Question 1: May a State use the residence address as opposed to the mailing address on the CDL?

Guidance: Yes.

Question 2: May a State issue temporary nonphoto CDLs?

Guidance: Yes, as long as:

a. The State does not liberalize any existing procedures for issuing nonphoto licenses; and

b. The State does not allow drivers to operate CMVs indefinitely without a CDL which meets all the standards of §383.153.

Question 3: May a State choose to implement a driver license system involving multiple part license documents?

Guidance: Yes. A two or more part document, as currently used in some States, is acceptable, provided:

a. All of the documents must be present to constitute a ‘‘license;’’

b. Each document is explicitly ‘‘tied’’ to the other document(s), and to a single driver’s record. Each document must indicate that the driver is licensed as a CMV driver, if that is the case; and

c. The multipart license document includes all of the data elements specified in part 383, subpart J.

Question 4: If the State restricts the CDL driving privilege, must that restriction be shown on the license?

Guidance: Yes.

Question 5: Is a State required to show the driver’s SSN on the CDL?

Guidance: No. §383.153 does not specify the SSN as a required element of the CDL document although the regulation does require a driver applicant who is domiciled in the U.S. to provide his or her SSN on the CDL application.

Question 6: Is a State prohibited from issuing a CDL to an applicant who, for religious reasons, does not possess an SSN?

Guidance: No. The determination of whether a peson needs an SSN is left up to the Social Security Administration.

Question 7: Is a color-digitized image of a driver acceptable for purposes of a CDL?

Guidance: Yes. The FHWA will accept a color-digitized image of a driver on a CDL in lieu of a color photograph.

*Question 8: May a State issue a commercial driver’s license (CDL) without a color photograph?

Guidance: Yes, if requiring a photograph (whether in color or black and white) would violate a driver’s religious beliefs. The issuing State must determine whether a driver’s objection to a photograph has a genuine religious basis. In addition, §383.3(e)(1)(iii) and authorizes Alaska to dispense with a photograph on its CDL.

*Editor’s Note: This interpretation was issued after the interpretations were published in the Federal Register in April 1997.