I understand that Foundation members’ main focus is providing services to interstate for-hire motor carriers, which in most cases, would be insuring 18-wheelers. I have in previous information stated that the Unified Registration System has mandated state enforcement of who has to have a DOT# -- All users, for-hire or private, of a vehicle 10,001 GVW or larger – Not just an 18-wheeler but a 6-wheel pick-up --- must register with the FMCSA and obtain a DOT# that is required to be displayed on the side of the vehicle.
My son-in-law has a construction company in Six Mile, South Carolina – Yes -- Six Mile is about 30 miles northwest of Greenville. I am a partner and handle their insurance which renews on July 1. I was meeting with the agent to go over the renewal. As a part of the process I talked about the one and one-half ton truck that they use to pick up and deliver building materials not only in South Carolina but also Georgia and North Carolina.
Guess what? They told me that the vehicle had been stopped in Georgia on April 27, 2015 and received a warning because:
Violation Codes as cited on Driver/Vehicle Examination Report:
385.301A – Failure to register with FMCSA to obtain a US DOT number – Unable to locate during inspection
390.21B – Carrier’s name and/or US DOT number not displayed as
required – No US DOT number displayed
Ok, I understand but it went on –
393.11 – Lamp lens broken or improper color – Right head lamp lens cracked
393.95A – Fire extinguisher not equipped
Again, no surprise, but added –
391.41A-F – Operating a property-carrying vehicle without possessing a valid medical certificate – Warning
I have often discussed the importance of a user of a vehicle 26,001 GVW or larger to make sure they comply with the CDL hiring standards. I now understand that all drivers of CMV’s 10,001 GVW or larger must meet all requirements BUT the drug testing. At inspection time, the driver must meet the medical certification which must be completed by a provider that is on the National Registry list. The list can be found on the FMCSA website. If a DOT enforcement officer stops by your insured’s location to “help” your insured, they will review the application, MVR, previous employment and other requirements. If not in the driver’s employment file and on hand the insured could be fined. One area that the officer inspecting the one and one-half ton truck did not add is payment of the URS fees (I do know this and had my company comply).
An additional item to consider would be the Hours-of-Service. If the unit is within the 100 air miles of the office where they started from, then they do not need a “log book”, but if over 100 air miles, then they will. Even within the 100 miles, the driver is subject to the Hours-of-Service and the records must be kept in the home office.
So do you, your agency or company also insure private motor carriers using vehicles in interstate commerce 10,001 GVW or larger? If so, are they meeting the driver screening requirements of the FMCSA? If not, do you need to bring this to their attention? Would it be a concern if the driver has a crash and the driver has not been qualified to drive the vehicle? -- No CDL but other requirements?
For the August 13, 2015 monthly Truck Stop webinar (2:00 p.m. EDT) with the help of Scott Murray, we will go through the requirements of users of CMV’s that are not 18-wheelers.
Blog by Tommy Ruke,