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Towing more than 26K with that heavy-duty pickup? Let’s hope you have the proper driving license!

By G.R. Whale

(Article first published in 2011)

Most contractors are towing equipment trailers of one sort or another and they do so without giving a second thought about their driver’s license. That could be a costly mistake for those who are pushing the limits of their new heavy-duty pickup’s towing capacity.

Each of the major pickup manufacturers now offers one-ton dually pickups with a gross combined weight rating (GCWR) of more than 26,000 pounds. Labtec wireless laser mouse driver download. Kontron embedded comp driver download for windows 10.

And in many states, legally operating a pickup and/or a trailer combo exceeding 26,000 pounds may require a commercial driver’s license (CDL).

Unfortunately each state is allowed to set its own rules on commercial driver’s licensing; there are also Federal regulations and they more often involve interstate commerce and hazardous materials.

Drivers operating newer one-ton pickups with a GVWR greater than 26,000 pounds might be required to have a commercial drivers license (CDL).

The Motor Carrier Safety Improvement Act of 1999 definition of a motor carrier of property (MCP) includes trucks with a GVWR of more than 10,000 pounds or any motor vehicle when used to transport any property for hire, including courier services.

So what may be legal in your state may not be under Federal rule or across the border 10 miles away, and the ticket could get expensive.

We’ve heard from RV’ers in the northeast finding their 20,000-pound combo – well within truck/trailer limits of 11,000 and 17,000 respectively – getting four-digit fines for not having a CDL.

(If that’s how they treat guests, imagine what commercial operators face.)

Generally 26,000 pounds is a threshold, usually by vehicle rating and not actual weight.

Other triggers include certain combinations like doubles or triples (of any size), type of hitch/trailer, passenger count (for compensation or non-profit use), tankers and hazardous materials [U.S. Department of Transportation (DOT) regulations 49 C.F.R. parts 172,173 and 177 address hazardous materials].

Hazardous materials usually have a minimum limit (e.g. 1,000 pounds, or 500 pounds transporting for hire), while transporting explosives, inhalation hazards and radioactive materials have lower limits.

It’s also possible your pool-service, right-of-way clearing and extermination business chemicals qualify.

And when it comes to your CDL, it carries a lot more responsibility than the typical driver’s license.

CDLs, which are linked state-to-state, have lower presumed-drunk blood-alcohol-content levels, so that beer after work could result in loss of the license. You can also loose your CDL with a pair of “serious” offenses or just one violation involving a train crossing.

Where do contractors need a CDL to tow heavy trailers with their pickups or pickups with a GCWR greater than 26,000 pounds?

Those questions can be answered by department of public safety, motor vehicles, or state police websites. When in doubt ask, and get the answer in writing.

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We surveyed four states of varied geography to see what laws were in force in late 2011. The results are outlined below.

ALABAMA

CDL required for:

  • (Class A) Articulated vehicles with trailer GVWR > 10,000 pounds and GCWR > 26,000 pounds.
  • (Class B) Straight truck GVWR > 26,000 pounds and no trailer or trailer < 10,000 pounds.
  • (Class C) Bus or vehicle < 26,000 GVWR and > 15 passengers or placard-required hazardous materials.
  • Notes: Endorsements are required for doubles/triples, some passenger transport < 15 passengers, tankers, hazardous materials, and combo hazmat/tanker.

CALIFORNIA

CDL required for:

  • Vehicles with a GVWR > 26,000 pounds.
  • Vehicles designed, used, or maintained for carrying more than 10 passengers (including driver) for hire.
  • Vehicles towing a vehicle or trailer with GVWR > 10,000 pounds.
  • Vehicles transporting hazardous materials requiring placards.
  • Vehicles towing two trailers or trailer and vehicle.
  • Notes: Recreational not-for-hire travel trailers > 10,000 pounds GVWR and fifth-wheels > 15,000 pounds GVWR require a non-commercial Class A, as do livestock trailers > 10,000 pounds but < 15,000 pounds GVWR operated within 150 miles of the (home) farm to transport livestock.

TEXAS

CDL required for:

  • A single vehicle with a GVWR > 26,000 pounds.
  • A trailer with a GVWR of > 10,000 pounds if the GCWR is > 26,000 pounds.
  • A vehicle designed to transport more than 15 persons (including driver).
  • Any size vehicle which requires hazardous materials placards.
  • Notes: some tankers may require a CDL based on size, purpose and/or contents.

WISCONSIN

CDL required for:

  • Vehicles > 26,000 pounds determined by highest of the following: manufacturer GVWR; manufacturer GCWR when the towed unit has a GVWR, registered or actual weight > 10,000 pounds; actual weight; registered weight.
  • Class A for any combination with a GVWR, actual or registered weight > 26,000 pounds provided the GVWR, actual or registered weight of the towed vehicle(s) is > 10,000 pounds.
  • Class B for any single vehicle with a GVWR, actual or registered weight > 26,000 pounds, or such vehicle towing a vehicle with a GVWR, actual or registered weight of 10,000 pounds or less.
  • Class C for any single vehicle with a GVWR, actual or registered weight of 26,000 pounds or less, (or such vehicle towing a vehicle less than 10,000 pounds) transporting hazardous materials requiring placarding or designed to carry 16 or more persons (including driver).
  • Notes: If new to Wisconsin and you have CDL you must apply for new one within 30 days.
  • Vehicles designed or used to carry 16 or more persons (driver included).
  • Vehicles that carry hazardous materials that require placarding under federal law.
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When working with clients, I periodically encounter situations where a client is unknowingly out of compliance with Department of Transportation (DOT) regulations. Many times, these issues relate to light trucks or vans that are occasionally used to tow trailers. There are passenger carrier rules as well as hazardous material rules, which I will address in Part 2 of this series on DOT regulations.

For this post I will make two assumptions. First, I will assume that we are discussing vehicles being used in commerce. If they are driven for business in any way they are in commerce. The second assumption I will make is that these vehicles are being driven on public roadways. If you operate only on private property or are not operating in commerce, the DOT does not have jurisdictional authority over your operations.

Here, I will discuss only DOT weight regulations and the weight threshold that will trigger DOT regulations applicable to light trucks and trailers.


The topic of DOT weight regulations tends to get confusing for three reasons:

1. There are two types of fleet operations. One is called intrastate (For the sake of simplicity, let’s say that means never crossing state lines; more on that in a later post) and one is called interstate (crossing state lines). Depending on which type of fleet you operate and which state you operate in, the weight threshold that triggers a need for compliance can be different. For example, for intrastate fleets the state of Colorado threshold is 16,000 pounds GVWR (Gross Vehicle Weight Rating) / GCWR Gross Combined Weight Rating); the state of Arizona threshold is 18,000 pounds GVWR / GCWR; other states have different thresholds; and some states stick with 10,001 pounds GVWR / GCWR, which matches the federal government standard for interstate CMV definitions. In other words, depending on which state you’re in and whether or not you cross state lines, the threshold is different.

2. The way that these weights are measured is not intuitive to those who have not dealt with DOT regulations before. These weights are not the actual weights of a vehicle or trailer, but instead include the weight of the vehicle plus the weight it can carry. These two weights add up to the GVWR. This information is usually posted on the inside of the driver’s door and on trailers. The label below is from a light duty minivan:

3. It does not matter whether the weight rating is of a single vehicle (GVWR) or a combination of vehicles (GVWR + GVWR = GCWR). If it exceeds the threshold, then DOT regulations start to kick in.

To help explain why this is often missed, it may be helpful to look at an example. It is not uncommon for a three-quarter ton truck to have a GVWR as high as 10,000 pounds, especially with diesels, which is just one pound shy of the federal GVWR limit that would require DOT compliance at some level. Let’s look at what happens if such a truck is used for either interstate or intrastate purposes:

  • Interstate: If a trailer is then added to a truck of this type, the combination would be a CMV because the combined weight (GCWR) exceeds 10,001 pounds.
  • Intrastate: In some states, the combination would qualify as a CMV once it hit 10,001 pounds, and in some states with higher weight thresholds it would only become a CMV once it hit that state’s threshold. Using Colorado as an example, if the trailer GVWR is 6,000 pounds (not uncommon for a dual-axle trailer), the combined weight of 16,001 pounds would now require compliance with DOT regulations specific to Colorado.

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Even if you have quarter-ton trucks or vans, their GVWR can be 7,000 pounds or higher. A trailer with a GVWR of 3,001 pounds or higher would push the GCWR to 10,001 pounds.

Another somewhat confusing factor is that none of these thresholds mean that a driver must have a commercial driver’s license (CDL) to drive the vehicle. That is a different threshold set at a higher weight level. Many employers assume that if their drivers don’t need a CDL, then they are not subject to any DOT regulations. In fact, they may be required to keep driver qualification files; pull and check motor vehicle records; maintain medical cards; carry out road evaluations; ensure their drivers are not disqualified; keep hours of service records; and more.

To learn more about federal regulations, visit the Federal Motor Carrier Safety Administration (FMCSA) website. Questions about state-specific regulations can be sent to your Woodruff Sawyer account team or addressed to a state-specific enforcement agent, such as the state patrol or state police.

Follow these links for Part 2 and Part 3 of this series, on passengers and payment type and substances and toxins, respectively.