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Copyright 2026 J. J. Keller & Associate, Inc. For re-use options please contact copyright@jjkeller.com or call 800-558-5011.
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FEATURED NEWS
2026-06-15T05:00:00Z
NewsIndustry NewsFleet SafetyRisk Management TransportationRisk Management - Motor CarrierFocus AreaIn-Depth ArticleEnglishTransportationUSA
3 areas that catch motor carriers off guard and create risk when operating intrastate
For motor carriers that operate solely within one state, it is easy to assume that their operation can use less strict state regulations or use a federal exemption from most regulations. Most states adopt the Federal Motor Carrier Safety Regulations (FMCSRs) with some exceptions. Deciphering state rules often requires the help of a compliance expert.
1. State adoptions of federal regulations and guidance
A common pitfall is assuming the federal definition of a commercial motor vehicle (CMV) applies universally or that only vehicles requiring a commercial driver’s license (CDL) are regulated when operating intrastate-only.
Under federal rules in 390.5 that apply to interstate commerce, driver qualification or vehicle marking requirements are triggered by factors such as:
- Vehicle weight of 10,001 pounds or more,
- Passenger capacity rating at 16+ passengers, or 9–15 for compensation, or
- Placardable hazardous materials.
Under 383.5, a CDL-required vehicle is one that:
- Weighs 26,001 pounds, or
- Is a combination that weighs 26, 001 pounds or more with a trailer weighing 10,001 pound or more, or
- Carries or is rated for more than 15 passengers including the driver, or
- Hauls placardable hazmat.
For intrastate-only operations, the applicable CMV definition entails reviewing state statutes, administrative codes, and enforcement guidance because states frequently modify the safety regulations via the applicable CMV definition.
Some states apply driver qualification and medical certification rules at higher weight thresholds for intrastate property carriers, while still maintaining lower passenger thresholds.
2. Interstate commerce when operating in one state
A frequent misconception is that if a carrier’s vehicles operate entirely within a state’s borders, the intrastate rules apply. The following are examples of interstate commerce within a state:
- The delivery of products that came from out of state or from another country out of a warehouse to destination in the same state, or
- The pickup of products destined for another state or country from a shipper and delivery to a warehouse in the same state, or
- Transporting passengers to or from an airport under a pre-arranged agreement.
If a driver is furthering interstate commerce in a CMV as defined in 390.5 and is not qualified under federal rules, the carrier is at significant risk of increased liability and compliance issues
3. Differences in medical certification, age limits, and exemptions
Even though states adopt Part 391, which covers driver qualifications, they often modify specific provisions. While most states align with the federal requirement for a valid Medical Examiner’s Certificate, some maintain separate intrastate-only medical programs or grant waivers for certain drivers, such as farm or seasonal operators.
Age requirements also vary. Federally, a driver must be at least 21 years old to operate any CMV in interstate commerce, but states may allow drivers as young as 18 years old to operate intrastate, provided the driver and the cargo meet state criteria.
A carrier must be certain that a driver using state exceptions will operate only in intrastate commerce.
Keys to remember: Proactively identify and address state-specific differences to avoid costly violations and litigation. Engage the help of a compliance expert, if necessary.
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RECENT INDUSTRY HIGHLIGHTS
2026-06-15T05:00:00Z
NewsHazardous WasteWaste GeneratorsWaste ManifestsWaste/HazWasteWasteEnvironmental Protection Agency (EPA)In-Depth ArticleEnglishIndustry NewsWaste ReportingWasteTSD FacilitiesWaste ManagementEnvironmentalFocus AreaUSA
Hazardous waste manifest S Codes: What storage and transfer facilities need to know
Have you cracked the “S Code” yet? Starting in 2027, facilities that receive regulated waste for temporary storage and disposal must use S Codes on hazardous waste manifests. If your facility hasn’t made the switch, now’s the time!
Under the Resource Conservation and Recovery Act (RCRA), the Environmental Protection Agency (EPA) requires hazardous waste handlers to track shipments of regulated waste from the generating facility to final treatment, recycling, or disposal. Management Method Codes are key to hazardous waste manifests, and they also affect biennial reporting. The codes answer the vital question, “How’s the hazardous waste managed?"
Effective January 1, 2027, “S Codes” will officially replace code H141 for Storage and Transfer. EPA adopted these codes to improve the accuracy and transparency of waste tracking, specifically for wastes that travel through transfer facilities before final management. Use this overview to help your facility understand how to comply.
What are S Codes?
In January 2025, EPA added S Codes to the list of Management Method Codes, which identify the type of waste management system used to treat, recover, or dispose of a hazardous waste. Management Method Codes are used for:
- The Uniform Hazardous Waste Manifest (EPA Form 8700-22) and Continuation Sheet (EPA Form 8700-22A); and
- The National Biennial RCRA Hazardous Waste Report (EPA Form 8700-13 A/B), known as the Biennial Report.
S Codes apply to receiving facilities (primarily treatment, storage, and disposal facilities (TSDFs)) that temporarily store and then transfer regulated hazardous waste to another receiving facility without treating, recovering, or disposing of the waste. EPA established S Codes to provide more details than code H141 on waste handling activities, improving tracking and transparency. S Codes indicate two things:
- A hazardous waste was received to be stored or transferred; and
- The hazardous waste will be managed later by the final receiving facility using a certain method (i.e., the final management method).
EPA groups S Codes into three categories:
- Transfer off-site for reclamation and recovery,
- Transfer off-site for destruction or treatment prior to disposal, and
- Transfer off-site for disposal.
Each S Code corresponds to a specific final management method. Examples of these methods include metals recovery (S010), chemical treatment (S070), and landfilling (S132).
What’s required?
On January 1, 2027, EPA will remove Management Method Code H141 for Storage and Transfer from the e-Manifest and the Biennial Report forms. As a result, hazardous waste handlers must use S Codes instead of code H141 on manifests and the Biennial Report.
S Codes apply to RCRA hazardous waste that’s transferred off-site, impacting:
- Receiving facilities that store and transfer hazardous waste;
- Permitted TSDFs that receive hazardous waste solely for temporary storage and transfer (i.e., it’s the facility’s only management type); and
- Large quantity generators (LQGs) that report wastes shipped to transfer facilities on the Biennial Report.
Hazardous waste manifests
The first receiving TSDF is responsible for choosing and entering the S Codes on manifests. The storage and transfer facility must:
- Identify the S code that best describes how the hazardous waste will be managed by the final receiving facility, and
- Enter the S Code in Item 19 on the manifest and in Item 36 on the continuation sheet (if used).
Generators aren’t responsible for selecting or entering S Codes.
Biennial Reports
LQGs and TSDFs must use S Codes for the Biennial Report on the:
- Waste Generation and Management (GM) Form in Item 3, and
- Waste Received From Off-site (WR) Form in Item F.
LQGs use S Codes on the GM Form for shipments of hazardous waste off-site to a transfer facility for temporary storage and transfer.
TSDFs that receive hazardous waste for temporary storage and transfer off-site use S Codes on the WR Form. These TSDFs must also use Source Code G61 on the GM Form to report shipments of these transferred wastes.
How can facilities prepare?
Help your facility achieve a smooth shift to S Codes by January 1, 2027, with these tips:
- Identify where your facility currently uses code H141.
- Develop a process for transitioning to S Codes exclusively. Consider any changes your facility may need to make to its operations, such as updating software, adjusting procedures, and revising internal guidance documents.
- Train your employees accordingly.
- Set a deadline for making the switch to S Codes. Aim for a date well ahead of January 1, 2027, to give your facility enough time to address any issues that arise.
Key to remember: Starting in 2027, storage and transfer facilities must use S Codes in place of code H141 on RCRA hazardous waste manifests and Biennial Reports.
Keep reading...Show less
2026-06-15T05:00:00Z
NewsHazardous WasteWaste GeneratorsWaste ManifestsWaste/HazWasteWasteEnvironmental Protection Agency (EPA)In-Depth ArticleEnglishIndustry NewsWaste ReportingWasteTSD FacilitiesWaste ManagementEnvironmentalFocus AreaUSA
Hazardous waste manifest S Codes: What storage and transfer facilities need to know
Have you cracked the “S Code” yet? Starting in 2027, facilities that receive regulated waste for temporary storage and disposal must use S Codes on hazardous waste manifests. If your facility hasn’t made the switch, now’s the time!
Under the Resource Conservation and Recovery Act (RCRA), the Environmental Protection Agency (EPA) requires hazardous waste handlers to track shipments of regulated waste from the generating facility to final treatment, recycling, or disposal. Management Method Codes are key to hazardous waste manifests, and they also affect biennial reporting. The codes answer the vital question, “How’s the hazardous waste managed?"
Effective January 1, 2027, “S Codes” will officially replace code H141 for Storage and Transfer. EPA adopted these codes to improve the accuracy and transparency of waste tracking, specifically for wastes that travel through transfer facilities before final management. Use this overview to help your facility understand how to comply.
What are S Codes?
In January 2025, EPA added S Codes to the list of Management Method Codes, which identify the type of waste management system used to treat, recover, or dispose of a hazardous waste. Management Method Codes are used for:
- The Uniform Hazardous Waste Manifest (EPA Form 8700-22) and Continuation Sheet (EPA Form 8700-22A); and
- The National Biennial RCRA Hazardous Waste Report (EPA Form 8700-13 A/B), known as the Biennial Report.
S Codes apply to receiving facilities (primarily treatment, storage, and disposal facilities (TSDFs)) that temporarily store and then transfer regulated hazardous waste to another receiving facility without treating, recovering, or disposing of the waste. EPA established S Codes to provide more details than code H141 on waste handling activities, improving tracking and transparency. S Codes indicate two things:
- A hazardous waste was received to be stored or transferred; and
- The hazardous waste will be managed later by the final receiving facility using a certain method (i.e., the final management method).
EPA groups S Codes into three categories:
- Transfer off-site for reclamation and recovery,
- Transfer off-site for destruction or treatment prior to disposal, and
- Transfer off-site for disposal.
Each S Code corresponds to a specific final management method. Examples of these methods include metals recovery (S010), chemical treatment (S070), and landfilling (S132).
What’s required?
On January 1, 2027, EPA will remove Management Method Code H141 for Storage and Transfer from the e-Manifest and the Biennial Report forms. As a result, hazardous waste handlers must use S Codes instead of code H141 on manifests and the Biennial Report.
S Codes apply to RCRA hazardous waste that’s transferred off-site, impacting:
- Receiving facilities that store and transfer hazardous waste;
- Permitted TSDFs that receive hazardous waste solely for temporary storage and transfer (i.e., it’s the facility’s only management type); and
- Large quantity generators (LQGs) that report wastes shipped to transfer facilities on the Biennial Report.
Hazardous waste manifests
The first receiving TSDF is responsible for choosing and entering the S Codes on manifests. The storage and transfer facility must:
- Identify the S code that best describes how the hazardous waste will be managed by the final receiving facility, and
- Enter the S Code in Item 19 on the manifest and in Item 36 on the continuation sheet (if used).
Generators aren’t responsible for selecting or entering S Codes.
Biennial Reports
LQGs and TSDFs must use S Codes for the Biennial Report on the:
- Waste Generation and Management (GM) Form in Item 3, and
- Waste Received From Off-site (WR) Form in Item F.
LQGs use S Codes on the GM Form for shipments of hazardous waste off-site to a transfer facility for temporary storage and transfer.
TSDFs that receive hazardous waste for temporary storage and transfer off-site use S Codes on the WR Form. These TSDFs must also use Source Code G61 on the GM Form to report shipments of these transferred wastes.
How can facilities prepare?
Help your facility achieve a smooth shift to S Codes by January 1, 2027, with these tips:
- Identify where your facility currently uses code H141.
- Develop a process for transitioning to S Codes exclusively. Consider any changes your facility may need to make to its operations, such as updating software, adjusting procedures, and revising internal guidance documents.
- Train your employees accordingly.
- Set a deadline for making the switch to S Codes. Aim for a date well ahead of January 1, 2027, to give your facility enough time to address any issues that arise.
Key to remember: Starting in 2027, storage and transfer facilities must use S Codes in place of code H141 on RCRA hazardous waste manifests and Biennial Reports.
Keep reading...Show less
2026-06-12T05:00:00Z
NewsEmergency Planning - OSHAIndustry NewsIndustry NewsSafety & HealthWeather and Natural DisastersEmergency PreparednessEmergency Planning (OSHA)General Industry SafetyU.S. Chemical Safety and Hazard Investigation Board (CSB)EnglishFocus AreaUSA
CSB urges chemical companies to prepare for hurricane season
The U.S. Chemical Safety Board (CSB) urges chemical companies to prepare for extreme weather conditions, as the Atlantic Hurricane season is officially underway. Proactive planning and preparation by chemical facilities helps ensure the safety of workers, emergency responders, and surrounding communities from the dangers of chemical releases. According to the CSB, top priorities for limiting severe weather impacts are:
- Securing hazardous materials,
- Ensuring backup power for critical safety systems,
- Training personnel on emergency protocols, and
- Coordinating with local emergency management authorities.
The CSB encourages facilities to review its hurricane preparation resources and implement applicable recommendations.
2026-06-12T05:00:00Z
NewsIndustry NewsEnglishAssociate RelationsTraining & DevelopmentHR GeneralistIn-Depth ArticleEmployee Mental HealthHR ManagementWellnessUSAFocus AreaHuman Resources
Joy to the workplace
If you look around your office and see happy people, it’s likely that you and other coworkers have a hand in making this happen. New research from Wiley Workplace Intelligence shows that colleagues are a major influence on happiness in the workplace.
Both work and the people we work with can lead to an upbeat feeling. More than 75 percent of the employees surveyed said they feel joy in their work, according to the report. Most also said they:
- Feel motivated to do their best work,
- Feel connected to the people they work with (85 percent), and
- Understand how their role contributes to organizational success (93 percent).
Many employees (39 percent) cited their team as a major influence on their happiness at work. Another 19 percent said they shape their own joy, while only 6 percent credited senior leadership.
This research indicates that the team level is where workplace joy is won or lost. Specifically, it says that "Joy is local.” It’s found in:
- Daily interactions,
- Moments of collaboration, and
- The small but consistent experience of feeling seen by the people you work alongside.
On the other hand, efforts to build joy company-wide through announcements, campaigns, or top-down culture initiatives, may miss the mark.
The research points to these five practical interventions that can help increase joy:
- Focusing on capacity, not just commitment. Even when motivation is high, a shortage of time and resources can cause a frustrating bottleneck. Organizations that want to strengthen hope and joy should ask hard questions about workload, support structures, and whether employees have what they genuinely need to succeed, not just survive.
- Aiming for clarity at every level. Direction doesn’t flow automatically through organizations. It must be actively communicated and reinforced at every level.
- Support managers as a primary intervention. The road to greater hope and joy in an organization runs directly through its managers. Manager well-being should be a priority, not an afterthought. When managers receive clear direction, adequate resources, and more time to accomplish goals, those conditions extend to the people they lead.
- Investing at the team level. Factors that strengthen the relationships of team members, such as everyday recognition and true psychological safety, are investments in the actual source of workplace joy. Joy lives closest to coworkers, not leadership.
- Being intentional about development. Viewing a role as a starting point and working to help people thrive in roles that fit their strengths adds value to their workplace goals. This is an area where intentional development conversations and role design can make a real difference.
Key to remember: Joy in the workplace starts at the team level. Strengthening relationships at the team level can influence overall happiness in the workplace.
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2026-06-12T05:00:00Z
NewsIndustry NewsFleet SafetyExpert InsightsBusiness policies and procedures - Motor CarrierBusiness planning - Motor CarrierFocus AreaFleet OperationsEnglishTransportationBusiness planning - Motor CarrierUSA
Expert Insights: Motus — FMCSA's forward momentum
The Federal Motor Carrier Safety Administration (FMCSA) has rolled out the first phase of Motus, a new USDOT registration system designed to streamline compliance and modernize the way motor carriers, brokers, and supporting companies manage their regulatory obligations. Motus, which is Latin for movement/motion, represents a significant shift from the current systems and will involve consolidating USDOT numbers, biennial updates, hazmat registrations, and other filings into one secure, user friendly platform.
The initiative aims to simplify processes, enhance fraud prevention, and provide registrants with intuitive tools such as auto population, real time data validation, and mobile accessibility.
Troubleshooting Motus issues
Many carriers are running into obstacles when registering for Motus. The most frequent issue is not being able to claim DOT numbers, and the most common reason for this is that the carrier didn’t update its information before the deadline.
For example, only the company official can claim your USDOT number. This means that if your company official left earlier this year and you didn’t update this information in your portal, then you won’t be able to claim your USDOT number.
If you’re struggling to get your Motus account set up or claim your USDOT number, you must contact FMCSA at 800-832-5660. FMCSA will only work directly with the motor carrier at this point. Once you have set up your account, you can then grant permissions to other individuals — both within and outside of your organization.
Motus watchouts
Motus gives you more control over your registration, but it also puts more responsibility on you. For example, Motus has simplified applying for operating authority, but knowing which authority your company needs remains unclear. Obtaining the incorrect authority type can be costly, and making mistakes on your application can lead to long delays.
Without the correct authority in place, you may run into:
- A delay in approval, which would lead to a delay in beginning operations.
- Additional application fees, as you may need to reapply.
- Compliance issues, which could lead to expensive fees, audits, or even being placed out of service.
Key to remember: FMCSA has rolled out the first phase of Motus, which aims to streamline and simplify compliance, but it also comes with a few additional challenges for motor carriers.
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Copyright 2026 J. J. Keller & Associate, Inc. For re-use options please contact copyright@jjkeller.com or call 800-558-5011.