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October 28, 2011
INTRASTATE VS INTERSTATE AND THE CSA
How many of you are operating as an INTRASTATE carrier subject to the State regulations with a US DOT
number on the side of your unit?
In meeting with a customer a few weeks ago, we entered into a discussion about INTRASTATE vs. INTERSTATE
operations specifically with regard to the Compliance Safety and Accountability (CSA) carriers’ assessment
program of the FMCSA. This customer has US DOT INTERSTATE authority; however, some of his fleets
throughout the US operate as an
INTRASTATE carrier. His concern was
that by having their US DOT number on
the side of their units operating as an
INTRASTATE carrier the roadside
inspections, violations incurred and
accidents are being used in the CSA
CSMS program to access him as an
INTERSTATE carrier. The INTRASTATE
fleet that he was referring to was in the
state of California and there was no
exposure for these units to operate
INTERSTATE or be involved in the
furtherance of an INTERSTATE shipment
and they do not transport hazardous
materials.
So in this instance where California does
require a US DOT number for INTRASTATE operations, this carrier could mark the units with their California
CA# issued by the state for INTRASTATE carriers. This way any violations, roadside inspections, and accidents
that are incurred would be registered with the state of California only. Is this applicable in all states? No, as
twenty nine states require a US DOT number for INTRASTATE operations.
(See the map on page 2)
Question of the Week?
I think my company is operating as an intrastate carrier. What is the definition of an intrastate carrier and do
we need a US DOT number?
Answer:
The definition of an intrastate carrier can best be defined by eliminating the fact that it is not an Interstate carrier.
The Federal Motor carrier Safety Administration defines interstate and intrastate commerce as follows in CFR 390.5
Interstate commerce means trade, traffic, or transportation in the United States;
1) Between a place in a State and a place outside of such State (including a place outside of the United States)
2) Between two places in a State through another State or a place outside of the United States
3) Between two places in a State as part of trade, traffic, or transportation originating or terminating outside
the State or the United States
Intrastate commerce means any trade, traffic, or transportation in any State, which is not described in the term "interstate
commerce."
The US Federal Government governs interstate operations, while intrastate operations are governed by the state in which you
operate. Check the following list to determine if you will be required, as an intrastate carrier, by your state to obtain a US DOT
number. Those states shaded in green and listed below require intrastate carriers to obtain a US DOT number.
The number can be applied for through the FMCSA website at www.fmcsa.dot.gov.
Alabama, Alaska, Arizona, Colorado, Connecticut, Florida, Georgia, Iowa, Kansas, Kentucky, Maine, Maryland, Michigan, Minnesota,
Missouri, Montana, Nebraska, New York, Ohio, Oklahoma, Oregon, South Carolina, Tennessee, Texas, Utah, Washington, West
Virginia, Wisconsin, and Wyoming.
Time to Fall Back!!!
Daylight savings time will "fall back" at 2:00 a.m. next Sunday, November 6 th.
Make sure that all of your drivers are aware that the change to daylight savings will occur. Caution route drivers
especially that the amount of daylight will change according to their stops with the change. An intersection or
street can present different challenges to drivers with one hour change in the position of the sun. One hour of time
difference can present unique changes to a driver who is on a route.
The Idealease Safety Bulletin is provided for Idealease affiliates and their customers and is not to be construed as a complete or exhaustive source of compliance or safety
information. The Idealease Safety Bulletin is advisory in nature and does not warrant, guarantee, or otherwise certify compliance with laws, regulations, requirements, or
guidelines of any local, state, or Federal agency and/or governing body, or industry standards.