The pickup and trailer can make your crew a DOT operation.
Most landscapers never think of themselves as motor carriers. But a truck and trailer combination rated at 10,001 lbs or more, used across state lines for the business, is a commercial motor vehicle, and the driver needs a federal driver file.
Free: see your roadside record and MCS-150 due date from FMCSA’s public data.
Does this apply to you?
A driver needs a federal driver file when all three are true:
- 1The vehicle meets the weight thresholdGross vehicle or combination weight rating, or actual weight, of 10,001 lbs or more, whichever is greater. 49 CFR 390.5
- 2It's used in interstate commerceCrossing a state line, or an in-state leg of trade that starts or ends out of state. 49 CFR 390.5
- 3They drive it for your businessPart 391 covers anyone who drives a commercial motor vehicle for a motor carrier, full-time or not. 49 CFR 391.1
Purely intrastate? Many states apply the same rules with changes; confirm with your state.
Vehicles to check
Compare each one’s ratings against 10,001 lbs:
- Pickups towing mower or equipment trailers
- Dump-body trucks for mulch, stone and debris
- Box trucks and stake-body trucks
- Hydroseeders and water trucks
Check the combination rating
49 CFR 390.5 counts the gross combination weight rating or the actual weight, whichever is greater. Add the truck's rating and the trailer's rating from their stickers. At 10,001 lbs or more, it's a commercial motor vehicle in interstate commerce.
Seasonal drivers need files too
Every person who drives a commercial motor vehicle for you needs a driver qualification file (49 CFR 391.51), including drivers hired for the season.
What every driver file must hold
11 records per driver across two separate files plus related obligations. A missing or incomplete required record is a recordkeeping violation: up to $1,584 per day and $15,846 per violation (49 CFR Part 386, Appendix B).
Driver Qualification File
49 CFR 391.51
- Application for employment · At hire
- Motor vehicle record — at hire · At hire
- Road test certificate or equivalent · Once
- Motor vehicle record — annual inquiry · Every 12 months
- Note of annual review of driving record · Every 12 months
- Medical examiner's certificate · Expires — up to 24 months
Driver Investigation History File
49 CFR 391.53
- Driver's written authorization · At hire
- Previous employer responses · Within 30 days of hire
Related obligations
49 CFR Parts 380 & 382
- Pre-employment drug & alcohol test result · At hire
- Drug & Alcohol Clearinghouse query · Pre-employment, then annually
- Entry-level driver training certificate · Once
We build the files for you
$999 one-time Audit-Ready Setup for landscaping companies with up to 30 drivers, with a 30-day money-back guarantee. Then $8 per driver per month ( $79 minimum) to track every expiry date.
None of our drivers have a CDL. Is this really about us?
It can be. A CDL is required at 26,001 lbs (49 CFR 383.5), but driver qualification files apply from 10,001 lbs (49 CFR 390.5 and 391.1). A crew truck and trailer can easily fall between.
We stay local. Does interstate commerce apply?
Crossing a state line on a job does. So can an in-state trip that's part of trade starting or ending out of state (49 CFR 390.5). If you never operate in interstate commerce, check your state's own rules, which often mirror the federal ones.
Other industries
General information, not legal advice. Rules cited are from Title 49 of the Code of Federal Regulations; exceptions and state rules can change what applies to your operation.