US DOT Requirements for CMVs; Meeting Minimum FMCSR Safety Standards

There is a more current version of this article! Find an updated article about CMV regulations and DOT compliance here.

Do your CMVs require US DOT numbers?

“Yes,” says Steve Jansen, Donlen’s Manager of Regulatory Compliance and Truck Services, “You better if you have commercial motor vehicles (CMVs) that cross state lines.”

Here’s why: Regardless of their applications, if your CMVs are used in interstate commerce, as defined under Federal Motor Carrier Safety Administration (FMCSA) §390.5, they must display US DOT numbers. Period. No exceptions. This applies to non-freight carrying CMVs, such as repair and service vehicles, mobile cranes, as well as all freight-hauling vehicles. It also applies to any CMV that crosses state lines for repairs.

Remember, if it crosses state lines for any reason, even if rarely, it must display a US DOT number.

The gross vehicle weight rating (GVWR) of the vehicle, or gross combination weight rating of vehicles, is the other determining factor. If the combined total GVWR is 10,001 pounds or greater, it falls within the FMCSA’s definition of a CMV. Even a pickup truck pulling a trailer requires a US DOT number if it’s over the minimum combined weight limit.

If you need a US DOT number, you must contact the FMCSA and complete Form MCS-150, “Application for USDOT Number.” Transporting hazardous materials listed in §385.403, even if not for hire, requires Form MCS-150B, “Combined Motor Carrier Identification Report and HM Permit Application.”

When filling in these forms, you will need specific information about your company’s operation, number and types of vehicles operated, vehicle miles traveled, and number and type of drivers (interstate, intrastate, CDL, etc.). You also need your company’s legal name and any “doing business as” (DBA) names. If your company is a division of another company or corporation, one US DOT number must be used since divisions are fully integrated within a primary business and not legally or otherwise distinct from it. They generally operate under one Federal Employer Identification Number (FEIN).

Subsidiaries, on the other hand, are separate, distinct legal entities for the purposes of taxation and regulation. Because they have their own FEIN, they must also have their own US DOT number.

What if your CMVs never travel out of the state? In that case, they fall under intrastate operations and are subject to the identification rules of the state in which they operate but do not require US DOT registration. These rules vary from state to state, so be sure to check with your state’s department of transportation or other regulating authority to make sure you’re in compliance. A little precaution now can save a lot of trouble down the road.

Steve Jansen can be reached at 847-412-4961

Meet Minimum Standards or Manage Above the Regulations?

Reprinted with permission: RegSense, J.J.Keller & Associates, Inc.

The Federal Motor Carrier Safety Regulations (FMCSRs) are the minimum safety standards for motor carriers. These standards are set in such a manner that the carrier is compelled to structure their company with controls in place to prevent commercial vehicle accidents, injuries, and fatalities. The regulations do not tell carriers how to put theses (sic) controls in place or how to manage them. They simply expect the carriers to comply with the regulations.

To this end, each motor carrier must determine how close to, or how far above, the regulations they wish to manage their company. The controls they use to manage their safety program must be sufficient enough to satisfy any form of FMCSA investigation when the agency has a reason to inquire. These controls should be a part of company policy that is supported by processes that complies (sic) with the FMCSRs and take in the following areas:

  1. Commercial driver’s license requirements (Part 383)
  2. Financial responsibility (Part 387)
  3. Who is qualified to drive (Part 391), how they must drive (Part 392), and the condition of their vehicles and safety of their cargo (Part 393)
  4. Documenting accidents (Part 390)
  5. The use of fatigued drivers including the number of hours they can drive (Part 395)
  6. Inspection, repair, and maintenance of vehicles (Part 396)
  7. Transportation of Hazardous Materials including driving and parking rules (Part 397), and hazardous material regulations (Parts 170 through 177).

Whatever methods or controls the carrier may put in place to meet, or better yet, to exceed these minimal standards, there is no denying that when management structures their company with these controls in place, their chances of financial success improves considerably. After all, a qualified driver who is managed with the safety regulations being a significant part of the company’s culture will have fewer accidents, fewer violations, and deliver their freight on time, satisfying the customer and setting the stage for continued and repeated profits.

Driver’s Corner

Tailgate up or down? If you’re driving with your tailgate down on your pickup truck, you’re most likely wreaking havoc on your gas mileage. Not a good thing under normal circumstances, but in these times of sky-high gas prices, even worse! According to the MythBusters

guys who tested several different configurations, driving with your tailgate down is one of the worst things you can do when looking at fuel economy. So close it and help improve your MPG.

And Finally…

And finally, what is 70′ long, has 22 wheels, and weighs 26 tons? If you thought a run-of-the-mill semi truck, you’d be wrong. This one comes with a crew of five people, a bar, and can carry up to 40 passengers. Oh, and it’s in the Guinness Book of World Records as the heaviest limo in the world. The Midnight Rider may look similar to a semi truck on the outside, but inside, it’s anything but. So if you and 39 of your closest friends decide to take an excursion, be sure to send pics to FridayFleet!

Have a nice weekend. Safe travels.

Originally appeared in FridayFleet on March 30, 2012

About Donlen
A wholly owned subsidiary of The Hertz Corporation (NYSE:HTZ), Donlen (, with headquarters in Northbrook, IL, is the fleet industry’s most comprehensive and integrated provider of financing and asset management solutions. Since 1965, Donlen has offered its clients highly personalized and responsive customer service, and their workplace excellence has been recognized as one of Crain’s Chicago Business “List of 20 Best Places to Work in Chicago” each year from 2009-2011, a Leader on “The Global Outsourcing 100®” list by the International Association of Outsourcing Professionals (IAOP) for six of the last seven years, and a National Association for Business Resources “101 Best and Brightest Places to Work For in Chicago” each year from 2007-2012. Donlen’s innovation has been awarded with the Computerworld “2012 Honors Laureate for Economic Opportunity,” named to “2012 InformationWeek 500” for innovative technology; the Stevie® “2012 Gold Award for Business Intelligence Solution,” the Silver Award for “2012 Front Line Customer Service Team of the Year,” and the “2011 Corporate Environmental Responsibility Program of the Year.”