Questions and Answers on the NEW Commercial Driver Requirement

  • I heard there is a new requirement for people who wish to obtain or who currently hold a commercial driver's license?

    Yes, everyone who wishes to obtain or who currently holds a Commercial Driver's License (CDL) will need to inform the RMV of the type of commerce they plan to operate within (interstate or intrastate) and whether or not they are required to hold a medical certificate. This notification is called self-certification.

    Those drivers required to have a DOT medical certificate, or have a medical variance from the federal government or a state medical waiver, will also need to provide the RMV with a copy of this paperwork. Those drivers who are not required to obtain a medical certificate will need to submit an Exemption Form signed by their employer. This form will be available on the RMV website.

  • Why is this new requirement called self-certification?

    It is called self-certification because the driver, alone, needs to determine the self-certification category they fall into based on their driving information.

  • When do I need to self-certify and provide the RMV with a copy of my medical certificate, exemption document, variance, or waiver?

    New CDL applicants will need to self-certify and provide medical documentation before being issued a permit. If you currently hold a CDL, you will need to complete your certification if you renew or upgrade your CDL between Spring 2012 and January 30, 2014. If your license does not expire until after January 30, 2014, then you will need to provide us with your self-certification information and a copy of your documentation prior to this date. You will be able to self-certify in an RMV branch or via an on-line transaction in spring of 2012.

  • Do I need to submit all nine (9) pages of the Medical Examination Report?

    No, you only need to provide the completed one-page Medical Examiner's Certificate. This is the final page of the full Medical Examination Report signed by the medical provider.

  • Will I still have to carry my medical certificate with me?

    You will need to carry your medical certificate with you until January 30, 2014. After that date, you will no longer need to carry it.

  • Am I affected by the new requirement if I operate a commercial motor vehicle that does not require me to have a Commercial Driver's License (CDL)?

    No, if you operate a commercial motor vehicle that is over 10,000 lbs. and less than 26,000 lbs. with a Class D license, you are not required to self-certify. However, if you are required to hold a medical certificate, you must continue to carry it with you.

  • What is the difference between Interstate and Intrastate commerce?

    Interstate commerce is trade, traffic, or transportation involving the crossing of a state boundary. Either the vehicle, its passengers, or cargo must cross a state boundary, or there must be the intent to cross a state boundary to be considered an interstate carrier.

    Intrastate commerce is trade, traffic, or transportation within a single state.

    If your operations include interstate commerce, you must comply with the applicable federal safety regulations and operating authority rules, in addition to state and local requirements. You must notify the state in which you plan to register your vehicle(s) of your intentions to operate in interstate commerce to ensure that the vehicle is properly registered for purposes of the International Registration Plan (IRP), and International Fuel Tax Agreement (IFTA). The base state will help you by collecting the appropriate fees and distributing a portion of those fees to the other states in which you operate commercial motor vehicles.

    If you operate exclusively in intrastate commerce, you must comply with applicable state and local regulations. The only federal regulations that are applicable to intrastate operations are:

    • The Commercial Driver's License (CDL) requirement, for drivers operating commercial motor vehicles as defined in 49 CFR 383.
    • Controlled substances and alcohol testing for all persons required to possess a Commercial Driver's License.
    • Minimum levels of financial responsibility for the intrastate transportation of certain quantities of hazardous materials and substances.
  • How many self-certification categories are there?

    There are four (4) different categories you may fall into as a CDL driver. The category you choose depends on whether you operate in interstate or intrastate commerce and whether or not you are required to have a medical certificate or are exempt.

    • Non-excepted Interstate (NI) - You operate or expect to operate in interstate commerce, and are subject to meet federal qualification requirements (Title 49, Section 391.64) and are required to obtain a medical examiner's certificate.
    • Excepted Interstate (EI) - You operate or expect to operate in interstate commerce, but engage exclusively in transportation or operations that are excepted from all or parts of the federal qualification requirements, and are therefore not required to obtain a medical examiner's certificate.
    • Non-excepted Intrastate (NA) - You only operate in intrastate commerce and are subject to State driver qualification requirements and are required to obtain a medical examiner's certificate.
    • Excepted Intrastate (EA) - You operate in intrastate commerce, but engage exclusively in transportation or operations excepted from all or parts of the State driver qualification requirements, and are therefore not required to obtain a medical examiner's certificate.
  • What if I don't normally operate in interstate commerce but meet the qualifications to do so?

    You should self-certify at the highest standard for which you qualify. NI is the broadest category and the one you should select if you meet the criteria, even if you currently do not consider yourself an interstate driver.

  • Can you provide examples for each of the categories?

    Following are the types of drivers that may fall into each category.

    • Non-excepted Interstate (NI) - All Class A, B, or C privately or self-employed commercial drivers who operate or expect to operate in interstate commerce, and are subject to meet the federal medical standard and therefore are required to obtain a medical examiner's certificate.
    • Excepted Interstate (EI) -
      • City, municipal, or state employed CDL holders
      • Beekeepers
      • Transporters of human corpses or sick and injured persons
      • Fire truck or rescue vehicle drivers during emergencies or other related activities
    • Non-excepted Intrastate (NA)
      • Drivers 18-21 years of age with a K restriction associated with their license to operate
      • Drivers 21 and over with a W Restriction associated with their license to operate
    • Excepted Intrastate (EA) - Same examples as Excepted Interstate except only engaging in Intrastate commerce

    See the Medical Self-Certification policy on the RMV website for a more extensive list of examples www.mass.gov/rmv

  • How do I know if I need to have a DOT medical certificate?

    To qualify for a Commercial Driver's License (CDL) in Massachusetts, you must pass a Department of Transportation (DOT) medical examination. Medical examiner's certificates are valid for no more than two years. Some medical conditions may require you to have a physical examination more frequently.

  • What if I do not meet the physical qualifications required?

    If you do not meet the vision or diabetes physical qualification standards, or have a loss or impairment of limbs, you may be able to satisfy alternative physical qualifications or qualify for an exemption with the Federal Motor Carrier Safety Administration (FMCSA). Additional information can be found on the FMCSA website at www.fmcsa.dot.gov

  • What if I can't meet the medical qualifications for interstate commercial operation?

    If you do not meet the medical qualifications for commercial motor vehicle (CMV) interstate commercial operation, you may qualify for an intrastate medical waiver through the Registry of Motor Vehicles. This waiver permits operation of a CMV used in Massachusetts intrastate commerce only. Intrastate medical waiver applications and information may be accessed through the following link: http://www.mass.gov/rmv/forms/21156.pdf

  • Why did my employer tell me that I do not need to have a DOT medical certificate even though I drive a commercial vehicle?

    Most city, municipal, and state employed commercial drivers are not required to obtain a medical certificate. The same is true for beekeepers who operate commercial vehicles. However, this is only if you drive exclusively for a municipality or state agency. In lieu of a medical certificate, Massachusetts requires you to submit an Exemption document for EI or EA self-certification categories. Your employer will need to sign an Exemption document in order for you to self-certify.

  • What if I work for a city or state agency but also plow in the winter for a contractor in my town?

    In this case, you would need to have a medical certificate if you are operating a commercial vehicle over 10,000 lbs. Also, drivers transporting 15 or more passengers or carrying placarded hazardous materials, regardless of vehicle size, are required to carry a DOT medical certificate.

  • I'm not currently driving a CDL vehicle or employed as a CDL driver. Do I still need to self-certify?

    Yes, if you would like to keep your CDL, you must self-certify. Otherwise, you may choose to downgrade to a Class D license. Drivers cannot keep a CDL without self-certifying.

  • What if I fail to provide the required information?

    Failure to provide your self-certification information and a copy of your medical certificate, if you require one, by January 30, 2014 will result in the downgrading of your commercial driver license (CDL). You will receive notice from the RMV reminding you to self-certify by the required date.

  • Can I provide my information to the RMV prior to that date?

    Yes, in Spring 2012 you will be able self-certify in an RMV branch or on-line at www.mass.gov/rmv

  • How often do I need to provide the RMV with my self-certification information?

    Self-certification is tied to the expiration date of your medical certificate, so at least every two years. If you are not required to hold a medical certificate, then you will self-certify every two years.

  • How will I know when I need to re-certify?

    After your initial self-certification, you will receive a reminder letter when your self-certification is due to expire. Notices will be sent to the address we have on record 90 days and 30 days prior to the expiration date. If you do not re-certify by the expiration date, you will no longer be authorized to operate a vehicle requiring a commercial driver license (CDL).

    You may also need to re-certify prior to the expiration date if the type of driving you conduct has changed.

  • If I do not re-certify, what will happen?

    If your updated information is not received within 60 days after the expiration date on record:

    1. The RMV will downgrade you to a Class D license which will be mailed to you.
    2. A $25.00 license amendment fee will be posted on your driving record to be collected at the time of your next license transaction.
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