1. “We are not a trucking company”
but Why DOT regulations might apply to you

2. We call it “the dot,” but we mean…
The Federal Motor Carrier Safety Administration
Write and enforce federal truck and bus safety regulations
Applies to any organization operating commercial motor vehicles in interstate commerce

3. We call it “the dot,” but we mean…
State commercial motor vehicle safety agencies
Commissions
Dept. of Public Safety or Transportation
Highway patrol
Enforces inter- and intrastate CMVs

4. We call it “the dot,” but we mean…
Pipeline and Hazardous Materials Safety Administration
Hazmat transportation regulations
Oil and gas pipelines
Oversight of any organization shipping or transporting hazardous materials

5. Federal and state truck regulations
The weight thresholds

6. Difference in actual and rated weight
Gross Vehicle Weight (GVW)
The actual weight of a single vehicle including cargo and people
GVW varies
Vehicles are trucks and trailers

7. Difference in actual and rated weight
Gross Vehicle Weight Rating (GVWR)
The maximum a single vehicle can weigh
Fixed value set by the manufacturer

8. Difference in actual and rated weight
Gross Vehicle Weight Rating (GVWR)
The maximum a single vehicle can weigh
Fixed value set by the manufacturer

9. Difference in actual and rated weight
Gross Combination Weight (GCW)
The actual weight of a truck and trailer combined – varies

10. Difference in actual and rated weight
Gross Combination Weight Rating (GCWR)
The maximum a combination can weigh – values set by manufacturers

11. Difference in actual and rated weight
Gross Combination Weight Rating (GCWR)
15,200 pounds

12. Which vehicles are regulated?
Commercial Motor Vehicles (CMVs) are regulated –
Federal definitions
CDL required –
Single truck greater than 26,000 pounds GVW or GVWR
Combination greater than 26,000 pounds GCW or GCWR, when trailer is greater than 10,000 pounds
More than 15 passengers, including driver
Hazmat requiring placards
Inter- or intrastate

13. Which vehicles are regulated?
Commercial Motor Vehicles (CMVs) are regulated –
Federal definitions
Part 390 General Regulations, parts –
Greater than 10,000 pounds GVW, GVWR, GCW, or GCWR
More than 8 passengers for compensation, including driver
More than 15 passengers not for compensation, including driver
Hazmat requiring placards
Interstate only

14. State definitions
Each state defines what they consider a CMV for intrastate commerce
Some states use the federal part 390 definition – 10,001 pounds and greater
Some use the CDL definition in part 383 – 26,001 pounds and greater
Still others use a different weight threshold – AZ says a CMV is 18,001 pounds and greater
Part 350 directs states to set a minimum threshold of 26,001 pounds

15. State definitions
Each state also has their own CMV regulations for intrastate commerce
Most adopt the FMCSRs as state regulations
CMVs that require a CDL are subject to all regulations regardless of location or use

16. CDL example
GVWR 13,000 pounds

17. CDL example
GVWR 13,000 pounds
GVWR 7000 pounds
GCWR 20,000 pounds

18. CDL example
GVWR 13,000 pounds

19. CDL example
GVWR 12,000 pounds
GVWR 13,000 pounds
GCWR 25,000 pounds

20. CDL example
GVWR 13,500 pounds
GVWR 13,000 pounds
GCWR 26,500 pounds

21. CDL example GVWR 13,500 pounds GVWR 13,000 pounds
Towed unit greater than 10,000 pounds

22. CDL example GVWR 13,500 pounds GVWR 13,000 pounds
Class A CDL required!

23. CMVs are subject to roadside inspection –
I have cmvs – now what?
CMVs are subject to roadside inspection –
Company must have an active USDOT number
Vehicles must meet standards
Drivers must be qualified and within hours of service
Results affect company’s standing with FMCSA and state agencies

24. Company is subject to onsite compliance reviews –
I have cmvs – now what?
Company is subject to onsite compliance reviews –
Company structure, registration with the state, and annual revenue
Policies and procedures
Driver qualification files
Drug and alcohol testing, if applicable
Hours of service
Vehicle maintenance files

25. Hazmat regulations
Are we regulated?

26. What is a hazardous material?
The PHMSA definition:
Hazardous material means a substance or material that the Secretary of Transportation has determined is capable of posing an unreasonable risk to health, safety, and property when transported in commerce…

27. Basics of the rules The Hazardous Materials Regulations exist to:
Ensure manufacturers and/or shippers package the material in containers strong enough to withstand normal transportation and common accidents
Ensure everyone involved in the transportation process knows of the presence of a hazardous material
Ensure the material is properly loaded depending on mode
Ensure first responders properly react to incidents

28. The hazmat table

29. A common fumigant in the table…

30. A division 4.3 material – dangerous when wet
Aluminum phosphide
A division 4.3 material – dangerous when wet
Packing group 1 – high danger
Available exceptions?
Small quantities for highway – not available for 4.3, PG I (173.4)
Materials of Trade – not available for 4.3, PG I (173.6)
Placard exception for certain materials less than 1001 pounds – not available for 4.3 ( )

31. Aluminum phosphide Available exceptions?
DOT Special Permit – exempts specific materials from the placard requirement:
Aluminum Phosphide – 4.3
Aluminum Phosphide Pesticides – 6.1
Magnesium Phosphide – 4.3

32. Exempt from placard requirement only
Aluminum phosphide
Exempt from placard requirement only
Specific types of packages
Quantity limitations
3.3 lbs.
3.3 lbs.
3.3 lbs.
Each canister
46.3 lbs. total

33. Other hazmat rules apply:
Aluminum phosphide
Other hazmat rules apply:
Hazmat employee training
Shipping papers – in transit and retention

34. Sulfuryl fluoride - vikane
Division 2.3 – poison gas, inhalation hazard, Zone D
Subject to all hazmat regulations –
Including placards for any amount transported

35. summary
Are you subject to motor carrier regulations because of vehicle weights and/or crossing state lines?
Greater than 10,000 pounds single or combination driving across state lines
Greater than your state’s definition of a CMV without crossing state lines

36. summary
Are you subject to PHMSA hazmat regulations because of materials transported?
Material is in the Table of Hazardous Materials in

37. Questions?

38. Call the DOT expert…
Thank you!
Please contact Chris Freedom or Randy Gafford for additional support regarding anything DOT or Driver Safety related.
Eos SAFE