Is Your Pickup Truck a CMV?

This may come as a surprise, but your company pickup truck might be defined as a commercial motor vehicle (CMV) under the Federal Motor Carrier Safety Regulations (FMCSRs).

You might think that since you are not hauling cargo with the truck 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 hazardous materials.

The trailer could be the key

Even if the trailer is a small utility model, if it places you at 10,001 pounds or greater you are operating a CMV.

If the vehicle only meets the definition when pulling a trailer, you will only need to observe the safety regulations on those days it meets the definition. This includes applying USDOT markings on the side of the truck, possibly stopping at roadside inspection stations, etc.

What if it’s a CMV?

When you determine 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 having 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.

If you aren’t sure about your compliance obligations, a J. J. Keller compliance specialist can help you evaluate your operation for risk with a light and medium duty fleet assessment created by our regulatory experts. Fill out the form below and a specialist will call you. Or call 855-693-5338 to speak with a specialist now.