• Motor carriers with a DOT number are subject to CSA program requirements.
• CSA may or may not be a factor for other carriers.

The Compliance, Safety, Accountability (CSA) program touches the same motor carriers that have always been subject to Federal Motor Carrier Safety Administration (FMCSA) tracking and enforcement — namely, those that have obtained a U.S. Department of Transportation (DOT) number. As required under 49 CFR 390.19, a DOT number is required of anyone operating a “commercial motor vehicle” as defined in 390.5.

For carriers that do not operate in interstate commerce but are engaged entirely in intrastate commerce, within the borders of a single state, CSA may or may not be a factor because:

• Not all states require intrastate carriers to obtain a DOT number (some require a state identifier);
• Not all states require carriers operating the vehicles described above to obtain DOT numbers (some, for example, do not require a DOT number for vehicles under 26,001 pounds); and
• The states are not required to use CSA for enforcement purposes, though some do.

Note, however, that the FMCSA has jurisdiction over intrastate transporters of hazardous materials, so those carriers are subject to the CSA program.