Understanding 49 CFR § 391.11 – General Qualifications of Drivers
When a driver does not have a valid operator’s license for the commercial motor vehicle (CMV) being operated, it is considered one of the most serious qualification violations under federal law. The rule is enforced by the Federal Motor Carrier Safety Administration (FMCSA) and is found in 49 CFR § 391.11.
This regulation establishes the minimum qualifications a driver must meet before operating a commercial motor vehicle in interstate commerce. Failing to meet these standards exposes both the driver and the motor carrier to significant penalties.
For the official regulation, visit: https://www.ecfr.gov/current/title-49/section-391.11
What This FMCSA Violation Means
Under federal law, a person may not operate a CMV unless they are fully qualified. Just as important, a motor carrier may not require or permit a person to drive unless that individual meets all federal qualification requirements.
If a driver:
- Lacks a valid commercial driver’s license (CDL)
- Holds the wrong class or endorsement
- Is underage
- Is medically unqualified
- Is disqualified from driving
FMCSA considers the driver unqualified, and the carrier may be cited for permitting operation.
Minimum Age Requirement
Drivers must be at least 21 years old to operate a CMV in interstate commerce under 49 CFR § 391.11.
If a carrier allows a driver under 21 to operate in interstate commerce, it constitutes a qualification violation.
English Language Requirement
Federal regulations require drivers to read and speak English sufficiently to:
- Communicate with the public
- Understand highway traffic signs and signals
- Respond to official inquiries
- Complete reports and records
This ensures safe interaction with law enforcement and compliance personnel.
Training and Experience to Safely Operate the CMV
Drivers must have the training and experience necessary to safely operate the specific type of CMV they are driving.
A license alone is not enough. For example:
- Operating a vehicle requiring air brake knowledge
- Driving combination vehicles
- Transporting hazardous materials
Each requires specific skills and, in some cases, endorsements.
Physical Qualification Requirements
Drivers must meet medical standards outlined in Subpart E of Part 391.
They must:
- Pass a DOT medical examination
- Maintain a valid medical examiner’s certificate
- Meet federal health standards
Official requirements can be reviewed at: https://www.ecfr.gov/current/title-49/part-391/subpart-E
A driver who fails to meet physical standards is not qualified—even if they hold a valid CDL.
Valid Commercial Driver’s License Requirement
Drivers must hold a currently valid CDL issued by only one state. Holding multiple licenses is prohibited.
The CDL must match:
- The class of vehicle being operated
- Any required endorsements
- The operational scope of the vehicle
If a driver operates a CMV without the proper class or endorsement, the violation falls under 49 CFR § 391.11.
Learn more about federal CDL standards here: https://www.ecfr.gov/current/title-49/part-383
Driver Must Not Be Disqualified
Drivers disqualified under 49 CFR § 391.15 may not operate a CMV.
Disqualifications may result from:
- Serious traffic violations
- Alcohol or drug offenses
- Out-of-service violations
- Felony convictions involving a CMV
The regulation is available here: https://www.ecfr.gov/current/title-49/section-391.15
A suspended, revoked, or disqualified license automatically makes a driver unqualified.
Road Test Requirement (49 CFR § 391.31 and § 391.33)
Before operating a CMV, drivers must complete a road test and receive a certificate of completion under:
- 49 CFR § 391.31
- 49 CFR § 391.33
Official references:
https://www.ecfr.gov/current/title-49/section-391.31
https://www.ecfr.gov/current/title-49/section-391.33
FMCSA allows certain license credentials to substitute for a road test under specific conditions, but carriers must document compliance.
Why This Violation Is Serious
Allowing an unqualified driver to operate a CMV significantly increases crash risk and liability exposure.
Consequences may include:
- Roadside citations
- Civil penalties
- Out-of-service orders
- Negative CSA Safety Measurement System impacts
- Increased audit scrutiny
- Higher exposure in post-accident litigation
Because this violation directly impacts roadway safety, FMCSA enforcement is strict.
How FMCSA Identifies This Violation
FMCSA inspectors may uncover qualification violations during:
- Roadside inspections
- New entrant safety audits
- Compliance reviews
- Focused investigations
Inspectors verify:
- CDL class and endorsements
- Medical certification status
- Driver qualification files
- Disqualification history
If deficiencies are found, the violation is documented under 49 CFR § 391.11.
How Motor Carriers Can Prevent This Violation
To reduce risk and maintain compliance, carriers should:
- Verify CDL class and endorsements before dispatch
- Confirm medical certification status
- Conduct regular Motor Vehicle Record (MVR) checks
- Monitor driver disqualification status
- Maintain complete driver qualification files
- Confirm drivers meet age and experience standards
Proactive qualification verification protects the carrier, the driver, and the public.
Final Thoughts
Federal law under 49 CFR § 391.11 requires commercial motor vehicle drivers to meet clear qualification standards before driving.
Allowing a driver to operate a CMV without a valid operator’s license—or without meeting all qualification requirements—creates serious safety, regulatory, and financial risk.
Motor carriers that verify licenses, training, medical certification, and disqualification status before placing drivers on the road significantly reduce violations and strengthen overall safety compliance.