If you operate in more than one state (interstate) of if your state has adopted the Federal Motor Carrier Regulations for in state (intrastate) operations, then the following apply to your business:
A Commercial Motor Carrier is any business that transports hazardous materials, that operates a vehicle whose weight is over 10,000 lbs. or carries more than eight passengers for compensation or fifteen passengers not for compensation. It does not matter that you do not haul freight or deliver materials. The only criteria are that the truck is being used in a commercial business and that it meets one of these other requirements. Just because a driver is not required to have a CDL license does not mean that the vehicle and the company are not subject to the FMCSA regulations.
If you are operating medium duty trucks you need to determine if your vehicles exceed the 10,000lb. threshold. Examine the rating on the plate from the manufacturer. This is the Gross Vehicle Weight Rating or GVWR. Add to that the GVWR of any towed trailer to get the Gross Combination Weight Rating or GCWR. If these do not exceed 10,000 lbs. you must then check the actual total loaded weight at a scales to be certain that you do not exceed 10,000lbs. If either of these numbers place you above the threshold then you are a Commercial Motor Carrier and the truck is a Commercial Motor Vehicle.
This article examines the FCMSA requirements for companies and drivers of vehicles that fall into the 10,000 to 26,000 lb. ranges and do not otherwise meet the requirements for a CDL licensed driver. The drivers of these vehicles are not required to hold a CDL but the company and driver are required to comply with the regulations. You need to obtain a copy of the Federal Motor Carrier Safety Regulations Handbook and a copy should be carried in each vehicle. This article covers a few of the major issues but is not intended to be a complete listing of all the requirements.
If you cross state lines you are required to register with the Department of Transportation and obtain a DOT number. This is the only difference between the requirements for interstate and intrastate operations. Companies that operate solely within one state are not required to obtain a DOT number.
