Monday, November 11, 2013

Important Notice: FMCSA to Enforce MCS-150 Requirement

Motor carriers and other entities that are required to have a U.S. DOT number are also required to file a Form MCS-150 with the Federal Motor Carrier Safety Administration at least every two years to update their identifying, contact, and operational information.  

This has been the law for a long time, but FMCSA has never strictly enforced it.  However, the agency now plans to do so, under a regulation that was part of its recently issued Unified Registration System rule.  (See the SLN of 8/30/2013. And once again, the URS has nothing to do with the UCRA)  

FMCSA has now indicated how they'll go about this enforcement.  Starting next month, the agency will send a letter to carriers that are due to update their information in January 2014 reminding them to do so.  In February, the FMCSA will check its system to see if those carriers complied.  If a carrier did not, its DOT number will be  deactivated on April 1.  FMCSA will adhere to a similar schedule in each succeeding month for carriers whose two-year window expires in the months following January.  

Although information from the MCS-150s filed by carriers and other entities is critical for FMCSA's master database, the Motor Carrier Management Information System, MCMIS, much of the enforcement of the filing requirement has in effect been left up to the states that participate in the federal PRISM program.  Under PRISM, a state participating in the program may not renew the International Registration Plan registration of a carrier unless it has updated its MCS-150 information within the preceding twelve months.  And most states participate in PRISM.

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