The Car and Truck Fleet and Leasing Management Magazine

Not Covered by DOT? Think Again

August 2007, by Mike Antich - Also by this author

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-road fleets," 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.

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