Motor Vehicle Safety Program: Fleet Safety, DOT Medical Cards, and Distracted Driving Policy

Motor vehicle crashes kill more workers every year than any other single hazard. The Bureau of Labor Statistics Census of Fatal Occupational Injuries shows that transportation incidents have been the leading cause of occupational fatalities for over two decades. In 2023, transportation incidents accounted for 38% of all work-related deaths. That’s not a narrow category. It includes highway crashes, workers struck by vehicles, and off-road incidents, but the largest share is crashes involving workers who drive as part of their job.

If your employees drive, you have a motor vehicle safety obligation. And most employers don’t manage it seriously until there’s a fatality.

OSHA and the General Duty Clause

OSHA doesn’t have a dedicated standard for motor vehicle safety the way it does for fall protection or lockout/tagout. That creates a false sense that driving falls outside OSHA’s reach. It doesn’t.

OSHA can cite employers under the General Duty Clause, Section 5(a)(1) of the OSH Act, when employees are required to drive as part of their job and the employer has failed to address recognized hazards. The elements for a General Duty Clause citation are: a recognized hazard exists, the hazard is likely to cause serious harm or death, the employer didn’t address it, and a feasible means of abatement exists. Motor vehicle crashes check all four boxes.

FMCSA regulations are a separate layer. If your operation involves commercial motor vehicles in interstate commerce, you’re looking at a regulatory framework that includes driver qualifications, hours of service, vehicle inspection requirements, and drug and alcohol testing. Those are in addition to what OSHA may require, not instead of it.

For employers who don’t operate commercial vehicles under FMCSA but still have workers driving company vehicles or personal vehicles for work purposes, the General Duty Clause is the enforcement hook. Build your program accordingly.

Building a Fleet Safety Program

A motor vehicle safety program is not a single policy document. It’s a system with multiple components that have to work together.

Driver qualification is the starting point. Before anyone drives on company business, you need a baseline. That means a motor vehicle record check at hiring and at defined intervals afterward. An MVR tells you about license status, suspensions, DUI history, and past violations. Some insurers require MVR checks as a condition of commercial auto coverage. Do them before the first day of driving, not six months in.

Set clear criteria for acceptable driving records. Define what disqualifies a driver from operating company vehicles. Two DUIs in the past three years? A license suspension in the past year? Put the criteria in writing. Applying them consistently protects you from discrimination claims and makes the program defensible if you ever terminate a driver for record issues.

Vehicle inspection is the second pillar. Pre-trip inspections catch mechanical problems before they become crash causes. This doesn’t need to be a CDL-style inspection for every sedan in the fleet, but it does need to be systematic. A basic checklist covering tires, brakes, lights, mirrors, fluids, and safety equipment takes five minutes. If a driver finds a problem, there has to be a clear process for reporting it and getting the vehicle out of service until it’s fixed.

Incident reporting ties the program together. Every crash, every near-miss, and every moving violation that occurs during work hours should be reported and reviewed. The incident investigation process applies here. You’re looking for root causes, not just driver error. Was the route unrealistic? Did the schedule pressure a driver to rush? Were roads icy and the driver lacked guidance on when to pull over? Those are program failures, not just individual failures.

DOT Medical Certificate Requirements

For commercial motor vehicle drivers covered by FMCSA regulations, the medical certificate requirement is non-negotiable. Drivers who operate CMVs in interstate commerce must pass a physical exam conducted by an FMCSA-registered medical examiner and carry a valid Medical Examiner’s Certificate, also called a DOT medical card.

The CMV threshold for medical requirements is a GVWR over 10,001 pounds, vehicles transporting 9 or more passengers for compensation, or vehicles transporting hazardous materials in quantities requiring placards.

Medical certificates are valid for up to 24 months. Some conditions require more frequent recertification. Drivers with controlled hypertension, insulin-treated diabetes (with a federal exemption), or certain cardiac conditions may be certified for one year or less. The medical examiner makes that determination, not the employer.

Employers are responsible for verifying that CDL drivers maintain a current medical certificate. If a driver’s certificate expires or is revoked, they can’t operate a CMV. Your driver qualification file needs to include a copy of the current certificate and a process for tracking expiration dates.

Intrastate commercial drivers, those who don’t cross state lines, are subject to state-level rules. Most states have adopted requirements that mirror the federal standard, but you need to verify the rules in your specific state, especially if you operate in a state with its own OSHA plan.

Distracted Driving Policy

This is where most employer programs are weakest. Phone use while driving is the most common unaddressed hazard in fleet safety.

NHTSA data consistently shows that hand-held phone use significantly increases crash risk. The research on hands-free calling is less clear in terms of crash outcomes, but it’s well-established that cognitive distraction from conversation persists even when hands are on the wheel. Some states ban hand-held use but permit hands-free. That’s a legal minimum, not a safety standard.

The most defensible employer policy bans all phone use while driving, hands-free included. That’s not realistic for every operation, and you’ll get pushback. But the liability exposure when an employee causes a crash while on a work call is significant. If you can’t get buy-in for a full hands-free ban, you need at minimum a strict policy against hand-held use, clear procedures for pulling over before making or taking calls, and regular enforcement.

Employer-issued phones create direct liability. If an employee causes a crash while using an employer-issued phone for work calls, the employer is exposed. Make the policy explicit in writing, train everyone on it, and include it in your new employee safety orientation so new hires understand it before they ever take the wheel on company business.

Texting while driving is categorically different from calling. It’s banned by federal regulation for CMV drivers. For non-CDL employees, it’s a General Duty Clause hazard with strong enforcement risk. No policy that permits texting while driving is defensible.

Fatigue Management

Fatigue is a driving hazard that most non-transportation employers ignore until someone drives off the road on the way home from a long shift. FMCSA hours-of-service rules handle fatigue management for CDL drivers in commercial operations. For everyone else, it’s on you.

Night shift workers, workers coming off extended shifts, and workers traveling across time zones for work are all at elevated crash risk. A fatigue policy for drivers doesn’t need to be complicated. Set a maximum number of driving hours per day for company business. Define what happens when a worker is too tired to drive safely, including hotel authorization if needed. Make it clear that driving fatigued is a safety violation, not just a personal risk.

Combining this with your drug testing program matters too. Many fatigue-related crashes involve prescription medications that impair driving. Your policy should address prescription drug use that affects driving, not just illegal substances.

Personal Vehicles on Company Business

Here’s where many programs have a serious gap. If your employees use their own cars for work, company auto liability coverage typically doesn’t apply. Employees need their own commercial-use coverage, or your business needs a non-owned auto endorsement on its commercial policy.

More importantly, personal vehicle use for work doesn’t put those drivers outside your safety program. If an employee runs a red light in their personal car while driving to a client meeting and kills someone, your business has exposure. The safety requirements, phone policy, and MVR check expectations should apply to any driving done on company business regardless of which vehicle is used.

Spell this out explicitly in your fleet safety policy. Personal vehicles used for work business fall under the same behavioral requirements as company vehicles. Most employees don’t know this, and most employers haven’t thought it through.

Putting the Program Together

A motor vehicle safety program that works has written policies, consistent enforcement, and regular review. Use a job hazard analysis for high-exposure driving tasks to identify specific hazards, like backing in tight lots, driving on rural highways at night, or navigating construction zones, and document controls for each.

Review crash data quarterly. Look for patterns. If three crashes happen in the same intersection, that’s a route hazard. If four of your last six crashes involved backing, that’s a training and equipment issue.

The program isn’t set-it-and-forget-it. Driving conditions, routes, schedules, and vehicle types change. Your program has to keep up.