Avoid an Inactive DOT Number Status or DOT Fine

Inactive DOT Number

An alert in red on the SAFER Safety and Fitness Electronic Records (SAFER) System

Don’t Get Deactivated

If you or your company have a U.S. DOT Number, your Operating Status will be classified in one of five categories:

  • OUT-OF-SERVICE
  • Inactive USDOT Number
  • AUTHORIZED FOR { Passenger, Property, HHG }:
  • NOT AUTHORIZED
  • ACTIVE

Out-Of-Service or OOS means the operation has no standing to operate due to bad safety performance or a failure to pay a fine. Continued operation is not permitted.

An Inactive USDOT Number status means the number has been suspended or deactivated. Continued operation is permitted, but you can be cited and fined. A deactivated USDOT number occurs when the underlying registration information has not been updated within a two-year period (called the Biennial Update requirement, under 49 CFR 390.19(b)(2) and (4)) or not updated in the correct update period/month per according to the schedule set forth in 49 CFR 390.19(b). See the following chart:

Chart per 49 CFR 390.19(b).

(See our earlier blog on this.)

Under § 392.9b Prohibited transportation. (a) USDOT Registration required. A commercial motor vehicle providing transportation in interstate commerce must not be operated without a USDOT Registration and an active USDOT Number.

(b) Penalties. If it is determined that the motor carrier responsible for the operation of such a vehicle is operating in violation of paragraph (a) of this section, it may be subject to penalties in accordance with 49 U.S.C. 521.  (Effective November 1, 2013)

A deactivated USDOT number, for those in interstate commerce, can result in roadside citations and fines, but not (at this time), being put Out Of Service (OOS).

At a later DOT audit or investigation, your company can be fined $1,000 per day, up to $10,000.

Tip: Check your status at the DOT’s SAFER Safety and Fitness Electronic Records (SAFER) System webpage: www.safersys.org (click on Snapshot and put in your DOT number). Update the registration information (at the same link), if your DOT Number is Inactive or deactivated, by clicking on: FMCSA Registration & Updates).

You may call the DOT toll-free for help at 1-800-832-5660.

 

Biennial Update: MCS-150 Registration Renewal

Biennial Update Notice

On October 2, 2013, the Federal Motor Carrier Safety Administration (FMCSA) — an agency of the United States Department of Transportation — distributed an email message to motor carriers encouraging them to update their registration, including the following:

“Failure to complete a Biennial Update may result in deactivation of your USDOT number and civil penalties of up to $1,000 per day, not to exceed $10,000.”

What is the DOT “registration?”

Registration refers to the process of obtaining (and maintaining) a United States Department of Transportation (USDOT) number (the number on both sides of most trucks and buses in North America).  The purpose of the USDOT number is to mark and track trucks for safety. The requirements for DOT registration are found in 49 CFR 390.19

After the initial DOT registration, a motor carrier needs to update the registration information every two years.

Note: If there is a change in your fleet in the number of power units — tractors or straight trucks — before the two year period, then the motor carrier should update the information immediately. Don’t wait for the statutory two-year period. The number of power units affects your CSA scores, so keep it current.

Some states may require annual registration renewal at the time of license plate renewal.

How is the registration updated?

The recommended way is online. Alternatively, paper forms may be sent to:

Mail Forms to:
U.S. Department of Transportation
Federal Motor Carrier Safety Administration
Attention: Office of Registration and Safety Information
1200 New Jersey Avenue, S.E.
Washington, DC 20590

If you renew online, you will need your personal identification number (PIN) and you may need a credit card — for identification purposes (there is no charge or fee for a DOT number or to renew/update a DOT number).

Carriers need to complete the Motor Carrier Identification Report (Federal Form MCS-150) or, if a hazardous materials (hazmat) carrier, the Combined Identification and Hazardous Materials Safety Permit Application (Federal Form MCS-150B).

After a carrier begins operations it needs to update at least every 24 months, according to the following due-date schedule:

If your USDOT number ends in:   You need to file by last day of:

1                              January
2                             February
3                             March
4                             April
5                             May
6                             June
7                             July
8                             August
9                             September
0                             October

 

If the next-to-last digit of its USDOT Number is odd, the motor carrier or intermodal equipment provider shall file its update in every odd-numbered calendar year.

 

If the next-to-last digit of the USDOT Number is even, the motor carrier or intermodal equipment provider shall file its update in every even-numbered calendar year.

 

Always be sure to update according to the above due-date schedule.

Intermodal Equipment Providers (IEPs)

Intermodal Equipment Providers are unable to update online at this time and need to mail in the Intermodal Equipment Provider Identification Report form (Federal Form MCS-150C). Be sure to go online and double-check your information for accuracy in about four to six weeks.

Registration Pitfalls, Traps and Minefields

(1) If you mail in the form(s):

Important note for hard copy registrations: Forms must be received by FMCSA on or before the date your Biennial Update is due to avoid deactivation of your USDOT number and the assessment of civil penalties. Please allow ample time for mailing.

(2) Always update any operational changes:

  • In the number of active power units;
  • In carrier status: interstate to intrastate or the reverse;
  • In business/operations status: if no longer in business, file a final report.

(3) Always file even if no changes have occurred, but within the provisions and requirements of the due-date chart above.

How can I check my registration date status?

You can follow these easy steps to check your Official US DOT number to see if you need to update your Biennial Report:

If the MCS-150 Form Date is more than two years old, you should immediately update your information. Do not expect any further notice from the DOT.

The renewal process should not take more than 30 minutes, if all of the information is available. When done, a printable confirmation page will indicate that the update has been made. It is a best practice to keep a copy of any confirmations for your records.

November 1, 2013 was the compliance date for the biennial update requirements.

Are you in compliance?

CSA Effects

As the total number of power units and/or mileage are used in the CSA enforcement program, accurate information is necessary for precise calculations of your CSA scores. Inaccurate or stale data may impact your CSA Behavior Analysis and Safety Improvement Categories (BASICs) in a negative manner.

Summary

Renew and update your US DOT registration in a timely manner. Be aware of the changes that require an immediate update. Always be sure to update according to the above due-date schedule.

 

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