A = A Single Number. As a matter of policy, the FMCSA assigns a unique USDOT number to each person or entity that registers. A one-to-one relationship should exist between a legal entity and a USDOT number, but the FMCSA’s position is not hard and fast regarding this stance. Some companies do have multiple USDOT numbers, but it is the FMCSA’s preference that divisions and terminals report up through the corporate USDOT number. The agency does prohibit companies from obtaining or keeping multiple USDOT numbers to avoid compliance, mask or conceal non-compliance, or hide a history of non-compliance. The unique identifier policy is also the reason that USDOT numbers are not transferable. When, as a result of a sale or merger, a new entity is created (as identified by a new FEIN), the new entity will also need a new USDOT number to continue transportation operations.
B = BASICs Influencer. Five of the seven Compliance, Safety, Accountability (CSA) BASICs rely solely on the number of relevant inspections within the BASIC to determine a carrier’s scoring and resulting peer group ranking. However, two of the BASICs, Unsafe Driving and Crash Indicator, also take into consideration how many “at bats” the carrier has. These two BASICs have a utilization factor that incorporates the number of power units and the vehicle miles traveled into the methodology formulas. It stands to reason that if all things are equal, a carrier that has twice as many powered vehicles and travels twice as many miles in a year will have twice the number of accidents and unsafe driving violations. Because of this factor, carriers that are growing should/must update their MCS-150 more often than every other year so they can be properly compared with their peers.
When carriers are reducing their size, based on vehicle counts, it’s as important to provide updates more often than biennially. This is because the Unified Carrier Registration (UCR) plan uses a carrier’s MCS-150 vehicle count as the starting point to determine the fee bracket. The more vehicles reported, the greater the likelihood of being in a higher fee bracket. Changing from one bracket to the next can mean the difference of hundreds, thousands, or tens of thousands of dollars that the carrier pays.
C = Counting Vehicles and Drivers. As stated, getting the counts right can make a difference in a carrier’s CSA peer group and the fee bracket for UCR. But what vehicles and drivers should be counted? At first glance, the driver count seems the more difficult of the two to calculate. The FMCSA wants the drivers broken out by the number that operate strictly intrastate (within one state) and the number that operate interstate (in multiple states). The agency then wants those totals broken down into drivers that operate exclusively within a 100 air-mile radius and drivers that work outside of the 100 air-mile radius. Those four totals need to add up to the total number of drivers.
From the total number of drivers, a separate count is needed for the number of CDL drivers. At this point, it seems almost as bad as doing your own taxes on the long form, but it needn’t be. The driver counts are based on an average workday. The FMCSA is not expecting carriers to break out the spreadsheets and pivot tables. They are looking for an educated overview of the operation. The data is used more from a census point of view rather than from an enforcement stance. Your driver count does not enter into the calculation of any safety scores.
The exercise is completed more easily when you work it out backwards. Start with the number of drivers that operate CMVs on any given (average) day. Break that count into drivers that are likely to stay within 100 air-miles (not necessarily qualifying for the short-haul exception). The outside the air-mile number is then the difference from the total. Break those numbers out into the average that run intrastate versus interstate. The interstate versus intrastate breakdown is most important if taking advantage of the often more permissive intrastate rules.
Counting vehicles seems like it would be easier than drivers, and it might be if the count also used the “on an average workday” instructions. But, the MCS-150 instructions are a bit confusing regarding which vehicles to count. Thankfully, MCSA-1 will eventually replace the MCS-150. The MCSA-1 is much clearer and provides exactly what the FMCSA is looking for.
The vehicle count is based on the number of vehicles, on the day the form is submitted, that have a weight of 10,001 pounds or more (rated, actual or used in combination) and are operating under the carrier’s USDOT number. For the purpose of the operation, count vehicles that are registered to the carrier or have been leased for more than 30 days in the last year. On the MCS-150 there is no distinction between inter- and intrastate vehicles. If the vehicle meets the description above, it should be counted.
The count does need to be broken down by the type of vehicle and whether the vehicle is owned by the carrier or leased. Leased vehicles are subdivided by whether the lease agreement is a term or a trip lease. The vehicle types are relatively straight forward. But one question that is often asked in this area is how to count pickup style trucks. Pickups are considered straight trucks.
The old adage goes, if all else fails, read the directions. That’s good advice when registering or updating your registration with the FMCSA. On paper, the MCS-150 is three pages, but the form comes with eight pages of instructions and examples. For the most part, the instructions are simple and written in plain English. As with taxes, filers have two additional options: filing electronically or hiring a professional. The electronic versions have some help available through the process, which makes it a little easier. Since professionals are familiar with the process, there should be no guessing or headaches for those who choose this option.
By Wayne Schooling
Posted in: Wayne's World
Posted in: Wayne's World
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Wayne Schooling has been in the transportation business since 1962. Starting out as a driver, Wayne later made the switch to management. Over the years, he has accumulated 22 various awards and honors, been involved with 6 professional affiliations, has spoken at several lectures, and earned 3 professional diplomas. Wayne, who has written for 10-4 Magazine since 1994, is currently President Emeritus of the NorthAmerican Transportation Association (NTA).
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