The Car and Truck Fleet and Leasing Management Magazine

DOT Mandates May Apply When Using Trailers

November 2007, by Joe Bohn - Also by this author

When a Midwestern company bought an out-of-stock Ford F-350 Duallie to pull a small trailer full of training materials, it hardly considered the truck falling subject to federal regulation. Used to operating a large fleet of mostly cars, commercial truck regulations were never a big concern.

Even the company’s Ford Explorer Sport Tracs used to tow trailers fall under the weight limit, which exempts them from Department of Transportation (DOT) commercial operating requirements.

But, after having a driver of its F-350 stopped in Nebraska, pulled over to a weight station, and cited for failing to have a DOT number/decal, the company’s fleet manager learned how easy it is to cross the line into regulation territory.

“We dug into it, got on line with the DOT and started entering all the information required,” says the fleet manager.

“I had to learn all the requirements and regulations for log-keeping, hours on the road, and so forth,” the fleet operator added.

Such experiences aren’t unique. Many fleet managers, particularly those with insurance companies and pharmaceuticals who typically operate cars, are caught off guard when they first begin buying trucks and trailers.

"Many companies have one of two common misconceptions," said the former DOT Compliance and Driver Safety Programs Manager for Sprint Nextel Corp., in Overlake Park, Kan., Julie Timberlake. 

"They may think because they’re not hauling cargo, it’s not a commercial motor vehicle or it’s exempt from regulations because it’s too small," she adds.

"Big trucks are pretty self explanatory, in terms of their regulation requirements, but a lot of people don’t understand that with a 1/2- or 3/4-ton truck, the gross combination weight rating (GCWR) comes into play. As soon as you tow anything, even a small trailer, if the GCWR is greater than 10,000 pounds, it becomes a commercial vehicle because of its combination weight rating,” she adds.

At that point, companies are required to obtain a DOT number and follow guidelines as set forth by the Federal Motor Carrier Safety Administration (FMCSA).

The driver must have a medical exam, for example, documented on a DOT form. In addition, employers need to keep a driver file, including items such as a certificate of road test evaluation, background check on moving violations, and a log of hours spent on the road.

Employers also must provide documented driver training on various regulations.

If the vehicle carries something as seemingly harmless as spray paint or bug/insect repellent, for example, that qualifies as hazardous material, requiring specialized driver training every three years.

These are just some of the numerous requirements outlined by the FMCSA in its regulations for commercial vehicles. Complete details are available online at

The regulations apply to:

  • Vehicles with a GVWR or gross combination weight rating (GCWR) of more than 10,000 lbs.
  • Vehicles with a GVWR of more than 26,000 lbs., which require commercial driver license (CDL).
  • Vehicles hauling hazardous materials, whether operating across state lines or totally within one state.
  • Trucks or for-hire small buses designed to carry more than 16 people, including the driver.

    The regulations are lengthy and potentially confusing. For example, operators can drive 3/4- or 1/2-ton pickups without requiring a DOT sticker, if there is no trailer attached. But adding a trailer may put it over the 10,001-pound GCWR regulation limit.

    For that reason, Sprint Nextel, for example, uses magnetic DOT number decals that it attaches only when its pickups are towing a trailer.

    “If you’re not towing, the GCWR is not in effect, and you don’t have to display any signage. And the DOT won’t bother you,” says Timberlake.

    On days that any of its vehicles meet the definition of a commercial motor vehicle, the company also requires that drivers conduct a pre-trip inspection and be satisfied the truck is in safe operating condition, as specified by Sections 396.13 and 392.7 of the FMSCR.

    The driver must also document a post-trip inspection, in accordance with section 396.11.

    The next time the pickup truck is used, the report must be maintained and reviewed, prior to operating the vehicle, even if days, weeks, or months have elapsed.

    Even though DOT regulations only apply to vehicles crossing state lines, some states, like California and North Carolina, also have in-state commercial truck requirements.

  • California regulations are very stringent, exceeding even those of the federal government. They require operators of trucks with trailers over 10,001 lbs. GVW, for example, to have CDL licenses.

    They’re also very confusing.

    Says Timberlake: “If you’re crossing state lines, you’re responsible to know any of the rules of that state, over and above the federal regulations.”

    The information is typically available online from the state’s department of motor vehicles, which is usually the governing administration. In some states, it’s available from the highway patrol.

    Even savvy operators can be caught off guard by federal regulation governing trailer brakes, for example.

    Section 393.42 on the FMSCR Web site notes a requirement for the truck and trailer to have a common braking system for all wheels. Basically, that means when an operator steps on the brakes they must apply pressure to all truck and trailer wheels at the same time.

    One fleet operator interviewed by Work Truck noted that many of the company’s trailers were originally equipped with surge brakes.

    Surge brakes, unlike electrical brakes, operate under inertia. Typically, surge brakes are incapable of providing DOT’s one-brake-for-all-wheels requirement.

    After discussion among its supervisors, the company took the action needed to retrofit the trailers. It decided to retrofit its fleet with electrical brakes. Such a retrofit costs about $600 and can be done in a few hours.

    The confusion surrounding the brake systems resulted from the company’s departments not taking the FMCSRs into consideration prior to ordering trailers.

    Last July, a fleet official within the company created an internal fact sheet for departmental supervisors, which explained the surge brake issue in layman’s terms.

    Electric brakes use a single valve to control braking on all the vehicle’s truck/trailer wheels.

    A small brake control box, typically mounted under the dash, controls the amount of braking pressure and how quickly it’s applied after the operator steps on the brakes.

    DOT regulations really have a major impact on vehicle spec’cing, the company’s fleet manager noted.

    And in that respect, it pays to thoroughly study the guidelines and consider all the ways in which an operator’s trucks might be used in the future before spec’cing them.

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