Current Physical Qualifications Standard for Medical Examiners: Respiratory Conditions – Obstructive Sleep Apnea

FMCSA’s physical qualifications standards prohibit CDL drivers from receiving a medical examiner’s certificate, or commonly called a DOT medical card to operate commercial motor vehicles in interstate commerce if they have an “established medical history or clinical diagnosis of a respiratory dysfunction likely to interfere with his or her ability to control and drive a commercial motor vehicle safely.” (49 CFR 391.41(b)(5)).

Obstructive Sleep Apnea (OSA) is a serious sleep disorder in which breathing repeatedly stops and starts during sleep. Because of the severity of the case, OSA is considered a respiratory dysfunction that it is likely to interfere with the driver’s ability to operate safely.

FMCSA’s Advisory Criteria For Medical Examiners (Unchanged Since 2000)

If the medical examiner detects a respiratory dysfunction, that in any way is likely to interfere with the driver’s ability to safely control and drive a commercial motor vehicle, the driver must be referred to a specialist for further evaluation and therapy. A lot of conditions prevent oxygen exchange and may result in incapacitation, including chronic asthma, sleep apnea, emphysema, carcinoma, chronic bronchitis, and tuberculosis.

This advisory criterion is helpful to medical examiners when the examiner has enough experience or information to recognize certain risk factors for OSA, or when a driver tells the examiner that he or she has been diagnosed with OSA. Under these circumstances, the medical examiner should consider referring the driver to a specialist for evaluation before issuing a DOT medical card, or request additional information from the driver and his or her treating healthcare professional about the management of the driver’s OSA.

Role of Medical Examiners’ Clinical Judgment in the Medical Certification Process

FMCSA relies on medical examiners to make driver qualification decisions based on their clinical observations, findings and standards of practice. Medical examiners should rely upon their medical training and expertise in determining whether a driver exhibits symptoms and/or multiple risk factors for OSA. They should clearly explain to drivers the basis for their decision if they decide to issue a medical certificate for a period of less than two years to allow for further evaluation, or to deny a driver the DOT medical card.

The Agency encourages medical examiners to consider the following in making the medical certification decision:

  • The primary safety goal regarding OSA is to identify drivers with moderate-to-severe OSA to ensure these drivers are managing their condition to reduce to the greatest extent practical the risk of drowsy driving. Moderate-to-severe OSA is defined by an apnea-hypopnea index (AHI)1 of greater than or equal to 15.
  • The Agency does not require that these drivers be considered unfit to continue their driving careers; only that the medical examiner make a determination whether they need to be evaluated and, if warranted, demonstrate they are managing their OSA to reduce the risk of drowsy driving.
  • Screening: Symptoms such as loud snoring, sleepiness during the major wake periods, or witnessed apneas. Medical examiners should consider multiple risk factors such as body mass index (BMI), neck size, involvement in a single-vehicle crash, etc.
  • Diagnosis: Methods of diagnosis include in-laboratory polysomnography, at-home polysomnography, or other limited channel ambulatory testing devices which ensure chain of custody.
  • Treatment: Drivers with moderate-to-severe OSA can manage the condition effectively to reduce the risk of drowsy driving. Treatment options range from weight loss to dental appliances to Continuous Positive Airway Pressure (CPAP) therapy, and combinations of these treatments. FMCSA believes the issue of treatment is best left to the treating healthcare professional and the driver.

Contact us at 925-275-9350 or visit one of our testing centers:

San Ramon Occupational Center (Main Office)
1081 Market Place, Suite 100
San Ramon, CA 94583
Phone: 925-275-9350

Fremont Occupational Testing (by appointment only)
556 Mowry Ave, Suite 102
Fremont, CA 94536
Phone: 510-742-9143

1 AHI = (apneas + hypopneas)/hours of sleep. Apnea is a term for the involuntary suspension of breathing during sleep. During an apnea there is no movement of the respiratory muscles and the volume of air in the lungs initially remains unchanged. Hypopnea is a term for a disorder which involves episodes of overly shallow breathing or an abnormally low respiratory rate. This differs from apnea in that there remains some flow of air. Hypopnea events may happen while asleep or while awake.

View the full bulletin – FMCSA Bulletin to Medical Examiners and Training Organizations Regarding Obstructive Sleep Apnea

For more information and or to schedule an examination, please contact us at East Bay Occupational Testing / San Ramon Occupational Center at 925-275-9350.

Serving and providing testing and evaluations for DOT and commercial drivers for San Ramon, Danville, Pleasanton, Tracy, Livermore, Alamo, Walnut Creek, Fremont, Lathrop, Stockton, Oakland, Concord, Antioch, Brentwood, and surrounding areas.