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Analyzing USDOT Governance and Proper Counts

Anyone in the trucking or transportation industry will tell you that rules and regulations have been a long part of the landscape. Yet, when did it become this way? Certainly, long ago when trucking first came into being, it was sort of like the wild, wild west out there. Perhaps that is why the United States Department of Transportation was created. We bet you thought it was created a lot earlier than it was. In fact, the DOT was not created until Lyndon Baines Johnson was brought to office in 1966.

The original purpose of the DOT was to “create, develop, and coordinate policies to provide an efficient and economical national transportation system.” As the economy grew in the 60s, the federal government needed to create a cabinet-level position to help ensure the growing transportation sector of the United States remained safe, efficient, and adequate for the country’s needs.

But did you know that the idea for a national department of transportation actually originated 92 years before President Johnson actually created the agency? That’s right. Thomas Jefferson once recognized the need for a governmental department to regulate national transportation efforts when he referred to the “roads department.” Yet, it wouldn’t be until many years later that the roads department transformed into the Department of Transportation.

It has been since 1967 that the DOT has governed mass transit across the country. Today, the DOT incorporates more than just land travel. You will also find the Coast Guard, Federal Aviation Administration, Railroad Administration, Maritime Administration, Commercial Space Transportation, and the National Transportation Safety Board all under the DOT umbrella.

After the 9/11 terrorist attacks, Congress passed the Aviation and Transportation Security Act, which would eventually lead to the creation of the Department of Homeland Security. Today, the Coast Guard and Transportation Security Administration fall under the Department of Homeland Security, who’s job it is to monitor threats of terrorism within the United States.

Now that you know the history of the agency that governs the industry you operate in, now it’s time to learn more about that special number that identifies each truck driver and trucking company they work for: The ubiquitous USDOT number.

What is the USDOT Number?

Another agency that falls under the auspices of the DOT is the Federal Motor Carrier Safety Administration (FMCSA). All trucking companies must have an identifiable USDOT number registered through the FMCSA. The agency uses the number to track a fleet’s overall level of safety performance. If you are a trucking company operating in interstate commerce, you are required to have a USDOT number.

The USDOT number is also mandated by individual states. To-date, nearly 40 of them require truck drivers within their state to have a USDOT number. That is regardless of whether they are operating interstate commerce or not. Many new truck drivers probably wonder what exactly the USDOT number means. We are here to help.

As a matter of policy, the FMCSA assigns a unique USDOT number to each person or entity that registers with the agency. The USDOT number will be specific to the legal entity, or company, applying for it. Still, some trucking companies do have multiple USDOT numbers, which is not entirely unheard of. A single number for a single legal entity is not a hard and fast rule. Still, the FMCSA prefers that different aspects of an organization report up the line to a single USDOT number. And while multiple numbers are allowed in some instances, the agency does not allow multiple USDOT numbers to be used to help trucking companies avoid compliance, hide non-compliance, or hide a history of bad behavior.

And because a USDOT is a unique identifier, it cannot be transferred from one organization to another. And if a trucking company ends up being sold or merging with another company, a new entity must be created with its own USDOT number, otherwise they will not be allowed to continue running freight operations.

How the BASICs Tie In

Although the CSA program has gone through a couple convolutions since its inception, it is still around. Part of the CSA program are the BASICs. While the BASIC scores rely on inspections to determine whether a fleet is ready and where they rank in their peer group, there are two ranking factors that serve as outliers.

Both the Unsafe Driving and Crash Indicator BASICs take into consideration how many “at bats” the fleet has. But what does this actually mean? Basically, these two scoring mechanisms incorporate a formula that factors in how many vehicles the carrier has, as well as the number of miles traveled across the fleet. They do this to account for large trucking companies who may have twice the violations and crashes because they have twice the power units and drive twice the miles.

Trucking companies would do well to ensure their MCS-150 files are updated with the FMCSA so that they can be properly judged against their peers in the industry. And in cases where a motor carrier reduces their size, updates need to be provided quickly. If the FMCSA doesn’t have an accurate number of power units for your organization, your scores may be weighted improperly.

All of this is done through the Unified Carrier Registration system. This system uses a fleet’s MCS-150 power unit count as a starting point for determining their fee bracket. If a trucking company reports more vehicles, they will likely be slotted into a higher fee bracket. Being in different brackets means the difference between hundreds and tens of thousands of dollars in fees.

Keep Accurate Vehicle Counts

If there has been one takeaway from all this, it is to ensure you are keeping accurate vehicle counts in your fleet. If getting your vehicle counts right means the difference between fair and huge fees down the line, you need to be as accurate as possible. Still, many fleets may not know which vehicles and truck drivers they need to count.

For many fleets, assessing the truck driver count is the harder of the two tasks. If you look closely at the FMCSA regulations, they want a motor carrier’s truck drivers to be broken out by truck drivers who operate within state lines and those who operate from state to state. Once a fleet has broken out those numbers, then they need to isolate who operates within a 100 air-mile radius. When added up, these four metrics should add up to an accurate total number of truck drivers.

But it doesn’t end there. Once that number is totaled up, a motor carrier will need to create a separate count for the number of CDL truck drivers they have on staff. While this all may seem like a very onerous way of doing business, when you are dealing with government regulations, you have to make sure you know what is expected.

And if you have a problem figuring out something like truck driver counts, just take into consideration your average fleet workday. You don’t have to provide a hugely detailed analysis, but you must know the basic numbers. If you can provide an educated overview of your operation, you won’t have to worry about running into the wrong end of an audit.

Work Your Way Back

He best way to handle an accurate truck driver count is to work your way backwards. You want to start with the gross number of truck drivers that operate a vehicle on any given day. Then break that number down to those who stay within 100 air-miles of home base. The outside number you get out of that equation makes the difference.

Once you know the inter- versus intrastate breakdown, you will be able to provide an accurate number. And while counting power units may seem like an easier proposition then counting truck drivers, it does not come without its complications. It’s even harder when you are going by the guidelines outlined in the MCS-150 form.

Basically, a fleet’s vehicle count should be based on the number of commercial motor vehicles counted on the day the report is submitted. And for the purposes of reporting, a fleet needs to count vehicles that have been registered to the company or leased for more than 30 days in the last calendar year. Also keep in mind that for this count, there is no distinguishing between inter- and intrastate commercial motor vehicles. All must be counted.

The fact is the DOT and FMCSA are the principle factors in the lives of just about every trucking operator out there. So, why not be proactive and ensure you do everything you can to keep them happy and your trucking company humming?



from Quick Transport Solutions Trucking Blog https://ift.tt/2SShz7C

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