Register 3 dba’s Separately With the DOT?

US DOT Number

US DOT Registration / Truck Marking Rule

Does an owner (with a parent company and 3 subsidiaries), have to register 3 dba’s separately? Is that parent company supposed to register as a parent with a dba separately for each dba? And do I need distinct MC and DOT numbers for each different dba?

The purpose of the USDOT Number is to track the safety of an organization. As such, there is no need for separate DOT numbers — unless the owners are not the same.

Motor carrier (MC) numbers are no longer required to be displayed. Older trucks may run with MC numbers displayed, so from time to time you might see them.

An MC Number is assigned by FMCSA to interstate for-hire carriers who apply for operating authority. The MC Number may be obtained from FMCSA for a fee and you can apply online for this at its website:

Truck Marking Rules – 49 CFR Part 390.21

Regarding the truck “Marking Rule,” DOT says:

Display the legal company name (as shown on the registration form MCS-150 “Motor Carrier Identification Report”) for all regulated vehicles (*GVWR/GCWR, GVW/GCW of 10,001 pounds or more).

To display another company name/dba on the vehicle, show the name and US DOT number of the company operating the vehicle, preceded by the words “operated by,” in the following manner:

DBA Company

Operated by:
Parent Company
USDOT 012345678

Again, the concept of having a single US DOT Number displayed is to avoid confusion when determining legal responsibility when interacting with motor carrier field enforcement officials.

Check your state’s requirements for intrastate marking rules. The rules may vary by state.


FMCSA – Federal Motor Carrier Safety Administration (an agency of the US DOT)

*GVWR – Gross Vehicle Weight Rating

GCWR – Gross Combination Weight Rating (power unit + a trailer)

GVW – Gross Weight Rating

GCW – Gross Combination Weight

Usually GVWR can be found on the vehicle door jam, or sometimes on the glove box door or in the Owner’s Manual. The weight rating is assigned by the manufacturer.

US DOT – United States Department of Transportation


Drug Testing Delays . . . What to do?



Drug Testing Procedures

A driver was selected for a Random DOT Drug Test. What should I do, if I called to notify a CDL driver everyday for a week with no response?

The Regulations in 49 CFR Part 382.307(l) say:

Each employer shall require that
each driver who is notified of selection
for random alcohol and/or controlled
substances testing proceeds to the test
site immediately; provided, however,
that if the driver is performing a safety-sensitive
function, other than driving
a commercial motor vehicle, at the
time of notification, the employer
shall instead ensure that the driver
ceases to perform the safety-sensitive
function and proceeds to the testing
site as soon as possible.

A safety-sensitive* function, other than driving — means, for example, inspecting or servicing the vehicle. When the safety-sensitive function is complete, the drug testing process needs to be conducted without any delays.

If a driver has been selected, the employer shall require that driver to submit to testing at their first available time in the terminal or other appropriate location. After an employee is notified, he or she must immediately proceed to the collection site, without delay.

Perhaps meet with your supervisor and/or dispatch to see how, working together, you can make this happen.

* 49 C.F.R. § 382.107 defines “safety-sensitive” to mean any on-duty functions in 49 C.F.R. § 395.2, including: (1) all time at a shipper or carrier, etc., waiting to be dispatched; (2) all time inspecting equipment; (3) all driving time; (4) all time in or on a commercial motor vehicle, except resting time; (5) all time loading or unloading; and (6) all time repairing, obtaining assistance, or remaining in attendance upon a disabled vehicle.

Safety Meeting Ideas

Winter Pileup


I will be having a Safety Meeting in the beginning of December. I am looking for some subjects or ideas to talk with my drivers during the meeting.

Changing seasons are always a good time to revisit driving strategies. The Fall is a good time to cover topics as:

  • Running in bad weather: snow, slush, ice, freezing rain.
    Emergency procedures.
    Chain Laws — if you run in the western half of the U.S.
    Carrying Firearms in the truck.
    Logging questions.
    Getting your DOT Medical card renewed.
    Top violations in the fleet.
    Preparing for roadside inspections.
    Load securement review.
    Security and safety when parking.

Perhaps look at your CSA scores and address some of the top CSA violations.

Good solid information on any of the above is always appreciated.

Why am I DOT Regulated?

Future Truck by Benz

Does what I do with a vehicle subject me to FMCSA or does the size of the vehicle regardless of what I’m doing with the vehicle subject me to FMCSA safety rules and regulations?

Answer: All of the above.

Determination if a trip is DOT regulated is made on a trip-by-trip basis, based on:
(1.) Intent of the trip; or
(2.) The Federal Motor Carrier Safety Regulations (FMCSRs).

Trip — is a one-way movement of a person or vehicle between two points.

Example: You take half of the seats out of a 15 passenger van so you can carry, at most, only 8 passengers (and escape many regulations), but occasionally have ten or twelve passengers and have those extra passengers sit on their luggage. Clearly, the intent on those trips carrying extra passengers is to haul more than eight passengers.

The key regulatory phrase is “Designed or used.”

Many times a vehicle or re-purposed or modified after it comes from the manufacturer. An old school can be turned into an RV or used as a truck. As such, it would not be a “bus,” but depending on the intent of user, it could become a federally regulated vehicle if used in commerce.

Note: Your state may have its own rules for the type vehicle you are operating or the type of operations you are engaged in (limo, towing, farm, commercial, etc).

FMCSA is the regulatory arm of the Unites States Department of Transportation (USDOT) and means: Federal Motor Carrier Safety Administration.

A $6,500.00 fine for being on a restricted route?

RegulationsIs it legal to charge a driver $6,500.00 for being on a restricted route?

Restricted routes may include:

  • Vehicles carrying Hazardous Materials (Haz-Mat) that cannot travel in tunnels or certain areas;
  • Motor homes and vehicles towing trailers (camping or travel) that are carrying propane tanks;
  • Vehicles over the legal maximum height, width and length dimensions. For example, Maryland (opens .pdf file) restricts combination vehicles towing a semi-trailer exceeding 48 feet in length up to, but not exceeding 53 feet in length, certain car/boat haulers, Maxi-cube combinations, and doubles, to certain routes.

Your state may publish a Motor Carrier Guide with this information. Your State Police or Highway Patrol or Department of Public Safety may have information on restricted truck routes.

Violations can result in fines from hundreds to thousands of dollars. It’s advisable to consult with an attorney, if you have been cited.

Driver Verification Fees

Running man

Is it legal to charge a fee for verification of a prior drivers employment/accident/drug history? I have heard yes and I have heard no.

Charging a de minimis fee for driver verification is a long established industry practice. Some carriers charge and some do not.

De Minimis, by the way is an abbreviated form of the Latin Maxim — de minimis non curat lex — or “the law cares not for small things.”

Guidance from the DOT says:

§40.25                                                                                 11/03


May the previous employer delay sending an employee’s drug and alcohol testing information to the gaining employer pending payment for the cost of the information?


• No. Part 40 specifically requires that previous employers immediately provide the gaining employer with the appropriate drug and alcohol testing information.

• No one (i.e., previous employer, service agent [to include C/TPA], employer information / data broker) may withhold this information from the requesting employer pending payment for it.