Applying for a USDOT can be intimidating. It is essentially raising your hand and saying, "I need to be regulated." If printed, the form to apply for a new USDOT number is over 30 pages broken into 12 sections covering over 60 data entry areas. The complexity causes much confusion, below are five considerations. 

1. Interstate carriers are required to have a USDOT number.

Carriers that operate commercial motor vehicles (CMVs) to further interstate commerce are required to have a USDOT number. The definition used includes the familiar weight classifications of any vehicle over 10,001 pounds (rated, actual or in combination with a trailer) in commerce used on a highway. The definition also includes buses and vehicles that carry placardable amounts of hazardous materials. 

Even if a carrier only:

• Uses CMVs in intersate commerce occasionally.
• Only uses rented or leased CMVs, or 
• Have intrastate operations in multiple states,

the carrier is considered interstate and needs a USDOT number.

2. 37 states require USDOT numbers.

The majority of states require their in-state only carriers to obtain a USDOT number. When a carrier registers with the FMCSA, the selection of "intrastate" is made. Carriers that register as intrastate are regulated by their state rather than the FMCSA. The exception to this rule is for carriers that are required to have a hazardous material safety permit (HMSP) because they carry extremely dangerous commodities. Intrastate carriers that have an HMSP are regulated by the FMCSA. Intrastate carriers with a USDOT number can follow the often less restrictive rules of their state. 

3. USDOT numbers are primarily used to track safety history. 

A USDOT number is a unique identifier when collecting and monitoring a company's safety information acquired during audits, compliance reviews, crash investigations, and inspections. All violations found at roadside inspections are recorded to the operating carrier's USDOT number. 

4. A carrier should have a single USDOT number.

As a social security number is unique to an individual, a federal employer identification number (FEIN) is unique to a corporate entity, a USDOT number is unique to the individual carrier. Some 20 years ago, the FMCSA shared that they would "consider requests for assignments of individual USDOT numbers to corporate divisions on a case-by-case basis." However, multiple USDOT can never be created for the purpose of evading statutory or regulatory requirements, an FMCSA order, enforcement action, or negative compliance history. 

There should be a one to one relationship between FEIN and a USDOT number. The FMCSA strongly prefers that individual terminals, operations in other states, or divisions that are not a legal entity, report through a single corporate USDOT number. This also means that related entities cannot share a USDOT number. 

5. Driver and vehicles are counted differently. 

The driver count is based on the number of drivers on an average business day. Because of this, the reported number of drivers is a bit of a "thumb's eye view." Part-time, casual, term-leased, trip-leased and company drivers are all included. The count is broken down further by the number of drivers operating vehicles that require a CDL and the number driver operating within a 100-air mile radius of the driver's normal work reporting location. The driver count is for statistical purposes, there is no direct safety measurement tied to the number. 

The vehicle count is a recording of all CMVs using the most general definition of a CMV (10,001 pounds or more, passenger carrying vehicles, and vehicles that carry placardable amounts of hazardous materials). All CMVs that are controlled by the carrier for more than 30 days in any given year are included in the count. The vehicles could be owned, trip leased, or termed leased by the carrier. All interstate and intrastate vehicle are included in the counts. 

Vehicle counts are factored into a carrier's CSA scores for Unsafe Driving and Crash BASICS. The Unified Carrier Registration (UCR) program uses the vehicle counts reported as a starting number to determine the fee bracket. 

It is important to compliantly register for a USDOT and keep the registration updated in order to operate, and continue to operate, as a carrier. As with any required regulatory filing, the forms are complicated. While carriers are allowed to complete their own filings using the available forms, instruction sheets, and electronic pop-up window; many carriers choose to get help from a third-party compliance service provider.