If you are a hotshot trucker (or are interested in becoming one), and want to understand the key rules and regulations that may apply to you, you’re in the right place.
I know it’s not exciting, but if you want long term success and a profitable career as a hotshot trucker, you have to know the rules and play by them.
In this article, I am going to cover key regulations for hotshot trucking issued by the Department of Transportation (DOT) and the Federal Motor Carrier Safety Administration (FMCSA), which is the part of the DOT that is responsible for reducing crashes, injuries, and deaths involving large trucks and buses.
Note: In the interest of trying to cover more bases, I have included a couple of regs from related governmental entities as well. Now this article does not cover every possible regulation that may apply to your situation. Not only would something like that be highly circumstance-specific, it would be impossible to do without writing an entire book!
Many large truck operators (i.e., semi trucks and the like) will automatically be subject to the most stringent DOT requirements due to the nature of their vehicle and weight of the cargo they are transporting.
Hotshot trucking, though, is often performed by much smaller vehicles, like pickup trucks with trailers, so they may or may not be subject to all of the standard regulations that semi-truck operators must follow.
We’ll cover when those circumstances come up and what you need to look at to determine if a set of regulations apply to you.
Here’s a list of topics we will cover. If you want to skip ahead to any of them, just click on the corresponding link below.
We’ve got a lot to cover, so let’s get into it!
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The information contained in this post is for informational purposes only. It is not a recommendation to buy or invest, and it is not financial, investment, legal, or tax advice. You should seek the advice of a qualified professional before making any investment or other decisions relating to the topics covered by this article.
1. Obtain DOT Medical Card
In general, you will need to pass a Department of Transportation (DOT) physical and receive a medical card. This signifies that you are physically capable of handling the work required for this type of activity.
The exam must be conducted by a licensed medical examiner listed on the FMCSA National Registry. You can use this tool provided by the FMCSA to find a qualified medical examiner near you.
2. Obtain Commercial Driver’s License (CDL)
Not all hot shot loads require a CDL, but if you will need one if you plan on operating vehicles that meet or exceed certain weight thresholds. According to the Federal Motor Carrier Safety Administration (FMCSA), you will need a CDL under the following conditions:
You operate in interstate, intrastate, or foreign commerce and drive a vehicle that meets one or more of the classifications of a commercial motor vehicle (CMV) described below:
Class A: Any combination of vehicles which has a gross combination weight rating or gross combination weight of 26,001 pounds or more, inclusive of a towed unit(s) with a gross vehicle weight rating or gross vehicle weight of more than 10,000 pounds.
Class B: Any single vehicle which has a gross vehicle weight rating or gross vehicle weight of 26,001 pounds or more, or any such vehicle towing a vehicle with a gross vehicle weight rating or gross vehicle weight that does not exceed 10,000 pounds.
Class C: Any single vehicle, or combination of vehicles, that does not meet the definition of Class A or Class B, but is transporting material that has been designated as hazardous under federal law.
If you want more info on CDL requirements, check out the FMCSA page on the topic.
3. Obtain Trucking Authority (USDOT and Motor Carrier Numbers)
According to the FMCSA, if you plan on engaging in interstate commerce (delivering across state lines) and your vehicle meets certain weight requirements then you will need a USDOT Number.
Now even if you plan on delivering within just your state, some states also require you to have a USDOT number even if you are only engaging in intrastate commerce, so you need to check your state’s requirements on this.
In addition to getting your USDOT, you will need a Motor Carrier (MC) number. Again, this only applies if you plan on engaging in interstate commerce, you don’t own the freight you are transporting, and you will be receiving a fee for providing such transport.
For more details on MC numbers, check out the FMCSA website on the topic.
Getting your own authority is a fairly involved process so you should be prepared for that.
One important element that you should not ignore as part of this process is insurance. The FMCSA requires specific insurance coverage amounts if you are a carrier seeking your own authority.
In general terms, the FMCSA’s insurance requirements are as follows:
For those transporting freight (as opposed to passengers), the required public liability insurance coverage is $750,000 – $5,000,000, depending on commodities transported.
If you are moving non-hazardous freight in vehicles weighing under 10,001 lbs., then that amount is reduced to $300,000. As a hotshot trucker, you may be able to take advantage of this lower threshold.
If you are transporting household freight, you will also need cargo insurance ($5,000 per vehicle; $10,000 per occurrence).
To learn more about insurance filing requirements and the forms you will need to fill out, check out the FMCSA’s website on the topic here.
As far as who you should use for insurance coverage, that’s really up to you, but Progressive seems like a leader in this space, so you may want to check them out.
Again, you won’t need your own authority if you stick to loads that don’t meet these requirements. Of course, you could also choose to “lease on” your truck to another company that has their authority already and avoid these requirements, but you won’t make as much.
4. Designate Agents For Service of Process (BOC-3)
If you are a carrier operating under your own authority, you will need to file a BOC-3. “BOC” stands for Blanket of Coverage and the form lists out the entities or individuals who may receive legal documents on your behalf (i.e., if you need to get served a complaint, etc.).
According to the DOT, an agent must be designated for each state in or through which the carrier operates. This is so that if a claim is made against the carrier, they can be served in that state, even if the carrier does not reside there.
The DOT offers a terrific resource that lists various process agents you can use to fill out your BOC-3 form. These process agents all have national coverage, so if you go with one of them, you can have a process agent for every state you may operate in.
Note: If you are a carrier, you cannot file the form yourself – you will need to have your process agent do it for you.
5. Comply With Hours of Service (HOS)
According to the FMCSA, most CMV drivers must comply with hours of service (HOS) requirements. This is to basically ensure that exhausted drivers are not becoming a hazard on the road.
In their Q&A’s, the FMCSA defined a CMV as a vehicle that is used as part of a business and is involved in interstate commerce and fits any of these descriptions:
- Weighs 10,001 pounds or more
- Has a gross vehicle weight rating or gross combination weight rating of 10,001 pounds or more
- Is designed or used to transport 16 or more passengers (including the driver) not for compensation
- Is designed or used to transport 9 or more passengers (including the driver) for compensation
- Is transporting hazardous materials in a quantity requiring placards
So, if your hotshot trucking activities meet these thresholds, then you will need to comply with HOS standards. At a high level, the requirements are as follows:
- You can’t drive for more than 11 hours after 10 hours off duty,
- You get a 14 hour window for driving after 10 hours off duty,
- You must take a 30 minute driving break if you’ve driven for 8 straight hours
- You have a 60/70 hour limit in 7/8 consecutive days
The driver must also maintain a log book that tracks their status (driving, off duty, sleeper berth, on duty but not driving). Generally, you have to do this using an ELD (which stands for an Electronic Logging Device), but there are some exceptions. Source
Note: There is a short haul exemption to the HOS rule that may apply for certain hot shot operators doing shorter loads. A driver is exempt from certain HOS requirements if the driver operates within a 150 mile radius of the normal work reporting location and the driver does not exceed the maximum duty period of 14 hours.
If you want a more detailed description of Hours of Service requirements, check out the DOT’s summary of the topic here.
6. Driver Vehicle Inspection Reports (DVIRs)
The FMCSA requires that drivers inspect their commercial motor vehicles (again, your hotshot set up may not qualify as a CMV) before and after each trip (at the end of each work day).
You typically will need to check things like your service brakes including trailer brake connections, parking brake, lighting devices and reflectors, coupling devices, wheels and rims, steering systems, horn, wipers, mirrors, emergency equipment (e.g., fire extinguisher, fuses, flares, etc.) and so on.
For more details on what needs to be in the DVIR , check out the FMCSA rules here.
7. Drug and Alcohol Testing (Owner-Operators)
According to the FMCSA, if you are a owner-operator driving a commercial motor vehicle in intrastate or interstate commerce that requires a commercial driver’s license, you need to participate in a DOT Drug and Alcohol Testing program.
Owner-operators must register with a consortium, which is basically an entity that administers random drug testing for employers (including owner operators) and participate in the Consortium’s random testing pool.
To learn more about Consortium testing, check out the DOT link here on the topic.
8. UCR Compliance
What is UCR?
The Unified Carrier Registration (or UCR) is a federal program that requires that individuals or companies involved in interstate travel pay an annual registration fee based on the total number of vehicles in their fleet.
It replaces the old Single State Registration System (SSSR). Source.
Who is subject to UCR?
If you are a carrier operating a commercial vehicle that weighs more than 10,000 pounds, or placarded amounts of hazardous materials or transporting more than 10 passengers (including driver) across interstate lines, then you will be subject to UCR.
If you want to know if this will apply to your hotshot operation, use the decision tree tool provided by the UCR organization. You can access that tool here.
How Do I Comply with UCR?
If you are subject to the UCR, you will need to register with them (and of course pay the applicable fee). You can start the process by going to the official UCR website here.
9. IFTA and IRP Compliance
The International Fuel Tax Agreement (IFTA) and International Registration Plan (IRP) are cooperative programs to collect and distribute registration and fuel tax revenue between member US states and Canadian provinces.
If you are traveling across state lines and you meet other qualifying criteria (which we will cover later), then you need to comply with these programs.
IFTA stands for International Fuel Tax Agreement, which is an agreement between US states and Canadian provinces, which allows a carrier to register and pay motor fuel road taxes in the carrier’s home or base state for all participating jurisdictions.
IRP stands for the International Registration Plan, which is essentially a way of registering vehicles that travel in two or more member jurisdictions. Your fees are determined based on the distance that you travel in each jurisdiction and other factors.
You will pay all fees to your base jurisdiction (usually your state DMV) which then distributes them to the other appropriate jurisdictions.
Who Needs to Comply with IFTA and IRP?
For both IFTA and IRP, you will need to comply with its requirements if you operate a Qualified Motor Vehicle across state lines, which meets the following criteria:
- Has two axles and a gross vehicle weight or registered gross vehicle weight exceeding 26,000 pounds; or
- Has three or more axles regardless of weight; or
- Is used in combination, when the weight of such combination exceeds 26,000
pounds gross vehicle or registered gross vehicle weight
Note that even if you fall below the weight requirements, but still cross state lines, you may be subject to one or both of these programs.
You should check with your individual state’s DMV to find out rules around this. For example, Virginia requires IRP plates even if the vehicle is less than 26,000 lbs., but the driver crosses state lines. Source.
What Do I Need to do to Comply with IFTA and IRP?
For IRP, you will need to file the appropriate paperwork with your base jurisdiction (usually your “home” state where your vehicle is registered). Check your DMV’s website to find out specifics. There will be fees and they may not be cheap, depending on how many jurisdictions are in play.
Once you complete the process, you will get an Apportioned License Plate for your vehicle and an Apportioned Cab Card that lists the states/provinces where you are registered to operate in.
For IFTA, you will need to apply for an IFTA license in your home state. Once you complete that process, you will get a set of decals (stickers) for you vehicle and an IFTA license for your records.
Once you get these things, you will also need to keep meticulous records of your driving and fueling activity and file and pay quarterly IFTA taxes. The mileage is also important when you renew your apportioned license for IRP, so maintaining accurate records is a must.
So there you have it – 9 key regulations you need to be aware of as a hotshot trucker and some helpful tips on how to comply with them. Hope this has been helpful and happy trucking!