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There is often confusion regarding motor carriers that only have intrastate drivers and non-commercial license drivers, yet still coming in for the DOT/CDL exam.

Commercial Driver Program

Recall that the FMCSA/DOT program is applicable to certain drivers and vehicles involved in interstate commerce.  There are many bus companies, package car drivers and other motor carriers for whom the federal law is not technically applicable, yet they want their drivers held to same quality medical standards as called for by the DOT regs, so are required by their employers to have the same DOT exam.  Many states require the DOT exam even for those that are only involved in intrastate transportation.
Two specific areas of confusion are the two boxes to check on the medical certificate:
  • “Applicable State Variances” refers to cases where there is a state exemption document presented by the driver, exempting the driver from a specific qualification standard.  These are rare.  This may also be checked if the driver is under 21, as you must be 21 to qualify for interstate commercial driving, but some states allow 19 year old drivers to operate within state borders.
  • “CDL yes/no”  is checked “yes” if the driver possesses a class “A”, “B” or “C” license, as indicated below, and which is marked on their driver’s license.  This may be checked “yes” if the driver is applying for the CDL or the CLP-Commercial Learners permit, and they are medically qualified.  Class “D” is a regular non-commercial driver’s license, and should be checked “no”


Here is a general description of the types of commercial driver’s licenses:

Types of Commercial Driver’s Licenses

Class A includes

  • Tractor trailers
  • Any truck and trailer combination with a gross combined weight rating (GCWR) of 26,001 or more pounds – provided that the gross vehicle weight rating (GVWR) of the vehicle being towed is more than 10,000 pounds
  • Any vehicle in B, C or D categories, if you have qualified for the proper extra endorsements


Class B includes

  • Any vehicle with a GVWR of 26,001 or more pounds
  • A vehicle with a GVWR of 26,001 or more pounds towing a trailer with a GVWR of less than 10,000 pounds
  • A bus with a GVWR of 26,001 or more pounds designed to transport 16 or more passengers (including driver)
  • Vehicles in Class C and D categories – provided you have qualified for the proper extra endorsements


Class C includes

  • Any vehicle with a GVWR of less than 26,001 pounds used to transport hazardous material (with mandatory placard)
  • Any bus designed to carry 16 or more passengers (including the driver) and with a GVWR of less than 26,001 pounds
  • School vehicles designed for 15 passengers or less (including the driver)
  • Any bus or vehicle used for hire and designed to transport eight to 15 passengers (including the driver)

DOT Examiners: Still have questions about the new DOT Commercial Driver Exam form and Certificate, Determination Pending and the 45 day rule?