Violation code

391.11B2-Z

Border Zone - Driver cannot satisfy the English language proficiency requirements of 391.11(b)(2) as per FMCSA Enforcement Guidance Memo MC-SEE-2025-0001.

Driver Fitness4Non-OOS· SMS Appendix A v3.20

391.11B2-Z is a General Driver Qualification violation under 49 CFR §391.11B2-Z. It falls in the Driver Fitness BASIC with a severity weight of 4/10. Nationally it was cited 48,988 times in the last five years, with an OOS rate of 0.3%.

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National roadside inspection stats

as of 6/20/2026

Inspections

48,921

that found this code

Violations

48,988

total written

OOS rate

0.3%

132 OOS

Source: FMCSA roadside inspection data (last 5 years). The OOS rate is the share of these violations that led the officer to mark the driver or vehicle out of service.

Violation group: General Driver Qualification
Regulation §: 391.11B2-Z
Severity weight: 4
Used in SMS: Yes
Status: Active
Updated: 6/20/2026

Last updated June 2026

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Notes

DSMS: Y | Comment: Added in 3.20 | Footnote: This violation was added to SMS with the July 25, 2025 snapshot.

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Challenging 391.11B2-Z through FMCSA DataQs

If this violation was written incorrectly, here are the angles trucking-safety managers use to contest it. Playbook: Driver Fitness.

Common ways to challenge this code

Medical certificate was valid and on file
A valid medical examiner's certificate was in the driver's qualification file and was either not produced at roadside or not properly recognized.
Evidence that wins
- ✓Copy of the valid medical examiner's certificate
- ✓Driver qualification file index
- ✓National Registry verification printout
CDL class / endorsement was correct for the operation
The driver's CDL class and endorsements were correct for the vehicle and cargo being operated.
Evidence that wins
- ✓Copy of the valid CDL with endorsements
- ✓Vehicle registration showing GVWR/configuration
- ✓Bill of lading or shipping papers showing cargo

Common pitfalls — avoid these

⚠A medical certificate that expired the DAY of inspection still fails — there is no grace period

⚡ Draft a challenge for 391.11B2-Z →Read the DataQs guide first

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Frequently asked questions about 391.11B2-Z

What does violation 391.11B2-Z mean?

391.11B2-Z is the FMCSA roadside-inspection violation code for "Border Zone - Driver cannot satisfy the English language proficiency requirements of 391.11(b)(2) as per FMCSA Enforcement Guidance Memo MC-SEE-2025-0001.", part of the General Driver Qualification group, cited under 49 CFR §391.11B2-Z.

What BASIC does 391.11B2-Z affect?

391.11B2-Z falls under the Driver Fitness BASIC in the FMCSA Safety Measurement System (SMS).

What is the CSA severity weight of 391.11B2-Z?

391.11B2-Z carries a severity weight of 4 out of 10. Higher weights indicate violations more closely tied to crash risk, and they count more toward a carrier's Driver Fitness score.

Is 391.11B2-Z an out-of-service (OOS) violation?

No. 391.11B2-Z is not an out-of-service violation, so on its own it does not trigger an out-of-service order at the roadside.

How many CSA points does 391.11B2-Z add to a carrier's score?

The point contribution of 391.11B2-Z depends on its severity weight (4/10) multiplied by a time weight of 3, 2, or 1 based on how recent the inspection is. You can calculate the exact contribution with the CSA points calculator.

Can 391.11B2-Z be challenged through DataQs?

Yes. If you believe 391.11B2-Z was recorded in error, you can file a Request for Data Review (RDR) through the FMCSA DataQs system with supporting evidence. A successful challenge can remove or correct the violation on your record.

Keep going

CSA points calculator How to challenge a violation Draft a DataQs letter for 391.11B2-Z Driver Fitness BASIC Carrier CSA lookup CSA glossary