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Registrant-only USDOT numbers:
The DOT number is used by the Federal Motor Carrier Safety Administration (FMCSA) and the States to identify motor carriers and monitor their safety performance. Historically, owner-operators leased to a carrier operated under the carrier’s authority and US DOT number. There was no need for the owner-operator to have a separate DOT number. When the Performance and Registration Information Systems Management (PRISM) was implemented, things became more complicated.

Registrants in a PRISM state are required to have or obtain a USDOT number or update their MCS-150 information before vehicle registration is granted. To better monitor motor carrier safety, the FMCSA and the States developed PRISM to link safety fitness to state vehicle registration. Registrants in a PRISM state are required to have or obtain a USDOT number or update their MCS-150 information before vehicle registration is granted.

Owner-operators who registered their vehicle in their own name needed a DOT number to register their vehicle in a PRISM state. The Federal Motor Carrier Safety Administration (FMCSA) created the “vehicle registrant-only” category as a way for non-motor carriers (primarily owner-operators and leasing companies) to have a DOT number to obtain their registration plates.

The “vehicle registrant-only” company operation type became an option in 1999 when applying for a USDOT Number. This operation type designated the company as a non-motor carrier; it did not grant authority to operate as a motor carrier in interstate commerce. The number was not to be displayed on a CMV, or have any safety events assigned to it.

The FMCSA found that registrant-only USDOT numbers were not used as the Agency intended and eliminated the “registrant-only” USDOT number as part of the PRISM program on September 1, 2012.

The problems encountered included:
Incorrect Data: When entering inspection or crash data, often the USDOT Number of the “vehicle registrant-only” company was incorrectly used instead of the USDOT Number of the responsible motor carrier. This resulted in the FMCSA using resources to research events attributed to the registrant-only records and reassign the events to the proper motor carrier.

Enforcement: Registrant-only USDOT Numbers were not included when evaluating companies for compliance reviews and New Entrant Safety Audits. When a company that is actually a motor carrier used the “vehicle registrant-only” company operation type, whether intentionally or not, the company evaded FMCSA safety oversight.

To overcome these problems, the FMCSA eliminated the issuance and use of registrant-only numbers.

The FMCSA sent letters to companies using a registrant-only USDOT Number, advising them to either:

1.Inactivate their Registrant-Only USDOT Number, or
2.Change their company operation type to one of the other options on Form MCS-150 (interstate carrier, intrastate hazmat carrier, intrastate non-hazmat carrier, interstate hazmat shipper, intrastate hazmat shipper) instead of “vehicle registrant only.Option (2) may be necessary when the motor carrier responsible for safety cannot be identified by the lessor at the time of registration.

After September 1, 2012, when a company with a registrant-only USDOT Number applies for a registration renewal, they will be asked to either inactivate their USDOT Number or change to another company operation designation.

At some point, any company that has not inactivated their own registrant-only USDOT Number or changed their company operation type will receive a letter from FMCSA stating the Agency intends inactivate

Owner Operators and US DOT Authorities

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