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Our drivers undergo DOT medical exams, why should we have them undergo a Post-Offer Physical Abilities Test?

Quin Bond, CEAS IIILeave a comment

This is a question that we have heard over the years from companies that require a Commercial Drivers License (CDL) for employees in certain job titles – whether they are bus/transport vehicle drivers or public works employees. For many positions that involve driving certain classes of vehicles, the state or federal government require a driver to have a CDL. One component of obtaining and maintaining a CDL is undergoing a DOT medical examination with a DOT certified provider.

The main purpose of a DOT medical examination as part of obtaining/maintaining a CDL is to ensure that a driver is medically safe to operate the vehicles within the classification of their license.  Priority areas of a DOT medical exam include assessments of vision, hearing, blood pressure, cardiovascular health history, metabolic health history (ex. diabetes), and an overall physical assessment. An assessment of the upper and lower extremities checks for muscle weakness or loss of limbs. While range of motion is addressed in a DOT medical examination, it is to determine whether the examinee has any potential range of motion issues that the DOT examiner may feel are detrimental to their ability to operate trucks and passenger buses.  While an employer may be sending a driver for an exam, the examiner is not evaluating based on specific job demands.

Concrete Mixer-Drivers have to be able to lower a ladder at the rear of the vehicle.

The DOT medical examination does not address specific range of motion issues related to ingress/egress for specific types of vehicles (how high is the first step and the grab handles), the range of motion required to operate controls on specific vehicles, or the strength and range of motion related requirements to perform employer specific tasks (loading/unloading products/materials, securing items, operating controls, moving hoses, pulling down ladders, etc.).  A job specific post-offer physical pre-employment evaluation (or depending upon the situation, Return To Work FCE or Fit For Duty FCE) can address the examinee’s ability to perform the essential minimum postural and physical demands of the position. Employers should have a customized job description that includes objective measurements of the essential minimum physical and postural demands of the job title. These measurements should be collected using the vehicles, equipment, and other items that are used by the employer and employees when performing their job.

Obtaining a DOT medical certification does not necessarily mean that a driver can meet the essential postural and physical demands of a customized job description.  Conversely, meeting the essential postural and physical demands of a customized job description does not mean that a driver will be able to successfully pass a DOT medical examination (a variety of medical conditions are automatic exclusions in DOT medical examinations or require physician approved waivers).

NJ Ergonomics can assist with the documentation of objective measurement of physical and postural demands of job tasks as well as generation of Post-Offer Pre-Employment physical abilities testing protocols that are based on the essential demands of a job title.

NTSB Recommends Annual Physical Performance Testing of School Bus Drivers

Quin Bond, CEAS III1 Comment

Yellow school bus. Vector illustrationShortly before the holidays, the NTSB offered a blog post that included recommendations for school bus operators as a result of the investigation into a December 2017 school bus accident in Oakland, Iowa.   The tragic accident took the lives of a school bus driver and a 16 year old student when the exhaust pipe of the bus was blocked by the side of a drainage ditch. While all of the bus exits – emergency non-emergency – were operational, the report suggests that the student and driver succumbed to smoke inhalation when the student may have been attempting to help get the bus driver off of the bus.

In November 2017, the driver had visited his doctor due to complaints of pain and stated that “he could walk if he used a cane or crutches, that he experienced pain that prevented his sitting for more than 30 minutes (or standing for more than 10 minutes), and that he was sleeping less than 4 hours a night.” The school bus driver had been scheduled for a lower back surgery that would have occurred just 2 days after the fatal bus accident due to complaints of chronic lower back pain with weakness of his right leg. 

The NTSB final report notes that the school district was aware of his physical disabilities and his scheduled surgery but did not remove him from service. In addition to his physical complaints, numerous complaints about his driving performance were provided to the school district previous to the event but not documented.  However, finding number 9 concludes:

“It is likely that the bus driver’s progressive chronic back disease, which caused severe chronic pain, impaired his ability to evacuate the school bus himself or to assist the passenger to evacuate.”

The report also notes that the school district did not follow the district’s own requirements defining physical abilities of school bus drivers including appropriate fit for duty clearance of a driver that was not able to perform the required safety duties of the position.

Finding number 10 states:

“The use of physical performance tests on both a routine and as-needed basis can help identify physically unfit drivers who have a valid medical certificate but who might not be able to perform required safety duties, especially in an emergency.”

It is important to remember that a valid medical certificate does not necessarily indicate that the holder can perform the essential postural and physical demands of a specific position. The valid medical certificate only indicates that the holder meets the 4 non-discretionary standards (vision, hearing, epilepsy, diabetes mellitus) and 9 discretionary standards (hypertension, cardiovascular disease, respiratory function, loss of limb, limb impairment, neuromusculoskeletal dysfunction, mental disorders, drug use, and alcoholism) as outlined in 49 CFR 391.41.   The valid medical certificate indicates that a physician has determined them to meet the 13 standards but does not include a functional abilities test based on the essential minimum postural and physical demands of a position based on validated measurements of the required tasks.

Finding number 10 provides the basis for the following recommendation, which is directed to 44 states including New Jersey, made in the report:

“Revise your school bus driver requirements so that all drivers must pass a physical performance test on hiring and at least annually, and also whenever a driver’s physical condition changes in a manner that could affect his or her ability to physically perform school bus driver duties, including helping passengers evacuate a bus in an emergency.” (Emphasis mine)

School bus drivers perform a variety of tasks, in addition to driving the bus, that have specific postural and physical requirements, including:

  • Range of motion/strength to enter/exit the bus from the front side entrance, rear exit, or the wheel chair entrance.
  • Check roof top emergency exits (reaching to 72+ inches and applying vertical pushing and pulling forces) as part of the daily pre-drive inspection.
  • Maneuvering and securing (bending, kneeling, reaching) of wheelchairs when driving students who utilize wheelchairs.
  • The ability to bend/kneel to check under seats as well as view underneath bus.
  • The physical ability to provide assistance in seating/securing (seatbelts) for special needs students in the event that a bus aide is not provided for this task.
  • The physical ability to help move a physically incapacitated passenger from the bus in the event that the passenger needs to be moved to safety prior to the arrival of trained first responders.

Many states, including New Jersey, suffer from a shortage of school bus drivers. However, the NTSB report states:

“The NTSB is also aware that many medically certified school bus drivers with safe driving records have physical limitations that could prevent them from passing a PPT. However, the consequences of a driver not being able to evacuate a school bus or assist passengers in an emergency cannot be ignored.” (emphasis mine)

Additional recommendations by the NTSB include:

  • Appropriate fire suppression systems in the engine compartment
  • Usage of 911 emergency buttons as opposed to radioing the transportation supervisor (The driver of the bus contacted the transportation supervisor by phone after the fire started rather than calling 911.  The call to 911 was not immediately placed by the transporation staff but by the student’s mother  after the family was notified.)
  • Making sure that students, teachers, and other district employees are trained in evacuating through all of the exits, including manually operated loading doors, in the event that a bus driver becomes incapacitated.