DOT Compliance Basics Checklist
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Commercial Motor Vehicle (CMV) Operators participating in INTERstate commerce must comply with the Federal Motor Carrier Safety Regulations (FMCSRs).
Operators of CMVs participating in INTRAstate commerce will need to comply with Drug and Alcohol and Commercial Driver’s License (CDL) rules, if operating CDL vehicles (vehicles with a gross vehicle weight or rating of 26,001 pounds or more; or a gross combined actual or rated weight of 26,001 pounds or more when pulling a trailer weighing or rated at 10,001 pounds or more; rated for more than 15 passengers including the driver, or hauling any placardable hazmat).
If operating intrastate-only CDL and non-CDL vehicles, they may have to comply with other safety regulations since it’s likely that their state has adopted a portion or all of the FMCSRs!
The following questions will help you determine whether your vehicles meet one of the definitions of “CMV” and which FMCSRs need to be implemented.
Weight Rating 10,001 Pounds
- Do any of your vehicles have a gross vehicle weight, gross combination weight, gross vehicle weight rating, or gross combination weight rating of 10,001 or more pounds? (For vehicles operating in intrastate commerce-only not hauling placardable hazmat, you must confirm if it is a for-hire or private operation, the weight or passenger rating at which the state’s adoption of the safety regulations apply, and any differences between the state and federal safety rules to know the carrier’s compliance requirements.)
- Are any of your vehicles required to be placarded for hazardous materials, regardless of vehicle size or weight?
- Are any of your vehicles designed to transport more than 8 (for compensation) or more than 15 (both ratings include the driver)?
If the answer is YES to any of these questions, you’re required to do the following:
| Requirement | Solution(s) |
|---|---|
| Comply with the current FMCSR 390.3(e)(1). | |
| Maintain driver qualification records for each driver 391.51. |
|
| Complete a pre-trip (392.7) before operating a CMV, and when finished using the vehicle for the day, conduct a post-trip (396.11) inspection, and a DVIR if there is a safety defect or one likely to lead to a breakdown. | |
| Maintain Safety Performance History information on your CMV drivers 391.53. | |
| Establish a routine, ongoing vehicle maintenance program 396.3. | Vehicle Maintenance Packets (1758) |
| Document each driver’s hours of service 395.8. Note: Drivers who meet a short-haul exemption in 395.1(e) may not need to complete a log grid, but still must track their hours of service! | |
| Maintain required information for each accident in an accident register 390.15. | |
| Mark the vehicle with name and DOT# 390.21. | |
| Ensure driver compliance with FMCSRs 390.3(e)(2). | FMCSR Pocketbook with driver’s receipt page (347) |
| Document periodic vehicle inspections performed at least annually 396.17. | |
| Comply with 393, Subpart I Protection Against Shifting and Falling Cargo. |
Weight Rating 26,001 Pounds
- Do any of your vehicles have a gross vehicle weight or rating of 26,001 pounds or more, or a gross combined actual or rated weight of 26,001 pounds or more when pulling a trailer weighing or rated at 10,001 pounds or more?
- Are any of your vehicles required to be placarded for hazardous materials, regardless of rated weight or passenger rating?
- Are any of your vehicles designed to transport more than 15 passengers?
If the answer is YES to any of these questions, you’re required to implement the items above as well as do the following:
| Requirement | Solution(s) |
|---|---|
| Implement an Drug & Testing Program 382. | |
| Ensure driver-supervisors receive reasonable suspicion training 382.603. | Reasonable Suspicion Training (71293) |
| Ensure each driver possesses a CDL or CLP (commercial learner’s permit) 383.23. | |
| Conduct Hazardous Materials Training as needed. |
Also note: Use real accident and roadside data that you can pull in directly from the Safety Measurement System (SMS) to generate a safety rating and determine the likelihood of an FMCSA intervention. Know when and how to implement necessary corrective actions. J. J. Keller’s online Fleet Management Advisor - FleetMentor® Service.
Interstate vs. Intrastate Commerce
The Federal Motor Carrier Safety Administration (FMCSA) defines interstate commerce in Section 390.5 of the Federal Motor Carrier Safety Regulations. This definition applies to drivers and vehicles that:
- Cross state lines;
- Travel over the border into and/or from Canada or Mexico; and
- Travel between two places within the same state, but the cargo/passengers are part of a trip that began or will end in another state or foreign country.
Intrastate commerce includes drivers and vehicles that remain exclusively within a state. Travel does not include crossing state lines, travel over the border into and/or from Canada or Mexico, or transporting cargo/passengers that originated or are destined for another state or country.
For more information on the differences between the two and the compliance aspects of each get our Interstate vs Intrastate: Understanding Compliance Requirements Whitepaper.