I enjoy discussing the fleet market with representatives of fleet management companies because, just like Automotive Fleet, they are in contact with a broad crosssection of different fleets of different sizes in different industries, which provides an excellent barometer of emerging trends. Recently, I participated in a teleconference with Merchants Fleet Management that included VP of Sales & Marketing Tom Coffey and Marketing Manager Tracy Durocher. The freewheeling discussion segued to where future growth will occur in the commercial fleet market, with Coffey focusing on the growing penetration of trucks and vans in light-duty fleets and Durocher stressing the need for more education because, in some circumstances, such as towing trailers, these fleets fall under DOT (U.S. Department of Transportation) regulations.
I, too, see growth in truck penetration in light-duty fleets, which is substantiated by R.L. Polk data, and agree with Durocher that more education is needed. Most of these companies operate vehicles under 10,001 pounds gross vehicle weight (GVW) and believe they are not covered by DOT regulations. However, this may not be the case, as Durocher points out, if vehicles are towing a trailer or equipment. Many light-duty fleets do not realize 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. It doesn’t matter if you have a one-truck or a 500-truck fleet, you must be compliant with DOT rules.
When the GCVW is 10,001 pounds or more, a vehicle is covered under DOT regs and must display a DOT number or it will be subject to a fine if pulled over by the police. In some states, a vehicle can even be placed out of service and held at the inspection facility until it is compliant. If the police issue a ticket to the driver and even though the company reimburses the driver for the fine, the citation goes on the driver’s record.
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, as well as 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 pounds. But it doesn’t matter. The truck and trailer were rated at more than 10,001 pounds and are thereby covered by DOT. It is important to know that it is not only the actual weight, but also the rating of the vehicle that determines whether it falls under DOT regs. In addition, OEMs are building more light-duty trucks rated at 10,001 pounds or more GVW or GCWR. You can buy a truck from a dealer at 12,000-pounds GVWR and you will need a DOT number on the side of the vehicle. Fleets need to understand that buying greater than 10,000-pound GVW-rated trucks makes them governable under both federal and state DOT regulations.
Who Needs a DOT Number?
A USDOT number is required for a commercial motor vehicle if any of the following criteria is met:
- A vehicle with a GVWR or GCWR of 10,001 pounds or more involved in interstate commerce.
- 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 and interstate operations.)
To apply for a USDOT number, you must go to the DOT’s URS website and complete the online form to obtain a USDOT number. 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.
Ignorance of the Law is No Excuse
The federal and state DOTs focus not only on the traditional over-the-road fleets, but also on light- and medium-duty fleets who may not know they are in violation. Fleet managers responsible for light-duty fleet assets 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.