Based on current federal regulations, intrastate trucking companies in 19 states are not required to obtain a USDOT number. This situation needs to change for a number of reasons, according to National Tank Truck Carriers.

For instance, roadside inspection information from these carriers is not entered into Federal Motor Carrier Safety Administration (FMCSA) databases like the ones used for the Compliance, Safety, Accountability (CSA) program. NTTC believes in this change to ensure a more equitable enforcement and compliance playing field.

NTTC filed a petition for rulemaking with the Pipeline Hazardous Materials Safety Administration (PHMSA) on April 11. “We’ve asked that PHMSA make provision of a USDOT number a requirement for any carrier applying for a Hazardous Materials Registration Number, which already must be carried on every truck transporting hazardous materials,” says John Conley, NTTC president. “Intrastate carriers are already required to obtain a HM Registration, so this proposed new requirement would add minimal cost or burden to the application process.

Today, the USDOT number application fee is $300. The NTTC petition states: Increasingly, the USDOT number is the gateway to enforcement and data collection of the hazardous materials regulations under which all HM carriers, including intrastate carriers, are required to operate. The safe transportation of hazardous materials should not be impacted by state borders or whether or not a state has adopted Federal Regulations… As the Department of Transportation becomes a more data driven agency, it is essential that all participants in the transportation field, and especially in the tank truck transportation of hazardous materials, are on an equal regulatory and competitive playing field. Hazardous materials do not know they cross an artificial geographic boundary.

A key principle of the CSA program—especially in the new HM BASIC—is that carriers will be compared to like carriers in their peer group. Of course, in the absence of USDOT numbers, there is no way to know whom your peers are. Those carriers above a certain threshold of their peer group face a higher likelihood of intervention by FMCSA. NTTC contends that any measurement of HM carriers should include all carriers, including interstate and intrastate carriers.

”While we believe the regulatory principles are the same for all trucking, the NTTC petition addresses only HM carriers, Conley says. “Appealing to PHMSA seems the avenue with the best chance of success at this time. We do expect opposition to our proposal.”