The practice for valid registrant-only companies – rental and leasing companies as well as leased owner-operators – to be issued such a number during the vehicle registration process was eliminated on September 1, and the registrant-only option on MCS-150 filing forms was removed September 15. Remaining active registrant-only DOT numbers are scheduled to be automatically removed on October 13.
The existence of these numbers had contributed to poor data quality in the Motor Carrier Management and Information System database, where inspectors somewhat regularly erroneously filed violations under carriers’ or equipment-providers’ registrant-only numbers rather than the correct operating authority. This allowed those violations to be left out of the CSA metric and the associated motor carrier to “evade enforcement,” FMCSA said, by flying under the agency’s radar.
“What we discovered was an accelerating trend of motor carriers registering for a registrant-only U.S. DOT number,” said FMCSA Transportation Specialist Steve Parker, of the Enforcement Division, for one of several reasons:
- By mistake – A carrier sees the vehicle registrant selection on an online or other filing form and thinks they’ve successfully filed for operating authority.
- By intent to evade – “A little more nefariously, they may be obtaining it because they’ve come to the realization that they can avoid enforcement in our Safety Measurement System,” said Parker.
Letting the number lapse into oblivion may not be, however, the only action necessary for carriers and equipment providers to take to maintain appropriate credentials. Beginning this week the agency has begun mailing the entire universe of registrant-only numbers notifying them of the elimination of the categorization. “If you’re an interstate carrier, and you’ve been one all along, then you need to make yourself an interstate carrier by updating your MCS-150 form,” Parker said.
Included in the mailing, he added, is a postage pre-paid, pre-populated form that carriers and leasing companies can send back with the appropriate business-categorization boxes checked.
“We did identify a small subset of the population that the FMCSA will be changing directly to interstate motor carriers from registrant only,” Parker said. The “pretty small group” was clearly involved primarily in transport, judging by FMCSA records.
For carriers and owner-operators who have only obtained the registrant-only DOT number within the past 18 months (anytime following March 1, 2011), “there was a small distinction in the letters,” Parker notes, indicating that changing status to interstate motor carrier would subject you to the new entrant program and a comprehensive new entrant audit. “For those who’d obtained a number … prior to March 1, 2011, they won’t go into the new entrant program,” he added. “A lot of folks won’t be affected by this at all. If you keep your U.S. DOT [operating authority] number active, you’ll be fine.”
Also for carriers operating intrastate, if your state requires an intrastate DOT number, you may need to file for the appropriate authority there.
For equipment and leasing companies, as well as truck dealers, FMCSA is exploring the potential for a special classification, still in vetting. Until (and if) that happens, Parker advised both short-term rental and long-term vehicle leasing providers who don’t know the DOT number and tax I.D. of the motor carrier responsible for safety in a particular vehicle at the time of registration to file as interstate motor carriers themselves, indicating on the form that the safety-responsible motor carrier would be expected to change in the next year.
Combined with efforts at educating law enforcement to determine the correct DOT number to record violations under during inspections of rental/lease vehicles, FMCSA hopes the registrant-only elimination may help bring under control the raft of DataQs challenges from the leasing and rental community to violations incorrectly assigned to their operating authority.
