Author: Stephen Glazier
When working with clients, we occasionally encounter situations in which a client is unknowingly out of compliance with Department of Transportation (DOT) regulations. Many times, these issues relate to light trucks or vans that are occasionally used to tow trailers. There are passenger carrier regulations, which we cover in Are You Subject to DOT Regulations (Part 2): Passengers and Payment Type and hazardous materials regulations, which we cover in Are You Subject to DOT Regulations (Part 3): Hazardous Substances, Agents and Toxins.
For this article, let's make two assumptions:
- We're discussing vehicles being used in commerce. If they're driven for business in any way, they're in commerce.
- The vehicles are being driven on public roadways. If you operate only on private property or aren't operating in commerce, the DOT doesn't have jurisdiction over your operations.
Here, we discuss only DOT weight regulations and the weight threshold that triggers DOT regulations for light trucks and trailers.
DOT fleet capacity weight regulations
To understand DOT weight regulations, you need to understand three things: the difference between interstate and intrastate commerce; how vehicle capacity weight is calculated; and when DOT regulations go into effect.
1. Intrastate versus interstate operations
Weight regulations depend on where the vehicle operates:
- Interstate. Vehicles that cross state lines are involved in interstate commerce, and the federal regulation for vehicle capacity weight applies. A truck or truck/trailer combo with a capacity weight of 10,001 lbs. or more weighs is considered a commercial motor vehicle (CMV) and is subject to the federal regulations.
- Intrastate. For the sake of simplicity, let's say intrastate means the vehicle never crosses state lines. Some states use the federal threshold of 10,001 lbs. for intrastate vehicles, while some states set their own limits. For example, Colorado's threshold is 16,000 lbs., and Arizona's threshold is 18,000 lbs.
Those thresholds apply whether it's the weight of the truck along or the truck and trailer.
2. How vehicle capacity weight is determined
The vehicle capacity weight isn't the actual weight of the vehicle. It's the combined weight of the vehicle plus the weight it's designed to carry. That weight is the gross vehicleweight rating (GVWR), which is usually posted on sticker on the inside of the driver's door and on trailers.
DOT regulations are triggered by the gross combined weight rating (GCWR), which is the sum of the GVWR of the truck and the trailer.
3. When DOT regulations kick in
DOT regulations apply when the either the GVWR of the truck or the GCWR of the truck and trailer exceeds the threshold.
It may be helpful to look at an example. A three-quarter-ton truck — especially a diesel — can have a GVWR of 10,000 lbs., which is just 1 lb. shy of the federal GVWR limit that would require DOT compliance.
Let's look at what happens if such a truck is used for interstate or intrastate hauling:
- Interstate: Adding a 7,000-lb. dual-axle trailer to the truck 10,000-lb. truck makes it a CMV, because the combined weight — the GCWR — exceeds 10,001 lbs.
- Intrastate: In a state that uses the federal threshold, the truck/trailer's weight would make it a CMV. The same is true in Colorado, where the threshold is 16,000. But in Arizona, the vehicle would be below the 18,000-lbs. threshold.
Even if you have a smaller truck — say, a quarter-ton truck or van — with a 7,000-lbs. GVWR, adding a trailer with a GVWR of 3,001 lbs. or more would push the GCWR to 10,001 lbs.
CDLs have a different threshold
None of these thresholds requires a driver to have a commercial driver's license (CDL) to drive the vehicle. Many employers assume that if their drivers don't need a CDL, they're not subject to any DOT regulations. In fact, they may be required to keep driver qualification files, pull and check motor vehicle records, maintain medical cards, conduct road evaluations, ensure their drivers aren't disqualified, keep hours-of-service records and more.
You can learn more about federal regulations at the Federal Motor Carrier Safety Administration (FMCSA) website.1 Send questions about state-specific regulations to your Gallagher account team or to a state-specific enforcement agent, such as the state patrol or state police.
Knowing whether your fleet is regulated by the DOT is important. Learn about passengers vehicle regulations and regulations for transporting hazardous substance and toxins in the other articles in this three-part series.
