspectors overlook; it is one of the most consistently enforced Driver Fitness violations in the database, and the pace of enforcement shows no sign of declining.

It follows both. In FMCSA's CSA system, Driver Fitness BASIC violations are attributed to the carrier's Safety Measurement System (SMS) score because the carrier is responsible for maintaining driver qualification files, including valid medical certificates. At the same time, the violation appears on the individual driver's inspection history and can affect their personal Compliance History. Carriers have a direct incentive to audit DQ files proactively — our records show that even large fleets accumulate significant exposure: FEDERAL EXPRESS CORPORATION (USDOT 86876) leads all carriers with 106 all-time citations for this code, demonstrating that no operation is too large to escape inspector scrutiny on medical certificate compliance.