Are You DOT Regulated? One Neat Trick from Loss Control

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Stop! In the Name of the Law . . .

You are driving your work truck down the road, pulling a trailer, when flashing emergency lights appear in the mirrors. You pull over to let the police car pass, but lo and behold, the police car pulls behind you. You are puzzled because you know your equipment and driving habits are good.

You might be a contractor, builder, racer, have a masonry or landscaping business. There might not be a trailer, if you are a welder, or operate a service truck,

You’ve never had a problem before. But this time it’s different. Perhaps your work took you across the state line (interstate commerce). Perhaps you passed a weigh station. Perhaps you drove on an interstate highway.

And you’re getting cited. Perhaps it’s a warning ticket or even a $100 fine.

What did you do? You have been ticketed for failure to register for, and to display U.S. DOT Numbers.

When did that start?

Oh — about thirty years ago, says the officer.

It Doesn’t End There . . .

If you’re lucky, you won’t be cited for not carrying a DOT medical certificate, not having an annual (periodic) inspection on your vehicle (truck and trailer), and not keeping a Record of Duty Status (RODS) or an exemption sheet.

Once you register for a U.S.DOT number, there are some record-keeping requirements that go along with it. Not having a DOT number is not a legitimate or legal excuse for failure to follow these requirements.

How Do I Know . . .

“If you have a truck or trailer with company signs, and/or a trailer with more than one axle, I will be writing you a ticket if you do not have a U.S. DOT number.” DPS Officer

The rules for interstate commerce (movement of goods or people between state or national lines) seem fairly straightforward . . .

You need a U.S. DOT number if you operate in interstate commerce and:

• Operate vehicles that are over 10,000 lbs,
• Transport between 9 and 15 passengers (including the driver) for compensation,
• Transport 16 or more passengers, or
• Haul hazardous materials.

A continuation of an interstate trip is also considered interstate commerce. Examples would include: picking up passengers from another state at an airport, moving product from a dock that came from another state or country, or making the final delivery of a partial load that has crossed the state lines.

If you do any of these things, the above rules would apply, even if your vehicle does not cross state lines.

Do I need a U.S. DOT number if I operate in Intrastate Commerce?

Most states follow the federal guidelines for interstate commerce. If your vehicle is rated at 10,001 pounds or more, you haul people or hazmat, then you need a DOT number.

A number of states, however, follow their own guidelines and use a 26,001 GVWR threshold as the definition of a Commercial Motor Vehicle. Some states may use a lessor weight as 18,001 pounds GVWR.

From personal experience, asking your state DOT or motor carrier enforcement for this information is generally difficult. The people with the exact knowledge are most likely in the field, not sitting by the phone waiting for your call.

Another information source is a state trade or professional association. They may have a knowledgeable compliance person on staff, depending on the size of the association.

The quickest and perhaps most reliable method to determine state DOT requirements is to go directly to your state code, via a Google search. Search for your state’s definition of a commercial motor vehicle (CMV).

Ex: “Colorado CMV definition” or “CO code CMV definition”

Several searches should narrow down your state’s exact definition of a CMV. Once you know your state’s definition of a CMV, you will know what state rules you need to follow.

Thank you for reading this.