FMCSR 391.45(a): No Medical Exam Certificate — Driver Q&A

Not automatically, but it can. Across our 13 million inspection records, 391.45(a) citations resulted in an out-of-service order only 7.0% of the time. That's significantly lower than the 31.4% average OOS rate across all FMCSR codes. In 66 of the 71 all-time citations we see for this violation, the driver was allowed to continue operating. However, when an inspector does place you OOS, it typically means you cannot legally drive until you obtain and file a valid medical examination certificate with your state licensing agency.

A 391.45(a) citation carries a CSA severity weight of 6 points. Under the CSA safety scoring system, this violation is multiplied by a 30-day event multiplier, meaning the impact compounds if you receive multiple violations within that window. While 6 points is moderate on the severity scale, accumulating citations—especially in the Driver Fitness category—can raise your CSA percentile and increase your risk of FMCSA attention, audits, or enforcement action.

Take these steps right away:

1. Contact your medical examiner — Schedule an appointment to complete or renew your DOT medical examination if it has expired or is missing.
2. Obtain your certificate — Once examined, get a copy of the medical examination certificate.
3. File it with your state — Submit the certificate to your state's commercial driver's license agency to ensure it's on file.
4. Document the filing — Keep proof of submission.
5. Contact your employer or insurer — Inform them of the citation and your remediation steps.
6. Request a DataQs RDR — If you believe the citation is factually incorrect (e.g., you had the certificate but the inspector missed it), file a DataQs Record Detailed Review to challenge it.

Speed matters: the sooner you file, the sooner the violation is resolved.

No—it's significantly less serious than related violations. Our data shows 391.41APC (operating without a valid medical certificate in possession) triggers an out-of-service rate of 97.1%, and 391.41(a) (general physical qualification) has a 16.2% OOS rate. At 7.0%, 391.45(a) is rarely enforced with an immediate OOS order. Across all inspections, we've logged only 71 citations for this code all-time, ranking it #1519 out of 3,036 FMCSR codes by volume. This suggests inspectors treat it as a documentation issue rather than a safety emergency, provided you can demonstrate the certificate exists or can be obtained quickly.

Yes. If you believe the citation is inaccurate—for example, you had a valid medical certificate on file when inspected but the inspector didn't locate it, or there's a clerical error in the citation—you can file a DataQs Record Detailed Review (RDR). The FMCSA processes RDRs and may update or remove the citation from your record if evidence supports your claim. Documentation violations like 391.45(a) are often contestable because they hinge on whether the certificate truly existed and was filed, not on your physical condition. Gather any proof of your medical examination and state filing to strengthen your challenge.

Very urgent. Although we recorded zero citations for 391.45(a) in the last 90 days and none in the last 12 months, this doesn't mean it's inactive—it reflects how quickly drivers typically resolve it. Once cited, you must obtain and file a valid medical examination certificate without delay. Operating without one exposes you to additional citations, potential out-of-service orders, and serious liability for your carrier. The low citation volume suggests most violations are caught and corrected quickly. Don't wait: schedule your DOT medical exam today and file the certificate with your state within days, not weeks.

Across our records, Maryland Tree Experts (USDOT 3304931) has the highest count at 2 citations. Nine other carriers—including W B Mason Co Inc, Waste Management of Michigan Inc, and Ryder Integrated Logistics Inc—each have 1 citation on record. The violation is not concentrated in any single carrier or region; it's scattered across diverse fleet types and geographies. Vehicle makes most commonly cited include Freightliners (15 citations), Fords (10), and Internationals (10), reflecting the general mix of commercial fleets.

Both. Under the CSA system, Driver Fitness violations appear on both your individual driver record and your carrier's CSA BASIC score. A 391.45(a) citation is logged as a driver-specific violation, but it also contributes to your carrier's overall safety metrics. This means remediation—filing your medical certificate—protects your own record and your employer's fleet profile. If you move to a new carrier, the violation stays with your FMCSA driver history, so prioritize resolution to prevent it from affecting future employment or safety audits.