§383.23 requires every CMV driver to hold a current CDL of the proper class for the vehicle being operated. Three classes: A (combination ≥26,001 lb GVWR with towed unit >10,000 lb), B (single vehicle ≥26,001 lb), C (vehicles not in A or B but carrying placardable hazmat or 16+ passengers including the driver). Endorsements layer on top: H (hazmat), N (tank), P (passenger), S (school bus), T (doubles/triples), X (combination of H and N).
Audit auto-fail
§385.321(b)(6) lists "using a driver who does not possess a valid CDL" as an audit auto-fail. §385.321(b)(7) covers the disqualified-CDL case. A single finding can convert a passing audit to a fail.
Common findings
- Driver upgraded to a larger truck without upgrading the CDL class
- CDL expired (track in Roadworthy HQ — §383.23 expiration alert)
- Endorsements not held for the cargo (tank without N, hazmat without H)
- License downgraded to non-CDL by the state due to a medical certification lapse (§391.45/§391.41)
How to prevent it
- Match every vehicle assignment against the driver's CDL class and endorsements.
- Track CDL expiration with an alert at 90 / 60 / 30 / 7 days before expiry.
- Verify the driver's medical certification status is sync'd with the state — a lapsed med cert downgrades the CDL.
How Roadworthy HQ helps
The driver record stores CDL class, endorsements, expiration, and the medical-certification sync state. The dispatch surface blocks assignment when the driver's CDL class doesn't match the vehicle assignment. Expiration alerts route to the carrier owner well before the cliff.