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.

 

Taking a wait-and-see attitude about DOT Compliance?

 

DOT Compliance with the Federal Motor Carrier Safety Regulations (FMCSRs), found in Title 49 of the Code of Federal Regulations(49 CFR), is not rocket science. It’s actually much harder because:

– compliance initiatives are competing with all the other things going on in the organization: customer demands, emergencies, weather changes, supplier failures and many more daily business challenges;

– the general complexity of the DOT laws, rules and regulations that seem overwhelming at first start;

–  some businesses simply will not comply until compliance enforcement actions are taken, according to several studies;

– time is lacking and resources are scarce or misappropriated for non-critical areas at the expense of critical areas.

The Cost

In the long-run taking the wait-and-see approach can be costly:

– Roadside fines can range from $100 to several thousand dollars, up to and including towing of the vehicle. In some instances the vehicle could remain impounded for a period of time;

– The driver may be personally ticketed, or even arrested;

– The DOT or State’s Motor Carrier Enforcement Division may conduct a what is called an “intervention” ranging from a phone call to a full-blown audit.

– Violations found during an audit may result in fines ranging from $1,000 for paperwork and documentation errors up to $11,000 or more for “egregious” (major) violations;

– Violations found lead to more inspections and inspections lead to audits;

– Your organization may be given a negative “CSA Score.”

Take Action

There’s an old saying, if you are not going anywhere, then any path will take you there. But that is not a very good business-like approach.

The DOT always checks critical areas in both roadside inspections and audits. Some areas are so critical to the DOT that they will result in an automatic Out-of-Service Order (OOS) or audit failure. I prefer to call these the Critical Success Factors (CSFs) and helping you succeed is what we are all about.

Don’t put the DOT off. Delay is a decision – for the wrong way. Avoid common mistakes and errors and the risk of citations and/or fines. Best of all, by taking action, by being proactive, you can avoid that feeling of panic and can remain in control and in change of the situation.