Discussion in 'Trucking Industry Regulations' started by bvacura13, Sep 27, 2023.

  1. bvacura13

    bvacura13 Bobtail Member

    Sep 27, 2023
    Afternoon everybody...

    The company I work for is going through a debate on whether we need to have a CDL or not as well as having a DOT registration and UCR registration. We are based in Illinois..

    We have a few different towing setups we primarily operate with..

    First up: Our marketing team uses a '21 RAM 3500 dually with a 44' gooseneck, wrapped with our company logos for events. Both are company owned and technically we carry "goods" to such shows for education and swag-bag giveaways. To my research, we are under 26k lbs but not sure if it is required to have a CDL or is it good practice since it goes on trips spanning multiple states. I believe we need a DOT (not for hire?) since it is company owned and over the 10k lbs requirement. Please correct me if I'm wrong...

    Second: We have a company sponsored auto racing team that we use a 2500HD (SRW) towing a 30' bumper-pull enclosed trailer. These are not wrapped with company logos. The company owns the truck/trailer/tools/spares/racecar and it is all registered to the company as well. I do not think we need a CDL for this setup but would this technically fall under DOT/UCR registrations? Do we placard as NFH as well? We also have a 24' trailer (wrapped - company logo) and a 20' open car trailer (bare aluminum) that may be used for other purposes and possibly track days/general towing.

    Hopefully I didn't leave any information out so please let me know if I need to expand on anything for clarity..TIA
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  3. Broke_and_Hungry

    Broke_and_Hungry Light Load Member

    Feb 26, 2008
    The 3500 Ram and 44 gooseneck is likely far closer to 38,000lb GCVWR, and would require a CDL, USDOT number, if travelling out of state IFTA, IRP and UCR. As described, it is not a personal or non-comm vehicle.

    For the second one, you must define a CMV. Federal Register :: Request Access
    Part 390.5
    Commercial motor vehicle means any self-propelled or towed motor vehicle used on a highway in interstate commerce to transport passengers or property when the vehicle—

    (1) Has a gross vehicle weight rating or gross combination weight rating, or gross vehicle weight or gross combination weight, of 4,536 kg (10,001 pounds) or more, whichever is greater;

    For hire doesn't matter when it comes to a USDOT number or UCR. For hire would be operating authority.
    Again, as described, it is not a personal or non-comm vehicle.
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  4. ZVar

    ZVar Road Train Member

    Sep 10, 2010
    Flint, MI
    As hinted at above, all we can do is guess.
    To be accurate we would need the GVWR (gross vehicle weight rating) of the trucks and trailers.
    With that my guess both are cdl territory and dot number territory.
  5. kemosabi49

    kemosabi49 Trucker Forum STAFF Staff Member

    Jan 13, 2013
    SW Arkansas
    I'm thinking that an ELD would also be required. And probably have to be in a drug testing consortium too. The driver(s) would have to be tested.
  6. Rideandrepair

    Rideandrepair Road Train Member

    Aug 8, 2015
    If you’re going that far, a full Drivers employment file will be needed. 10 years record of employment. Letters of verification from previous Driving job employers if any. Copy of D/L. ( updated annually Current DOT Physical, Drivers certification of violations updated annually. I’m sure I missed something.
  7. roundhouse

    roundhouse Road Train Member

    Jul 11, 2018
    Y’all should talk to some kind of consulting company aboit this

    I’m sure there are companies that help places like yours set up all the paperwork etc

    I’m gonna say the 3500 with a 44 foot trailer is gonna be over 26000 GVWR

    you said your research indicated the weight is under 26k

    if your research was looking at the GVWR sticker in the drivers door of the dodge and looking at the GVWR sticker on the trailer and adding those together , then if that number is under 26000 , you’re good ,
    But I can’t imagine a 44 foot goose that’s under 10k GVWR
    But it could be .

    also if it’s under 10k GVWR you need to be careful about not overloading it .

    the company I used to work for had a trailer with a 9900 GVWR with permanently mounted air compressors etc inside ,
    I weighed it one time and the trailer was 12,500
    wis bang Thanks this.
  8. wis bang

    wis bang Road Train Member

    Jan 12, 2011
    Levittown, PA
    Call the state motor truck association office for a reccomendation
  9. Ridgeline

    Ridgeline Road Train Member

    Dec 18, 2011
    The 21 RAM 3500 dually has a GVRW of 10,700 lbs.

    The 2500HD - assuming you mean GMC/Chevy depends on the engine. If it is a diesel, the GVRW is 10,700 lbs but a gas engine is 10,000 lbs.

    These are the numbers that matter for the question.

    OK for the Ram, yes you need a CDL, without a doubt because the trailer you have may have an 18,000 lbs GVRW which puts you into the class A range.

    The other truck, I am not sure but I would venture that it is close to 14,000 lbs GVRW which again would put you into the Class A range.

    As for DOT registration, yep.
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