Service Trucks

Do service vehicle operators need to have all the items that their regular drivers need?

To answer this question, one needs to refer to the two definitions of “commercial motor vehicle” found in the regulations. The definition of commercial motor vehicle differs, depending on the part of the regulations being referenced.

The general definition is found in §390.5. This definition refers to a vehicle used on highways, in interstate commerce (vehicle crosses state lines or transports commodities that are in interstate commerce), that meets one of the following criteria (transporting of passengers statements are left out):

  • Has a gross vehicle weight rating (GVWR) or gross combination weight rating (GCWR), or gross vehicle weight or gross combination weight of 10,001 pounds or more, whichever is greater; or
  • Is transporting hazardous materials in quantities requiring the vehicle to be placarded.

The regulations in Parts 390 through 396 apply to drivers of vehicles meeting the above definition. These parts include driver qualification, hours of service, and inspection and maintenance requirements.

A different definition of commercial motor vehicle is used for Parts 382 and 383. These parts regulate the commercial driver’s license (CDL) and alcohol and drug testing. This definition refers to a vehicle used in commerce, whether interstate or intrastate (stays inside state lines), that meets one of the following criteria (again leaving out the transporting of passengers):

  • Has a gross combination weight rating of 26,001 or more pounds inclusive of a towed unit with a gross vehicle weight rating of more than 10,000 pounds
  • Has a gross vehicle weight rating of 26,001 or more pounds
  • Is of any size and is used in the transportation of hazardous materials in quantities requiring the vehicle to be placarded.

As you can see, it can be a little confusing. Start first with the GVWR of the service vehicle to see if you are over 10,000 pounds (typically a one-ton vehicle). Then ask yourself if you are crossing state lines with that vehicle. If yes, follow the guidelines for the first definition. If no, then follow the guidelines for the second definition. Remember, if the vehicle is placarded then all the rules apply.

Most states have adopted the above definitions, but some states have slight modifications or exceptions to the above. Be sure to check if your state has modified the definitions.

If there are any questions on the above or if you want to check your state requirements, please contact me.

Gases and Welding Distributors Association
Michael Dodd Meet the Author
GAWDA’s DOT, Security, OSHA &EPA Consultant Michael Dodd is president of MLD Safety Associates in Poplar Bluff, Missouri. Members can reach him at 573-718-2887 and MLDSafety@hotmail.com.