CSA - Sample 5 Why's for Expired Medical Examiner's Certificate
Violation
A roadside inspection report for a motor carrier showed the following violation: 391.45(b) - Expired medical examiner’s certificate.
The motor carrier will want to find out the root cause of this Driver Fitness BASIC violation.
Question 1: Why did this event take place?
Answer: The driver’s medical certificate was 2 days expired.
Question 2: Why was the card expired?
Answer: The driver was not scheduled to be back home until the card was expired a number of days.
Question 3: Why did the scheduling conflict with the medical certificate’s expiration date?
Answer: Operations did not pay attention to the list of drivers with soon-to-expire medical certificates.
Question 4: Why didn’t dispatch check the list?
Answer: The dispatcher thought drivers had a grace card to renew the medical certificate.
Question 5: Why did the dispatcher believe this?
Answer: He was not trained or completely informed on the topic.
Possible Solutions
What might be some solution(s) based on the safety management cycle and the root cause(s)?
- Assign the role of monitoring medical examiner’s certificate expiration dates, issuing a reminder to the driver, and following up to ensure it has been completed.
- Assign the role of communicating with dispatch that the driver is unqualified unless he/she presents a valid medical examiner’s certificate prior to the run. If a dispatcher is aware that a driver is on the list of drivers with an expired or soon-to-expire medical examiner’s certificate, but is used anyway, enforce a policy that involves operations being held accountable in some way.
- Dispel myths about any grace period for the medical exam expiration dates. Do this during training that includes not only drivers but operations/dispatch. Use other communication such as posters, paycheck stuffers, and the like to explain the facts. Explain that drivers are unable to operate any CMV for you until a new valid certificate is presented.
- Compare records of duty status dates against any interim period when the driver’s medical card is expired. If the driver operated a CMV for you during this period, enforce your company driver qualification policy by disciplining the driver and anyone who knowingly allowed the driver to operate the CMV.
- Create a policy and procedures that no one is to be dispatched within 48 hours of a disqualification, such as medical certification and licensing. Enforce the policy.