Commercial Driver Medical Examination| Rules and Regulations

Skill Performance Evaluation 49 CFR 391.49

Skill Performance Evaluation (SPE)


The Skill Performance Evaluation, like other evaluations performed on drivers applying for an exemption or relief from the regulatory standards, requires the input of certain medical specialists.   In the case of the Federal Vision Exemption Program, this input is required from either an optometrist or opthalmologist, depending on whether or not there is retinopathy.  That same requirement applies to insulin treated diabetes mellitus, in addition to the endocrinologist evaluation.   In the case of the SPE, an evaluation from either a board certified physiatrist (Physical Medicine and Rehabilitation Specialist) or orthopedist is required.

What is the role of the medical examiner in all of this?  Just like in the other exemption applications, a medical examiner must first assess the driver in the usual way and find that the driver is qualified to drive, except for the condition that the driver is seeking regulatory relief from.  According to the Medical Examiner Handbook:

As a medical examiner, you determine if the severity of a fixed deficit that is less than the whole hand is medically disqualifying unless the driver has an SPE certificate pursuant to 49 CFR 391.49. The SPE is applicable only for fixed deficits of the extremities.

The Guidance/Advisory Criteria  for certification of the driver with fixed deficit of an extremity is listed in the Handbook.

The medical examiner will then check the proper boxes on both the Medical Examination Report Form and the medical examiner’s certificate that says “accompanied by a SPE certificate”.  The SPE certificate is applicable only for fixed deformities of the extremities and is not applicable to neck or torso deformities.  As usual, the journey for the driver always starts with the medical examiner, whether it’s for an exemption from the vision, or insulin treated diabetes standards or a Skill Performance Evaluation (formerly called a “limb waiver” until  May of 2000).

Physical demands of commercial driving


Unlike driving an automobile, greater demand is placed on the commercial driver and varies by type of vehicle (straight truck v.s. tractor-trailer), route driven (i.e. short relay of 4-5 hrs v.s. long relay 8-10 hrs or local deliveries with frequent stops), and weather and other environmental factors that affect rest, sleep cycle, sleep deprivation, and eating habits.  Overall strength, mobility, coordination and stability of both the extremities and torso is required to properly operate a commercial motor vehicle – whether to turn a 20-24 inches steering wheel, work the gear shift or brake controls, to maneuver in and around the vehicle (climb, bend, crawl etc during vehicle inspection), or the ability to maintain effective body posture for prolonged sitting while driving and simultaneously operating both hand and foot controls. Heavier tasks involve cargo handling, coupling and uncoupling the tractor-trailer, changing tires and mounting or removing snow chains on tires.  More moderate tasks involve maneuvering and operating the various switches, lights and wipers within the cabin.  Good perceptual skills is required for the driver to properly assess and monitor his vehicle and environment to safely execute his job.

SPE and Instructions to the specialist 

artificial limbs under the white background

Commercial drivers with limb impairment or amputation will have the Medical Evaluation Summary (SPE_Medical Evaluation Summarycompleted by either a board certified or eligible physiatrist or orthopedic surgeon.  This is an 8 page form within the SPE certificate package.  It contains instructions to the specialist examiner to comment on the type of disability the driver presents with (limb impairment or amputation), with background information on job description, physical demands, as well as factors affecting commercial driving such as vehicle type and environmental factors.  In amputation, an assessment is made regarding the driver’s physical capabilities and his ability to do the tasks of his job.  In limb impairments the examiner (orthopedist or physiatrist) is to assess whether the condition will remain stable over time, as well as how the impairment will affect the driver’s ability to do his job.  When the impairment or amputation involves the upper extremity, the specialist examiner should also include a statement that the driver is capable of demonstrating precision prehension (i.e manipulation of knobs and switches) and power grasp prehension (holding and maneuvering a steering wheel).   This has to be demonstrated with each upper limb separately.

As described above, the task of the physiatrist or orthopedic surgeon who is referred the driver with limb impairment or amputation is to precisely measure and assess the nature of the impairment or amputation and how it affects the driver’s ability to do his tasks.   If there is an orthosis or prosthesis being used, the specialist examiner must describe whether it’s the proper device type and components, properly fitting on the residual limb, and that the device is being used correctly and efficiently by the driver.  The device must also be in good working condition, and if it is an upper limb prosthesis, the examiner must assess that the device aids the driver in demonstrating power grasp and prehension.

The SPE Specialist and the road test

The information provided by the orthopedist or physiatrist will be important for the next step of the driver evaluation process.  A specially trained SPE Specialist will conduct skill performance evaluations of the driver on and off the road to see if the driver can overcome his or her handicap and safely operate the vehicle that they intend to drive.  The driver must pass a road test to receive the SPE Certificate.  This is performed at the four regional SPE Service Centers that service the Eastern, Midwestern, Southern, and Western parts of the U.S.   So far, more than 3,000 SPE Certificates have been issued.  The SPE certificate is valid for 2 years and may be renewed 30 days prior to the expiration date.  The SPE certificate is signed by the Division Administrator of the FMCSA.  As with any other waiver or exemption, the driver is responsible for maintaining and complying with the requirements of the SPE certificate. The driver must carry both a valid SPE certificate and medical examiner’s certificate when operating a commercial vehicle.

  • Randolph Rosarion M.D.
  • Board Certified Physical Medicine & Rehabilitation