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Scope
Proper external identification of vehicles is an important compliance issue.
Regulatory citations
- 49 CFR 390.19 — Motor carrier identification reports for certain Mexico-domiciled motor carriers
- 49 CFR 390.21T — Marking of self-propelled CMVs and intermodal equipment
- 49 CFR 390.5T — Definitions
Key definitions
- Commercial motor vehicle (CMV): Any self-propelled or towed motor vehicle used on a highway in interstate commerce to transport passengers or property when the vehicle:
- Has a gross vehicle weight rating or gross combination weight rating, or gross vehicle weight or gross combination weight, of 10,001 pounds or more; or
- Is designed or used to transport more than 8 passengers (including the driver) for compensation; or
- Is designed or used to transport more than 15 passengers, including the driver, and is not used to transport passengers for compensation; or
- Is used in transporting hazardous material in a quantity requiring placarding.
- Door signs: Another term for vehicle markings.
- USDOT number: A number that serves as a unique identifier when collecting and monitoring a company's safety information acquired during audits, compliance reviews, crash investigations, and inspections.
- Vehicle marking: A sign or lettering on each side of a motorized CMV identifying the carrier responsible for the safe operation of the vehicle.
Summary of requirements
Determining which vehicles need to display identification and what information must be shown can be confusing.
Several factors influence the answer to these questions. First, where does the vehicle operate? Traveling across state lines or furthering interstate commerce subjects the vehicle to Federal Motor Carrier Safety Administration (FMCSA) rules.
Operating solely within a single state, never crossing state lines, and not furthering interstate commerce is “intrastate” transportation, governed by the state of operation.
Second, certain characteristics of the vehicle or load affect which vehicles must display identification. These characteristics include gross vehicle (or combination) weight/rating, number of passengers, or if the vehicle is transporting placardable hazardous materials.
Marking interstate vehicles
All vehicles defined as commercial motor vehicles in 390.5T and operating in interstate commerce must display the identification information according to 390.21T (for information on the marking of intermodal equipment, refer to Intermodal Equipment Marking).
The vehicle marking must show:
- The legal name or single trade name of the company operating the vehicle; and
- The motor carrier identification number, issued by the FMCSA, preceded by the letters “USDOT.”
There are no size and spacing requirements other than the marking is readily legible, during daylight hours, from a distance of 50 feet and the letters must contrast sharply in color with the background on which the letters are placed.
If a vehicle travels interstate and falls within any one of the four definitions of a CMV listed above, it must have the USDOT number and legal company name displayed on the vehicle as required by the FMCSA marking requirements in 49 CFR 390.21T. Both for-hire and private carriers must comply. Transporters of placardable amounts of hazardous materials must comply regardless of weight.
Short-term (30 days or less) rental/leased vehicles may be marked as described above or the vehicles may use the rental company's information along with the documentation requirements described in 390.21(e)T. (See DOT numbers for rented/leased vehicles for more information.)
For carriers without a US DOT number, a motor carrier identification number is obtained by filing Form MCSA-1.
The DOT Safety Regulations require new motor carriers to file Form MCSA-1 before beginning operations and all carriers to update their information at least every 24 months according to the schedule provided in 390.19 on Form MCS-150.
Marking intrastate vehicles. Vehicles operating solely within the boundaries of a single state and not furthering interstate commerce are subject to the identification rules of the state of operation. These rules vary widely from state to state.
In many states for-hire carriers, regardless of weight, must have operating authority and display prescribed identification on the vehicle. Other states require for-hire and private carriers meeting a defined weight threshold to display state prescribed identification.
States may choose to adopt the FMCSA marking rules and issue USDOT numbers to their intrastate carriers. This means intrastate only vehicles in these states must display a state issued USDOT number often followed by the two-letter state postal code.
Interstate and intrastate. Certain states require interstate carriers, also operating intrastate, to comply with both the FMCSA rules for interstate carriers and the state’s intrastate marking rules.
Motor carriers with a state-issued US DOT number later wishing to begin interstate operations must convert their number to a US DOT number.