Unified Registration System: Clients with Trucks Must Comply
by Tommy Ruke
Do you know what a “motor carrier” is? More important, do you know how your definition compares to that of the Federal Motor Carrier Safety Administration (FMCSA)?
One thing’s for sure: It’s not your father’s trucker anymore.
When most insurance agents and carriers think about insuring motor carriers, what comes to mind is probably the for-hire motor carrier that operates a big 18-wheel rig: a tractor with three axles and 10 tires pulling a trailer with two axles and 10 wheels, driven by an over-the-road driver.
But the FMCSA defines a motor carrier as any business that uses a unit or a combination of units with a gross vehicle weight (GVW) of 10,001 pounds or larger and uses the unit in interstate commerce. Yes—that means a contractor with a Ford F-350 pickup who stores tools and materials in their bed, sports their name on the side of the truck and crosses state lines is a motor carrier according to the FMCSA.
And the new Unified Registration System (URS), effective October 2016, mandates stricter enforcement of requirements that every “motor carrier” maintain a DOT number, pay the required fees to the Unified Carrier Registration—and much more.
What does this mean for your commercial clients that drive trucks?
Rules of the Road
First, all motor carriers must obtain an identification number from the FMCSA—commonly referred to as a Department of Transportation (DOT) number. The business must display their number on the side of their vehicle. If they do not, law enforcement can stop them, fine them and even restrict their operations until they obtain the number. The severity of the consequences depends on how aggressive the enforcement officer wants to be when stopping and inspecting motor carriers.
To meet the registration requirement, motor carriers must visit the FMCSA online and use the URS/MCSA-1 portal. All businesses with units that have a GVW of 10,001 and cross state lines must register, obtain a DOT number, pay a fee to the Unified Carrier Registration and operate within all FMCSA rules and regulations.
For example, drivers must be at least 21 years of age and carry proof that they have had a DOT medical exam if unit is driven across state lines. If the driver plans to drive the unit more than 100 miles from where they started, they must also maintain a log of their driving time. The driver cannot drive more than 11 hours or work more than 14 hours straight, after which they must stop driving for 10 hours.
If you’ve been providing insurance to traditional for-hire interstate motor carriers, not much has changed. The FMCSA requires your client to obtain and update their registration every two years, or the government will render them “out of service” for failing to meet the biannual information update requirement. This is true for all holders of interstate DOT numbers. Note that 23 states also require businesses with units that do not cross state lines to have an intrastate DOT number.
But beyond the long-recognized for-hire motor carrier operating an 18-wheeler in interstate commerce, every business that has a unit with a GVW of 10,001 or larger and operates it across state lines for any business purpose—including lawn maintenance, welding, car dealing, boat sales and service, delivery and more—must also provide information to register and obtain a DOT number and update their information biannually at a minimum or every time their operation changes. Required information includes:
· Physical address
· Mailing address
· Contact information
· Number of units in operation
· Number of drivers in operation
· Type of cargo
· Nature of cargo
· If the cargo is hazardous, classification of the hazardous commodity with increased financial responsibility requirements
The Public Eye
The FMCSA provides this information for public view through its Snapshot link, which displays not only the information the business furnishes, but also information enforcement officers record when doing on-road inspections or investigating any crashes the business has experienced over the past two years. The enforcement officer’s information includes but is not limited to:
· The number of inspections a motor carrier had in the past 24 months.
· Whether any of the inspections prompted the FMCSA to render the unit out of service.
· When a unit cannot be moved due to an issue such as a bald tire.
· Whether a driver has driven over the 11-hour limit or neglected to complete the 10-hour break afterwards.
· Details regarding crashes that caused a fatality or an injury that required medical attention away from the crash site, or required a tow for a vehicle.
If you have been providing services to users of 18-wheelers, you know this information does not reflect who caused the crashes. That means even if the motor carrier was not at fault, the FMCSA still reports the crash in its record of public information. If you have motor carriers who also operate in Canada, the public record also incorporates inspections and crashes while there.
Lastly, a safety rating shows the date of a motor carrier’s on-site inspection, as well as its rating—Satisfactory, Conditional, Unsatisfactory or No Rating—and any other on-site inspection results that did not result in a rating.
An insurance agent who has not provided insurance to businesses that have DOT numbers may not understand that when they send an application to an insurance provider, the insurer compares the information furnished on the application to the public information the business provides to the government. This is one of the basic rules in providing insurance to motor carriers: The application must match the available public information.
Agents should start the conversation with the insured at least 60 days ahead of when they need coverage. This way, the insured can update their information to ensure the public information reflects the information the insurer receives. If not, the agent and client must prepare a narrative of why the public information does not match the information on the application. If the underwriter does not feel comfortable about the accuracy of the information, they will not typically proceed with the underwriting and, in most cases, will not offer a quote.
For more information about insuring clients who operate trucks, check out the Motor Carrier Insurance Education Foundation (MCIEF), which specializes in helping agents, brokers and insurance carriers build valuable relationships with their clients who are motor carriers through education and training. Want to stay ahead of your competition? Sign up to attend free trucking webinars every second Thursday of the month.