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Market Trends

Not Covered by DOT? Think Again

August 7, 2007, by Mike Antich

Most companies operating vehicles under 10,001 lbs. gross vehicle weight (GVW) believe they are not covered by DOT (U.S. Department of Transportation) regulations. However, this may not be the case if vehicles are towing a trailer or equipment. Many light-duty fleets do not realize that DOT regulations are triggered not only by GVW, but also by gross combination vehicle weight (GCVW) – the combined weight of the vehicle and the trailer. “When the GCVW hits 10,001 lbs. or more, a vehicle is covered under DOT regs,” said Bret Watson, fleet manager for Sprint Nextel. “Many light-duty fleets do not realize this.”

However, this awareness is growing due to increased ticketing. Police departments throughout the country, especially in California, Kentucky, and Georgia, have been aggressive in ticketing commercial trucks that do not display a DOT sticker. Fines range from $236 to $280. In some states, a vehicle can even be impounded at a weigh station if it is non-compliant. This is a cantankerous issue with some light-duty fleets. The reason is that the ticket is issued to the driver. Even though the company reimburses the driver for the fine, the ticket goes on the driver’s record and may result in higher personal insurance premiums for the driver. Already some drivers are refusing to drive trucks until they are DOT-compliant.

“It doesn’t matter if you have a one-truck fleet or a 500-truck fleet, you need to take a hard look to see if you are compliant with DOT rules,” said Dan Doucette, national truck manager, Mike Albert Fleet Management in Cincinnati. “This is an issue that needs to be talked about.”

Vehicle Rating is the Criteria, Not Weight
An important point to understand is that the threshold to be governed by DOT regs is a vehicle’s rating, not its actual weight.

“Fleet managers will say their truck and trailer are not covered by DOT because combined, they do not weigh more than 10,001 lbs. But it doesn’t matter. The truck and trailer were rated at more than 10,001 lbs. and are thereby covered by DOT,” said Watson. “It is important to know that it is not the weight, but the rating of the vehicle that determines whether it falls under DOT regulations.” To illustrate this point, Watson uses a Ford Expedition, which has a GVW of 6,000 lbs., as an example. The Expedition also has a trailer weight of 5,900 lbs., which results in a gross combined vehicle weight of 11,900 lbs. “If the Expedition is towing less than 4,000 lbs., you may think that it would not be covered by DOT, since it is under the 10,001-lbs. threshold, but this is not the case. The Expedition is covered by DOT because the vehicle is rated at 11,900 lbs.,” said Watson.

In addition, OEMs are building more light-duty trucks are rated at 10,001 lbs. or more GVW or GCWR. “You can buy a truck right from the factory at 12,000-lbs. GVW and you will need a DOT sticker,” said Doucette. “Fleets need to be educated that buying this size truck makes them governable under DOT regs.”

Who Needs a DOT Number?
According to Doucette, a USDOT number is required for a commercial motor vehicle if any of the following criteria is met:

  • It has a GVWR or GCWR of 10,001 lbs. or more.
  • It is designed to transport more than eight passengers (including the driver) for compensation.
  • It is designed to transport 16 or more people including the driver, and is not used to transport passengers for compensation.
  • It is transporting hazardous materials in quantities requiring the vehicle to be placarded. (There is no weight threshold for placarded vehicles and applies to both intrastate or interstate operations.)

    “To apply for a USDOT number, you must complete the MCS-150 (Motor Carrier Identification Report) and a MCS-150A (Safety Certification Application) to obtain a USDOT number,” said Doucette. The forms and submission instructions can be found at the Web site

    “The purpose of the USDOT number is to serve as a unique identifier when collecting and monitoring a company’s safety information acquired during audits, compliance reviews, crash investigations, and inspections,” said Doucette.

    Ignorance of the Law is No Excuse
    "The DOT is expanding its focus beyond traditional over-the-roadfleets," said Mike Butsch, North America fleet/alliance manager for Joy Global. "These fleets know the regulations."

    The attention is shifting to light- and medium-duty fleets who may not know they are in violation. Fleet managers need to reverse the culture of "this doesn*t apply to us." DOT compliance requires more than affixing a DOT number to the side of a truck. It involves recordkeeping, driver qualification records, complying with HOS regulations, driver record of duty status (driver log), vehicle inspection requirements, etc. Non-compliance penalties can be expensive and the DOT can shut down a fleet operation in egregious situations. To use a cliché, ignorance of the law is no excuse.

    Let me know what you think.

    [email protected]

  • Comments

    1. 1. Debbie Palmisano [ December 17, 2009 @ 08:51AM ]

      We lease Penske trucks to transport our computer equipment for trade shows. Penske says we do not have to have a DOT number but one of our drivers was told at a weigh station by an Illinois Commerce Commission officer that we did need one. Cannot seem to find the answer to this one. Any ideas where we can go for help?

      Do we or don't we need a DOT number for a rental truck?

    2. 2. David [ September 20, 2010 @ 02:48PM ]

      My understanding from an Ill. weigh station is that if you rent the truck from Penske for less than 30 days you do not need one. Penske should have one for short term lease.

    3. 3. melissa seabolt [ October 31, 2011 @ 10:04AM ]

      hello quick question i think. my husband and i own a very small 1 truck ag repair business and where told that we need a number because he carriers supplies to do the job (parts and other things). does this require us to have a dot number and what other requirements are there. thanks for ur time with this. melissa

    4. 4. Nick Cunningham [ May 30, 2012 @ 09:56AM ]

      My question is regarding vehicles in our non dot fleet that would need to go back and forth. We have a large fleet of DOT vehicles and a small fleet of light duties that are rarely used in a DOT regulated situation. My desire would be to alternate the vehicle using non permanent markings. The problem arises about inspection we have a 90day inspection program which DOT requires that any DOT regulated vehicle be inspected every 90 days regardless of use or lack thereof. I know what is required to move a vehicle from DOT to non DOT status as far as paperwork and inspection goes. What is required to remove from the 90 day inspection program and DOT fleet?

    5. 5. Tewodros [ December 30, 2014 @ 05:20PM ]

      I am lite truck driver non commercial truck, the PG county police officer pull me out the road for inspection, asking me Driver license, registration, and DOT, after I explain it's non commercial he come with the idea of tire on the left rear low air tire and DOT. Gave me ticket $230.00 with in 30 day payable and gave me warning not move till you fix tire stick. What are you advise me. It's happen 12/30/2014.

    6. 6. tyler madison [ June 15, 2015 @ 10:07PM ]

      i have an expedition that i use for work my company machanic saud i should get a dot inspection sticker since i use the vehicle for work plus i live in louisiana

    7. 7. Tim Albers [ January 23, 2016 @ 03:03PM ]

      I own a small playground business in Missouri that uses 2 15' Box trucks (no trailers) to deliver our equipment to residential locations for install. These trucks do not weigh over 10,000 lbs. We had one pulled over and was told a US DOT # was needed, yet according to everything I read we do not need this #. Am I missing something?

    8. 8. Mical Sanchez [ July 26, 2016 @ 06:26PM ]

      I'm driving my 2007 Hino box truck from NH to FL I'm moving my family down I need dot numbers?this truck is registered to me but gvwr is over 10000lbs?do I need to run a log book?

    9. 9. Patrick Carol [ August 26, 2016 @ 08:05AM ]

      Is a DOT inspection required for a privately owned recreational vehicle? The RV is a 30 feet with an F-350 cab with a 460c.i. motor

    10. 10. Mikhail [ June 30, 2017 @ 01:52PM ]

      2004 dodge sprinter box truck 9990 gvw. Same with some new ford transit box trucks. All I use for my small business

    11. 11. Mikhail [ June 30, 2017 @ 01:54PM ]

      2004 dodge sprinter 3500 box van has gvw of 9990. In 2005 they raised over 10k. 2015 and up transit 350 box trucks/van can be purchased with 9980 gvw rating. All I use for my business. Ties the DOT cops hands

    12. 12. Mark Wholesale [ February 28, 2018 @ 02:07PM ]

      I am a car dealer and I use trucks off the lot to haul a 2 car hauler. I am always under 26,000. Michigan state laws state I can use dealer plates to transport vehicles with trailers. When I go out of state am I required to get a dot number and how would the vehicle records be kept because sometimes the truck only is used for one trip even one way.

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    Mike Antich

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    Mike Antich has covered fleet management and remarketing for more than 20 years and was inducted in the Fleet Hall of Fame in 2010.

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