Your pickup truck might be a CMV
Did you know that your company pickup truck just might be defined as a commercial motor vehicle (CMV) according to the Federal Motor Carrier Safety Regulations (FMCSRs)? You may be thinking that you are not hauling cargo with the truck so it can’t be a CMV, or that your truck is way too small to qualify.
To understand how and when some of your company’s smaller vehicles become CMVs, consider the following:
- Commerce involves anything that furthers business, such as hauling supplies and tools to and from a worksite, dropping off workers, or just visiting a worksite in the course of business. If you are not hauling freight for someone else, you can still be considered a private (motor) carrier.
- The weight of the truck, load, and any trailer you may be transporting are included in the “10,001 pounds or greater” definition of CMV found in 390.5. This includes the manufacturer’s specifications of the truck by itself (i.e., gross vehicle weight rating (GVWR)), or with a trailer (i.e., gross combination weight rating (GCWR)). If you exceed the manufacturer’s weight specifications and the actual weight of the vehicle and load, with or without a trailer, is 10,001 pounds or greater, this is considered a CMV based on gross vehicle weight (GVW) or gross combination weight (GCW).
- Any size vehicle is subject to the safety regulations if it is hauling placardable amounts of hazmat.
The trailer can be key
Even if the trailer is a small utility model, if it places you at the 10,001 pounds or greater you are now operating a CMV.
If the vehicle only meets the definition when pulling a trailer, you would only be concerned about observance of the safety regulations on those days it meets the definition. This includes applying USDOT markings on the side of the truck and possibly stopping at roadside inspection stations.
It’s a CMV. Now what?
When you find your pickup meets the CMV definition, the usual FMCSR requirements for CMVs apply:
- Whoever drives this vehicle must be completely qualified under Part 391, including a copy of the medical certificate on the person of the driver when operating the truck.
- The driver must comply with the hours-of-service regulations.
- The pickup truck and trailer are subject to vehicle inspection and maintenance rules.
- You must retain records on the annual/period inspection of both the truck and trailer, including the appropriate documentation while on the road (i.e., inspection stickers or a copy of the inspection forms). In addition, you would be expected to present maintenance records on the truck and trailer in the event of an audit.
Finally, remember to consider the vehicle before any interstate travel. Depending on the circumstances, registration requirements under the International Registration Plan (IRP) may also come into play.
For vehicles between 10,001 and 26,000 pounds, some jurisdictions require trip permits or apportioned plates to travel through the jurisdiction or when engaging in intrastate transportation.
Even if the vehicles will stay within their base state only, the registration needed will depend on how the state registers smaller-type commercial vehicles or combinations.