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Updates on CDLs, Medical Waivers, and IRPs

Two news items courtesy of the good folks over at TRALA concerning FMCSA waivers for CDLs and medical cards, as well as information on state DMV statuses and IRP procedures.

CDLs and Medical Waivers

The Federal Motor Carrier Safety Administration (FMCSA) has issued waivers for commercial drivers licenses and medical cards due to the coronavirus outbreak throughout the U.S.

Given the lack of medical personnel available and the many restrictions that have been placed on patients in medical facilities, it became obvious in the last few weeks that drivers due to have physical examinations would not be able to see someone in a timely fashion.

In addition, commercial drivers licenses (CDLs) being administered for renewal face similar challenges now that many Department of Motor Vehicle offices are closed and there is an essential need for medical supplies, food, water, and other supplies to be delivered to those in need.

Some of the waivers include the following:

  • Extends until June 30, 2020 the maximum period of CDL validity by waiving 49 CFR 383.73(b)(9) and 383.73(d)(6) for CDLs due for renewal on or after March 1, 2020.

  • Extends until June 30, 2020 the maximum period of CLP validity by waiving 49 CFR 383.73(a)(2)(iii) and 383.25(c) for CLPs that are due for renewal on or after March 1, 2020, without requiring the CLP holders to retake the general and endorsement knowledge tests.

  • Waives the requirement under 49 CFR 383.25(e) that CLP holders wait 14 days to take the CDL skills test.

  • Waives the requirement under 49 CFR 391.45 that CDL holders, CLP holders, and non-CDL drivers have a medical examination and certification, provided that they have proof of a valid medical certification that was issued for a period of 90 days or longer and that expired on or after March 1, 2020. e.

  • Waives the requirement under 49 CFR 383.71(h)(3) that, in order to maintain the medical certification status of “certified,” CDL or CLP holders provide the State Driver Licensing Agency with an original or copy of a subsequently issued medical examiner’s certificate, provided that they have proof of a valid medical certification that expired on or after March 1, 2020.3

  • Waives the requirement under 49 CFR 383.73(o)(2) that the State Driver Licensing Agency change the CDL or CLP holder’s medical certification status to “not certified” upon the expiration of the medical examiner’s certificate or medical variance, provided that the CDL or CLP holders have proof of a valid medical certification that expired on or after March 1, 2020.

  • Waives the requirements under 49 CFR 383.73(o)(4) that the State Driver Licensing Agency initiate a CDL or CLP downgrade upon the expiration of the medical examiner’s certificate or medical variance, provided that the CDL or CLP holders have proof of a valid medical certification or medical variance that expired on or after March 1, 2020.

  • In accordance with 49 CFR 383.23(a)(1) and 391.41(a)(1)(i), FMCSA continues to recognize the validity of commercial driver’s licenses issued by Canadian Provinces and Territories and Licencias Federales de Conductor issued by the United Mexican States, in accordance with 49 CFR part 383, when such jurisdictions issue a similar notice or declaration extending the validity date of the medical examination and certification and/or validity of the corresponding commercial driver’s license due to interruption to government service resulting from COVID-19.

To view the entire waiver release by the FMCSA click here.

State DMV Status and IRP Procedures

In response to the COVID-19 (Coronavirus) Pandemic many states have chosen to close or reduce their Departments of Motor Vehicles, which has reduced their ability to answer questions and process services for motor carriers. This has been particularly difficult for the states’ ability to operate the International Registration Plan (IRP). Currently, many states are assessing how to reduce the regulatory burden on motor carriers. 

One of the main concerns facing motor carriers are pending annual IRP renewals. Many TRALA members are concerned that the expense of paying these renewals could lead to a cash crunch and make it difficult to operate their business as the economy has slowed down dramatically due to the coronavirus. The IRP Board of Directors has held several calls to discuss the best way to reduce the burden on the carriers. The Board has discussed many possibilities which include halting the enforcement of renewals and allowing for payments to be made in installments rather than all at once. To further complicate this situation, there is no mechanism in place to halt or manage payments across all jurisdictions. This would mean that a Base Jurisdiction could halt the enforcement of renewals, but other states might not take a similar action which would cause the carrier to still have to pay the other jurisdictions they operate in. 

TRALA has been working with its partners in the states and a handful of its member companies to keep a running list of DMV closures and actions taken by the states to reduce the IRP burdens. You may view a document put together by TRALA containing an updated status for each state DMV by clicking here. Currently, TRALA has received notices from several states regarding their IRP enforcement which you can access by clicking here. This is a very fluid situation and jurisdictions are making decisions quickly and this list can change often. TRALA is urging its members to contact their jurisdictions directly with questions specific to their jurisdiction. You may also find some of the latest developments from the IRP by visiting their web site which can be found here.

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We here at CyntrX would like to thank Andrew Stasiowski and Jake Jacoby of TRALA for allowing us to repost this material. Now more than ever trucking is the backbone of America, and we're glad that we're able to play a part in sharing useful information.

Stay safe and healthy, everyone.