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Features: Making Sure Your Rig Is Legal
Recently, federal and state agencies have been increasing the number of traffic stops on pick up trucks and pick up truck-trailer combinations.
Pick up trucks used strictly for personal non-business or recreational use — such as pulling an RV or personal-use trailer — are not subject to federal trucking authority. But farriers using pick up truck with a farrier body or who use a vehicle to pull a shoeing trailer may have to obtain state or federal trucking authority.
You should take some time to figure out if you need to obtain either kind of certification.
Where To Start
First, find the registered gross vehicle weight rating (GVWR) of your pick up truck or vehicle-and-trailer combination. The GVWR is not the actual weight of the truck. It is the maximum allowable total mass of the vehicle or vehicle-trailer combination when loaded, including the weight of the vehicle itself plus fuel, passengers, cargo, etc. The GVWR can be located on your vehicle door jam or trailer tongue. It may also be found on your vehicle or trailer registration. Let’s look at a couple of examples.
Example 1. The registration for your 3/4-ton truck lists a GVWR of 8,600 pounds.
Example 2. The registration for your 1/2-ton truck has a GVWR of 6,700 and you pull a trailer with a GVWR of 6,000 pounds. Your total combined GVWR is 12,700 pounds.
Next, determine if you travel intrastate or interstate in your hoof-care business. Farriers who operate entirely within a single state are known as intrastate carriers. If you do not cross state lines, then you do not have to worry about obtaining federal operating authority or getting a U.S. Department of Transportation number. As a farrier, you are required, however, to comply with your own state’s operating authority and insurance requirements.
Farriers who operate their vehicles outside their own state or cross state lines are known as interstate carriers. If you are an interstate carrier, you are required to obtain federal operating authority and get a U.S. DOT number if your pick up truck or vehicle-and-farrier-trailer combination has a GVWR of 10,001 pounds or greater.
Schedule A Weigh-In
The next step is to determine the actual weight of your farrier vehicle when it is fully loaded, or of the loaded vehicle with the loaded trailer attached. Find a local public scale and get weighed. This may cost you about $5. Get a receipt of your actual weight, as you may be able to use this for a state variance.
Example 3. Let’s say your 3/4-ton pick up with a GVWR of 8,600 pounds with a farrier body and equipment weighs less than 8,600 pounds. You do not need federal or state authority.
Example 4. Your 3/4-ton pick up with a GVWR of 8,600 pounds with a farrier body and equipment weighs over 8,600 pounds but less than 10,001 pounds. You do not need federal or state authority; however, you are operating in excess of your vehicle’s maximum allowable load. If stopped, you can be ticketed.
Example 5. Your 3/4-ton pick-up with a GVWR of 8,600 pounds with a farrier body and equipment weighs over 10,001 pounds. You will need federal authority to travel across state lines, but may not need state authority if you stay within your own state.
Example 6. Your vehicle and farrier trailer have a GVWR of 12,700 pounds together. Regardless of the weight, you will need federal authority to travel across state lines but may not need state authority if you stay within your own state.
Checking State Rules
To determine your own state’s maximum GVWR allowance, contact your local department of motor vehicles, go online to your state’s department of motor vehicles, or visit www.fhwa.dot.gov/webstate.
States has different allowable GVWRs. Some follow the federal authority GVWR of 10,001 pounds and others have higher allowable weights. For example, Michigan has an intrastate allowance of 12,000 pounds. That means Michigan farriers do not need special state authority if they stay within state lines and their farrier vehicle or vehicle and farrier trailer has a GVWR of less than 12,000 pounds.
If you do not cross state lines but have a GVWR that is over your state limit, then you will have to apply for your state’s intrastate motor carrier authority.
If you decide you want to cross state lines, you will have to apply for federal authority and a U.S. DOT number if your GVWR is greater than 10,001 pounds. New York has an intrastate allowance of 10,001 pounds. This means you do not need any special state authority if you stay in New York, so long as your GVWR is less than 10,001 pounds.
That 10,001-pound limit can be difficult to stay under for most typical 1/2-ton vehicles used for pulling a farrier trailer or that are equipped with a farrier truck body.
If at all possible, I’d advise staying under your state’s GVWR, as well as under 10,001 pounds if you travel across state lines. If you make some adjustments, many states will allow you to re-register your trailers at a lower GVWR, however you’ll still have to be sure not to carry a load in excess of your GVWR.
Rules And Regulations
It’s not that it’s difficult or expensive to obtain a U.S. DOT number or federal trucking authority. It is free and can be done online in minutes. However, the rules and regulations that go along with it can be overwhelming. For example:
- Your U.S. DOT number must appear on both sides of your vehicle.
- Your legal business name also needs to appear on your vehicle above your U.S. DOT number and the letters all need to be 2 inches or greater.
- You are considered a commercial motor vehicle and need to stop at all open weighing stations (FMCA 390.5).
- You are required to keep maintenance records at your place of business (FMCA 396.3).
- You will need to keep a Record of Duty Status or logbook whenever you travel outside a 150-air-mile circle from your home or business location (FMCA 395.8).
- You are required to have motor vehicle insurance on your vehicle and trailer.
- You are required to have a U.S. DOT Medical Exam Certificate (FMCA 391.43).
- Fire extinguishers need to be mounted in the cab of the vehicle; spare fuses and light bulbs must be carried for every light on your vehicle(s). The only exception is headlights.
- At least three safety triangles need to be carried.
- All tires and vehicle lighting devices and reflectors need to meet federal wiring and location specifications. This is not a problem for commercially purchased vehicles, but may present an issue for homemade trailers.
On the positive side, farriers can carry propane tanks without a hazardous material license and placards under the Materials of Trade Exception (FMCA Part 173.6). They do need to be secured and tied down to meet this requirement.
Not complying with these rules can be expensive. Fines for various violations of federal authority laws can range from a few hundred to several thousand dollars.
Further regulations can be viewed at the Federal Motor Carrier Safety Administration Web site (www.fmcsa.dot.gov) and your local state motor vehicle Web site under truck and motor carrier rules and regulations.
