Top 6 Small Fleet Challenges - Part 3

Richard Malchow, Industry Business Advisor

August 29, 2023

Driver getting into red truck

In this three-part series, we are exploring the six biggest vehicle challenges for small fleets. Vehicle compliance is comprised of three primary areas: the driver, the vehicle, and the carrier. In this third and final installment we examine the carrier.


Challenge 5: Understanding what companies need to register with the FMCSA

Many small carriers ask, “Aren’t the regulations meant for big over the road trucking companies?” The truth of the matter is that anyone that operates a vehicle the meets the Federal Motor Carrier Safety Administration’s (FMCSA) definition of a commercial motor vehicle (CMV) must register with the agency, obtain a USDOT number, and display the number on the vehicle. It does not matter how small the company or what the vehicle looks like. The regulations and expectations are the same for small carriers as for large carriers.

The definition of a commercial vehicle includes any vehicle operated that furthers interstate commerce on a highway:

  • With a weight of 10,001 pounds or more of gross vehicle weight (GVW), gross vehicle weight rating (GVWR), gross combination weight (GCW), or gross combination weight rating;
  • That is designed to carry more than 8 passengers for compensation or more than 15 passengers regardless of compensation. Either count includes the driver; and
  • Any vehicle that carried a placardable amount of hazardous materials.

A company that operates any vehicles that meet one of the above definitions is subject to all the applicable rules of the agency.


Challenge 6: For the purpose of registering with the FMCSA, how do small carriers count the vehicles operated?

An area that causes considerable confusion for small carriers is accurately counting vehicles when registering with the FMCSA to obtain a USDOT number. The FMCSA’s online form for new carriers has good instruction on counting vehicles. 

“Enter the total number of commercial motor vehicles owned, term-leased or trip-leased by the applicant on the date the Form MCSA-1 is submitted and that have a GVWR, GCWR, GVW or GCW of 10,001 pounds or more.” “A CMV is operated for purposes of this question if the vehicle is registered under Federal or State law, or both, in the name of the carrier, or is controlled by the carrier under a trip lease or term lease agreement (more than 30 days) during any given year.” 

Companies that operate pick-up trucks include the vehicles in the count as a “straight-trucks.”