Hello all, first post to HEF. I have a newly started business doing field service work for a local construction and road building contractor. I am looking for input from other independent contractors on how you handle DOT compliance as far as driver qualification file and who manages your drug and alcohol program. I have no employees and operate one service truck at 33k GVW.
While some of this is federal I believe alot of it depends on your state. I'm in Washington and run a KW T600 service truck and have no employee's. A number of years ago I contacted a State Patrol trooper in the commercial division and spent some time with him going over this same thing. He called down to Olympia and after a few questions I was told that all I have to do is make sure I get an annual inspection on my truck. I don't cross state lines and I don't haul anything for profit so I'm not required to do any bi-annual reports or submit anything to the utilities commission. Being self employed with no employees I'm not required to enroll in the drug testing pool. I still get all kinds of emails telling me I have to do all this but I just ignore them. They are all from 3rd party companies who are trying to make money on the confusion created by all the new laws. I would suggest you go to your DOT office and contact them, they will be able to help answer your questions.
What I hate, and it applies to a lot of stuff, is when you talk to someone in the government, police or otherwise, and they give you what they think is the answer, but they are not even close. A lot of guys at work have started carrying a paper copy of the rules for moving equipment, tie downs, D boards, flags. This time of year, I like to cross chain equipment because the deck is slippery. Some companies require it in their safety manual, we don't. Was stopped commercial vehicle enforcement once and the guy was going to fine me for not cross chaining. Even gave the number of the law. I pulled the book out, and asked him to find it, and there was no such thing. Our safety consultant ...... Took me years to find a bucket for my head that I don't mind wearing all day. She tells me that the provincial requirement says I can't wear a welders helmet if I'm not a welder. No such law. Do your home work
From what I’ve seen in the service truck industry, is they are so far outside the realm of what the motor carrier laws were written for and there are no clear answers on how we should be in “compliance.” Simply put, we just don’t fit into the nice neat box of the trucking industry but are still forced to comply.
I basically did filled out the paperwork to get my dot number and then I’ve ignored the 6 emails a day I get telling me I need to pay such and such to get my compliance for traveling east on a Monday morning when the wind is out of the northwest. I agree. Service truck operators seem to fall through the cracks. When I worked at the dealer we had questions about hours of service, etc. and running a log. It was common to travel 100+ miles and then work x amount of hours which technically put us over hours of service when in actuality we hadn’t been driving all those hours. There were plenty of blank stares and “ I’ll check into that and get back to you “. Never did get an answer.
Any hours worked-in shop or driving all counts as on duty-There is personal conveyance for over run on hours. Basically a service truck falls under the same rules for a tow truck. I only fill out a log when I run 100 miles as the crows fly. It's considered a fixed load-but dot can weigh it if they want and still can't go over gvw. Now if you cross state lines with a commercial vehicle and buy fuel that's another story. Your into IFTA.
The biggest thing I've heard of is a service truck pulling a trailer. The wrench found out he had to have a Class A license for that. The only guys that I've heard get hit on hours of service was some years ago over in Western States Cat Territory where they were crossing state lines all the time. They were concerned for a bit and then it just seemed to go away as far as I know. Maybe someone in Idaho might know what is going on there. All the diesel service trucks at all the dealers that I worked at had that IFTA sticker.
I don’t have an IFTA sticker and I don’t believe my dealer trucks had them either. I read up on it and I understood it that I was exempt due to miles and weight?
I don’t have an IFTA either, I do have an intrastate fuel permit which I had to have in Indiana to even register my truck and get plates. I guess the only thing I’m concerned about is the federal requirement for CDL holders to participate in a random drug and alcohol program which also requires a third party manager of the program.
Do you guys have to buy fuel in every state you travel to? Been a while, but I remember in my trucking days. Based on miles you run in a province, you have to buy fuel there. If I left my home province full of fuel, and went to Ontario, I would fuel in Quebec on the way back to New Brunswick. Then say I delivered my load in Nova Scotia, and went back to Ontario, I would fuel up once I crossed out of Quebec. I forget how it worked, based on miles in each province, you had to get a percentage of fuel there or you would get a bill at the end of the year for the fuel tax you should have paid. For trucking, not personal travel.
You aren’t required to buy fuel there but if you have an IRP or IFTA you have to keep record of the miles you drive in each state so that no matter where you buy your fuel, each state gets their share of the fuel tax based on the mileage you’ve driven there.
Prorated plates/Interstate road miles have to be filled out on trip envelope and miles documented at state lines. Intrastate does not require road miles documented. Company tow truck is prorated to run all 48.
Ahart, Unless I missed it, will you be traveling across state lines? What year is your truck? If you can stay under 12 hours and 150 airmile radius, you can make compliance fairly straightforward. Nobody has mentioned it yet, but you need a daily vehicle inspection report with your signature. Those have to be kept for 90 days. Then, you can toss them. If you do your own annual vehicle inspection, you will need a 396.17 document to prove that you are qualified. I can send you the one I use. I got audited one time and have to supply forms for every technician that ever did an inspection on one of my trucks. Same with the qualified brake inspector qualification form under 396.25. In my 35 years of trucking, I’ve only had to supply a 396.26 form once to the DOT. That was at a chicken coop in Morton. I was on a field call. The commercial vehicle enforcement officer didn’t believe I was qualified to change a slack adjuster because of how young I looked at the time.
One other thing, I’ve been asked for at audits is maintenance records for the power units. It does not matter how you do it, paper, spreadsheet, subscription. But, you have to have something.
Coaldust- My USDOT number is set up so I can do interstate travel, but I won’t be leaving the state or traveling outside of 150 air miles. My truck is a 2007. As a CDL holder do you not have to be enrolled in a random drug and alcohol testing program? I keep a maintenance spreadsheet on my truck and fill out the daily book every morning. I would appreciate copies of the qualification forms you use as well.
I have brought up the fact of a brake inspector card on here I don't know how many times. Every mechanic should have one in his wallet. As far as random drug testing, the OP should enroll himself, because if he does have a accident it will show his compliance-which goes a long ways and insurance companies like compliance. As far as vehicle records, a folder with every repair and FHWA inspections. A Stemco Brake or Wabco brake class can supply him with brake inspector card.
Ahart, Send me a PM with your email address. I recommend updating the mcs-150 and selecting intrastate. It might save some headaches later on. Yes, you will need to sign up with a service provider for drug testing. There is probably a local place. Your state’s trucking association may offer that service. That same service provider will probably include enrollment in the clearing house, as well. Check with your local NAPA Traction store and take a 4-hour brake class when it comes to town. That’s a good idea, Truck Shop. https://www.fmcsa.dot.gov/registrat...tructions-motor-carrier-identification-report I feel like I’m forgetting something. Let’s go over the must have checklist; CB radio CB handle **** bottle Oversized wallet with chain Chrome naked lady mudflap hangers Dead prostitute
I thought these days the checklist was more like dirty sweatpants Flip flops Bluetooth headset on at all times Taquito in one hand and a super mega gulp in the other
Oh’ yeah. It sounds basic and simplistic, but I highly recommend keeping a 1/2” three ring binder in the cab with HD plastic page protectors. Keep your; Medical Examiners Certificate Annual Vehicle Inspection Report (& previous year) Insurance Registration Brake examiners 396.25 Vehicle inspector 396.17 A and B level PM forms A copy of the title (just a copy) Not DOT - I have one customer that wants me to keep a msds/SDS folder with all the chemicals I keep on the truck. They are especially concerned about no CFC solvents or methyl chloride gasket removers.
Mike L, You made me spit coffee out my nose. Damn. Funny stuff. Thanks for keeping me up to date. Alaska just doesn’t have anything that resembles a true “truck stop” where these social conditions can be observed. There is no one-stop-shop where a person can get a new pair of Tony’s, chrome switch covers, a CB tune and a chicken fried steak lunch all at the same place.
Also for the folder, a written air brake test procedure. So when the dot cop try’s to get you all flustered you have something to refer to.
Good idea. The Bendix Airbrake Handbook is a good one. https://www.bendixvrc.com/itemDisplay.asp?documentID=6390
I kept an MSDS binder with all the products on board or that might be on board. Our crew collectively contributed what we each had, made a master set and photocopies for all. We needed to have a list on board in case the WCB (OSHA) wanted to look.
I’m kinda in the same situation you are. I’m a self employed carpenter with no employees. I have a Class A license and a Medium duty truck and air brake trailer. A year and a half ago I signed up for a drug and alcohol testing consortium,” Health Street”. Each month I receive two emails. One lists all the covered employees on my list (just me), the other lists who has to report for testing. I am the contact person since I am the only one here. If I receive the email outside of normal business hours, I am instructed not to tell myself that I have been chosen until the start of the next business work day and then I must immediately report to a local testing facility. That way I don’t have time to sober up. During the first year I never got picked to go and I decided to drop the service. But, apparently “Health Street” decided to keep my credit card number and went ahead and signed me up for another year! And such a coincidence that at the same time, someone tried to buy something with my card in Mexico. Of course this shut my card down and now I was in the position of having to wait for a new card to be issued. While I waited, I got an email from “Health Street” telling me that I had been picked and that they needed my new card number to “keep on file” so they could schedule appointments for my testing at labs of their choice, “for my convenience”. After several emails back and forth with Health Street personnel who clearly did not have English as their first language I decided to just ignore the whole thing. I still get the emails every month and now they pick me every time. I never go.
Yes isn’t it funny how the government doesn’t endorse any private companies but it requires you to use one to provide this service in order to be in “compliance.” Seems as if it is designed for safety but inadvertently opens the door for people to take advantage of others who are only trying to follow the rules.
Registration is called a cab card. Drivers out here stop at Bomb Taco. Nobody talks on a welfare radio anymore-they are all friends on facebook.
The Alaska Trucking Association has a dozen or so VHF business frequencies in the 150MHz range the cool kids run. The “big radio”. It’s kinda a grey area, because everyone uses them. Licensed or not. FCC ignores it. On the edge of the world, who cares? Now that welfare radio has gone FM, maybe it will make a come back and we can start using cool CB handles again. On the Highway, hail me with call sign, cyclops. The one eyed giant.
Damn FB. Had to terminate an CDL employee for driving over Turnagain Pass during a snowstorm, with a load, while videoing it and posting in real-time. Of course, everyone at the office got the notice. Dumb
Well that's alaska
We call it Faceplant around here, I got off it not long after got on it, too politically correct for a old buzzard as I. The warnings issued as if I were a criminal made me really angry. Are several drivers I am aware of that text and send posts of stuff while driving, one was caught by MoSHP and nothing happened, guess companies are too scared to lose much of anyone here. Have to admit I will take a photo while driving at times(NO Vids) however nothing of it until at delivery or load point to send it anywhere.
I have already started a collection of In Cab storage binders, for the KW when it becomes a Super Sized Pickup Truck, Can already see the drooling morons at the scales just expecting to find Something, ANYTHING to write a ticket on for a Personal Vehicle. With Air Brakes and being Class 8 machine they will be all over it trying to dig something up where I will carry Daily Inspect slips, have already spoken to MHC Service as to getting a Brake Inspect and Adjustment Class cert even as I am only a single truck operator with Mechanic Experience and ASE Certs from 30 years ago, will be a expense can live with. Have my Class A CDL, will be dropping Hazmat this next renewal as well Multiples and Passenger, do not see any need of those anymore, just need license to have the Truck as a Licensed Truck. Know how to arrange a Cab Card Booklet, done it enough where will be single grab hand off to the droolers. Being a Personal Vehicle, One Driver I too am curious as to the Drug/Alcohol Screen requirements as will still have a Class A, none of the local Brown Shirt Mo State DOT people have been any help on that.
Dmiller- I do know that if you have a USDOT number and hold a CDL then federal law FMCSA requires you to be enrolled in a drug and alcohol consortium. It’s a fairly new law and has to do with linking the DOT to the state agencies so they can suspend your license if you fail a drug test. I was finally able to get on at “quality consortium services” out of Minnesota and the annual fee is $49 and $59 for the drug test when your number gets pulled. They make all the queries into the FMCSA system for you as required by law. I’d say this program would be pretty low hanging fruit for them to nail a company on so $49 annually is fairly cheap insurance in my mind plus I have no objections to doing random drug and alcohol tests. Testing sites are all done by zip code and they use well known clinics for their collection sites.
All of this regulation and expense yet a 75 year old can buy a diesel RV that is 40 foot long and go anywhere on a regular driver's license.
They keep disincentivizing the ones that are working and paying the taxes. Every year it gets a little more difficult to make a living whether you’re self employed or working for someone else. Always more regulation
Once the DOT number is applied to the side of a vehicle-you fly by DOT rules. As far as seniors driving a diesel pusher, that falls in the politically correct zone. No one wants to go there other wise your picking on seniors, you can't pick on maw and paw. The problem with service trucks, tow trucks and any other truck that falls in this category is each state and their interpretation of the federal laws and each states own laws. They don't comprehend what they wrote. For instance in Washington St you can pull a 42' lead and a 20' pup {A Train} in Oregon the lead can only be 40'. It is crap like that with no standardization of rules/laws that causes so much confusion. The lower 48 should all be on the same page for all commercial vehicles.
Yea and I bet all the guys doing heavy haul and over size get tired of us service truck guys and our petty complaints.
No most all don't even acknowledge you guys even exist or think about it. Just another truck rolling down the road.
My KW will not have a DOT Number, will be tagged just as any MO Pickup truck driven out of state gets only weight will be greater. In MO it is a BL or Beyond Local tag and will receive a 54,000BL License Not Apportioned. Will cover any transport of MY OWN Machines anywhere I wish to take them, Flatbed with farm tractor or implements, RV, anything MINE. Will have to have a Class A license to do that, still have mine. When I tow RV Out of State will be against a Weight Tag not RV. "PERSONAL CONVEYANCE, NOT FOR HIRE" signage will be on it as will our address. Should drive the droolers insane.
And do this without a log book or medical, and maybe drive for 36 hours.
It was explained to me that even though people bitch about the seniors driving large rv’s the reason they get away with it is because they don’t drive after dark, don’t speed, and statistically are the cause of very few accidents.
The first two I will agree the third one-not so much.
We see way more wrecked and rolled 5th wheel toy haulers behind 3/4" lift and jumbo tire jobs then old people diesel pushers hands down.
That's probably a safe bet-it's the parking lot rash, fuel island rash and the car in tow disasters the boomers leave behind. Like one I saw on the highway last year with what was left of a power cable shredded dragging along side.
Yeah I've seen more then one old fogey bus with a curious safety yellow gash down the side at truck stops lol
Yep do not speed, drive 50 regardless road or lane or conditions unless really bad then destroy them as noted in fuel stations.
Most do not have a clue where that fogey bus is in the lane either where tire crawl the shoulders or yellow line the left side on the dashed or solid lines, corners are the next big game cutting them knowing are about to roll over and not giving up for oncoming traffic.
Retire with dreams of seeing the country. Buy an RV and start to travel, get a flat tire somewhere and have to call someone to change it. Drive from Washington State to Arizona and park the bus there for the winter months. Fire up the bus in May and drive back to Washington. Park the bus until November. Head back to Arizona and the bus breaks down this time pulling through the Siskiyous. Get ripped off by vulture shops in that area and then drive to Arizona. Park the bus for the winter. This time leave the bus parked in Arizona and fly back to Washington for the Summer. In October are tired of paying rent on the postage stamp lot the bus is sitting on so decide to bring the bus home. Flat tires, broken fan belts and leaking power steering and coolant hoses plague the trip. Finally get it home and parked where it sits for the next five years. It has to be worked on now to run so it is sold to someone and they park it in the street in Seattle and sell drugs to pay for the propane to keep some warmth. If it quits running before it get to Seattle, it is left on the side of the road for the taxpayers to have it dragged off where it will sit in a wrecking yard for years. I'm not a fan of the rolling the rolling palaces or their drivers.
Thank you John C., my sentiments also. I did a lot of work years ago on rolling **** houses, I learned to despise them and grew tired of the owners gripping about repair bills that were fair. Totally not designed to work on, built as a after thought. Diesel pushers are no different, big bucks spent on the rv lot when it comes time to settle up on repairs the whining starts. Labor for rv repair should be $300 an hour and $200 of that goes to the mechanic.
Done my share of Rolling **** House work, will soon have my own but ONLY the one.
Back in my truck mechanic days I worked at a dealer who worked on those miserable piles. We got paid an extra $5 per hour if we worked on them. Not worth it. They all seemed to have white carpet and of course the engine is in the rear, underneath the bed. Had to put shower caps over my work boots and make sure not to get a fingerprint on anything. Nope. Not my specialty.