The United States Department of Transportation Biennial Update is a federal requirement pertaining to and required of all entities operating under a federally-issued U.S. DOT Number. A U.S. DOT number is a “number” issued by the Federal Motor Carrier Safety Administration (FMCSA) that “tags” your vehicles with the federal Department of Transportation thereby making your vehicles available for monitoring and safety performance analysis.
Do I Need a DOT Number?
A U.S. DOT number is required for all vehicles that meet any of the following criteria:
10,000+ lbs in GVWR
Transports 8 or more passengers for compensation
Transports 15 passengers not for compensation
Transports Hazardous Materials per 49 CFR 385.403
and operate interstate (cross state lines or transport goods originating from or with a destination outside of the home state). Some states require a federal U.S. DOT number even if the vehicle is involved only in intrastate travel (never crosses state lines). These states are: Alabama, Alaska, Arizona, California, Colorado, Connecticut, Florida, Georgia, Idaho, Indiana, Iowa, Kansas, Kentucky, Maine, Maryland, Massachusetts, Michigan, Minnesota, Missouri, Montana, New Jersey, New York, Nebraska, Nevada, North Carolina, Ohio, Oklahoma, Oregon, Pennsylvania, Puerto Rico, South Carolina, Texas, Utah, Washington, West Virginia, Wisconsin, Wyoming.
State Regulations vs Federal Regulations
It is important to differentiate between state and federal regulations. Some states may require a motor carrier to obtain a state DOT number in addition to the federal DOT number. Other states may require a motor carrier to obtain an operating authority or a Commission of Commerce number. While these are valid requirements and your compliance with them is mandated by your state, it should be stressed that motor carriers must comply with federal regulations, such as the Biennial Update, in addition to complying with state regulations. This may be confusing to motor carriers that operate within state lines (intrastate carriers) and are normally not subject to federal requirements but it should be stressed that the DOT number is issued by the federal government and therefore all motor carriers operating under such number are subject to federal regulations.
WHEN MUST THE BIENNIAL UPDATE BE FILED?
The Biennial Update has a filing deadline unique to each U.S. DOT number. To determine your filing period locate the last 2 digits of your U.S. DOT number. The last digit indicates the month when the filing must take place. The second-to-last digit indicates the year when the filing must be completed (an odd number mandates a filing in an odd year and an even number mandates a filing in an even year).
U.S. DOT number ‘384983’ ends in the digit ‘3’ which corresponds to the third month of the year, March. The second-to-the-last digit is ‘8’ which is an even number which correspond to an even year. As such, this motor carrier must file their update in March of even-numbered years. Note that the last digit corresponds to the months 1-9 (January – September) while 0 indicates the month of October. No filings are scheduled for November and December.