Are your employees subject to the US Department of Transportation (DOT) requirements for operating commercial vehicles? Well, if you have a business that employs people who operate vehicles with a Gross Vehicle Weight Rating (GVWR) over 26,000 pounds, then the answer is pretty clear — yes.
It’s when you get into the realm of selling and servicing medium and heavy duty trucks, vehicles with a GVWR over 10,000 pounds, where the water may get a little muddy.
Hopefully by the end of this article you will have a better understanding of exactly where at your shop, and to whom, these requirements apply.
Let’s start at the beginning. Any time an employee operates a vehicle over public roadways for commerce and the GVWR is over 10,000 pounds, certain DOT requirements apply.
To whom in your facility does that refer?
For starters, it includes service technicians test driving a truck during the diagnostic process or resetting the vehicle’s computer. It also includes your sales associates taking a customer on a test drive and they’re behind the wheel. Remember the reason for these employees operating these vehicles is in the end to make money — commerce.
Fortunately these folks do not need a CDL to operate these vehicles, but there are certain requirements that nonetheless have to be met.
Here’s a quick overview of the requirements:
- Drivers must have a DOT physical and, if they pass, they will receive a medical card. The card must be on the driver at all times while operating these types of vehicles. This physical is required to be conducted every two years.
- The vehicle must be inspected annually.
- The equipment must be in proper working order.
- A driver qualification file must be kept. This file must include the application for hire and the medical card.
- Log books must be kept. However if the vehicle travels within a 150-mile miles of the business, the log book is not needed so long as:
- The employee returns to work within 12 consecutive working hours,
- The employee doesn’t drive more than 11 hours that day,
- The employee has at least ten hours off between consecutive 12 hour shifts, and
- The employee is maintaining an accurate time card
- If the employee is operating a company owned vehicle:
- The vehicle must have the company’s markings on it,
- There must be a secured and accessible fire extinguisher,
- Maintenance records must be maintained,
- The company must maintain at least $1 million of insurance if vehicles are being hauled, and
- If your employee travels over state lines in one of these vehicles, the vehicle must be equipped with the companies dot number.
The only time an employee would be exempt is if they are operating that vehicle on your facility’s lot. An example would be an employee operating a plow truck during snow removal.