OOSC, Part I, Item 3. Commercial Driver's License, a.(2) and Inspection Bulletin 2015-04 - Downgraded CDL

Part I: North American Standard Out of Service Criteria, Item 3: Commercial Driver's License (CDL), paragraph a. License, subparagraph (2), Operating a CDL-required commercial motor vehicle with driving privileges revoked, suspended, cancelled or otherwise disqualified. Inspection Bulletin 2015-04: Enforcement of Medical Examiner’s Certificate Integration with the Commercial Driver’s License does not provide clear guidance on citing CDL drivers downgraded due to medical status as the language used in the bulletin does not match the OOSC.

It is the opinion of this writer that the discrepancy between the wording of the OOSC and Inspection Bulletin causes unnecessary confusion for roadside inspectors when citing CDL drivers that have been downgraded due to medical status. The OOSC does not specify "downgraded" in subparagraph (2). Also, the inspection bulletin does not specify that a medical downgrade is a safety-related violation and advises inspectors to cite the most appropriate code as opposed to a specific code.

The request is to modify OOSC 3. (a)(2) to include the term "downgraded" as it is listed on the inspection bulletin. (2) Operating a CDL-required commercial motor vehicle with driving privileges downgraded, revoked, suspended, cancelled or otherwise disqualified. I also request that the fourth bullet under CDL Driver on Inspection Bulletin 2015-04 be modified to provide clear guidance on citing this violation. CDL is not valid (e.g. cancelled, downgraded, disqualified, revoked, suspended, etc.). Driver OOS, cite 383.51(a). This verbiage is my recommendation; however, similar wording could be considered. The intent of the change is to provide clear guidance to roadside inspectors on how to cite this violation and that the driver should be placed OOS as it is considered safety-related.