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	<title>Comments on: Do you have a question?</title>
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	<link>http://www.arnoldsafetyblog.com/do-you-have-a-question/</link>
	<description>Helping Companies Comply With D.O.T. Safety Regulations</description>
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		<title>By: Eric Arnold</title>
		<link>http://www.arnoldsafetyblog.com/do-you-have-a-question/comment-page-1/#comment-55118</link>
		<dc:creator>Eric Arnold</dc:creator>
		<pubDate>Wed, 18 Jan 2012 10:44:21 +0000</pubDate>
		<guid isPermaLink="false">http://www.fmcsacompliance.com/?p=38#comment-55118</guid>
		<description>You do not need a BOC-3 form designating a process agent in each state you operate if you are transporting your own product.  In other words, process agents are only required if you transport for hire.  The process agent requirement is a holdover from the old ICC regulations.  The way it was explained to me is a for-hire motor carrier is required to have a business agent in each state it operates.  Thus, if my Pennsylvania truck crashes and kills 6 people in Missouri, the people of Missouri don&#039;t have to come to Pennsylvania to sue me; they can sue my process agent in Missouri, and therefore me.  Anyway, that&#039;s how it was explained to me.... I do not have a great deal of expertise in the old ICC regulations.</description>
		<content:encoded><![CDATA[<p>You do not need a BOC-3 form designating a process agent in each state you operate if you are transporting your own product.  In other words, process agents are only required if you transport for hire.  The process agent requirement is a holdover from the old ICC regulations.  The way it was explained to me is a for-hire motor carrier is required to have a business agent in each state it operates.  Thus, if my Pennsylvania truck crashes and kills 6 people in Missouri, the people of Missouri don&#8217;t have to come to Pennsylvania to sue me; they can sue my process agent in Missouri, and therefore me.  Anyway, that&#8217;s how it was explained to me&#8230;. I do not have a great deal of expertise in the old ICC regulations.</p>
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		<title>By: Rosemary Czar</title>
		<link>http://www.arnoldsafetyblog.com/do-you-have-a-question/comment-page-1/#comment-54455</link>
		<dc:creator>Rosemary Czar</dc:creator>
		<pubDate>Thu, 05 Jan 2012 19:25:23 +0000</pubDate>
		<guid isPermaLink="false">http://www.fmcsacompliance.com/?p=38#comment-54455</guid>
		<description>Hello,

We are a project management company based in Nevada, that buys cabinets built per our specifications and then we install them on the customers jobsite that is usually out of state from our factory location in Michigan.  Most times we just use a freight carrier, but sometimes we rent a 26&#039; Penske truck and have our own team drive the cabinets to the jobsite location (more control, less damage.  We have him fill out the logbooks, he has a CSL, we have the correct insurances, he follows all the FMCSA rules for driving times, we actually insist on the safety aspect.
  In doing one of those runs today, our driver was told when he pulled into the weigh station that our company needed to have a DOT number.  When I went onto FMCSA and filled out their survey, it said I needed not only a OP-1 DOT number but a BOC-3 &quot;Designate Process Agent&quot;.  We do carry the proper insurances - always have.  My concern is a BOC-3 looks like I would need one for every state and that seems a bit much for hauling cabinets around the country.  Can you shed some light on this?  Please note, we probably only do 8-10 runs a year.  Thank you   Rosemary Czar</description>
		<content:encoded><![CDATA[<p>Hello,</p>
<p>We are a project management company based in Nevada, that buys cabinets built per our specifications and then we install them on the customers jobsite that is usually out of state from our factory location in Michigan.  Most times we just use a freight carrier, but sometimes we rent a 26&#8242; Penske truck and have our own team drive the cabinets to the jobsite location (more control, less damage.  We have him fill out the logbooks, he has a CSL, we have the correct insurances, he follows all the FMCSA rules for driving times, we actually insist on the safety aspect.<br />
  In doing one of those runs today, our driver was told when he pulled into the weigh station that our company needed to have a DOT number.  When I went onto FMCSA and filled out their survey, it said I needed not only a OP-1 DOT number but a BOC-3 &#8220;Designate Process Agent&#8221;.  We do carry the proper insurances &#8211; always have.  My concern is a BOC-3 looks like I would need one for every state and that seems a bit much for hauling cabinets around the country.  Can you shed some light on this?  Please note, we probably only do 8-10 runs a year.  Thank you   Rosemary Czar</p>
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		<title>By: Eric Arnold</title>
		<link>http://www.arnoldsafetyblog.com/do-you-have-a-question/comment-page-1/#comment-46248</link>
		<dc:creator>Eric Arnold</dc:creator>
		<pubDate>Tue, 07 Jun 2011 12:13:59 +0000</pubDate>
		<guid isPermaLink="false">http://www.fmcsacompliance.com/?p=38#comment-46248</guid>
		<description>Corrine:  You are subject to all of the safety rules, with the exception of drug and alcohol testing.  What do you have to do?  Keep time records, a driver qualification file, complete with a medical card, have maintenance records, including an annual inspection.  These are some of the main requirements.  I can tell you more over the phone.</description>
		<content:encoded><![CDATA[<p>Corrine:  You are subject to all of the safety rules, with the exception of drug and alcohol testing.  What do you have to do?  Keep time records, a driver qualification file, complete with a medical card, have maintenance records, including an annual inspection.  These are some of the main requirements.  I can tell you more over the phone.</p>
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		<title>By: Corrine</title>
		<link>http://www.arnoldsafetyblog.com/do-you-have-a-question/comment-page-1/#comment-45948</link>
		<dc:creator>Corrine</dc:creator>
		<pubDate>Sat, 28 May 2011 17:56:05 +0000</pubDate>
		<guid isPermaLink="false">http://www.fmcsacompliance.com/?p=38#comment-45948</guid>
		<description>I drive a box truck 12,000 gvw i go state to state i am the owner of the truck. i am a new entrant and the dot says 18 months safety audit what does this mean and what do i have to do. i drive less than 60 miles in a day. I am so confused.</description>
		<content:encoded><![CDATA[<p>I drive a box truck 12,000 gvw i go state to state i am the owner of the truck. i am a new entrant and the dot says 18 months safety audit what does this mean and what do i have to do. i drive less than 60 miles in a day. I am so confused.</p>
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		<title>By: Eric Arnold</title>
		<link>http://www.arnoldsafetyblog.com/do-you-have-a-question/comment-page-1/#comment-37418</link>
		<dc:creator>Eric Arnold</dc:creator>
		<pubDate>Tue, 11 May 2010 16:43:01 +0000</pubDate>
		<guid isPermaLink="false">http://www.fmcsacompliance.com/?p=38#comment-37418</guid>
		<description>Paul:  welcome to my little corner of the Internet.  I&#039;ll try to answer your question.  I do not think you would fall under the 100 air mile exemption, so I would say you should be logging every day.  You would fall under the 70 hours in 8 day rule, as it sounds like your company will occasionally work on any and all days of the week, including Sunday.

You fall under the 14 hour rule.  There are some exceptions, but generally speaking you get 14 hours a day, and then must take a 10 hour break.  As to your current situation... are you over hours?  Yeah, probably.  You only get 70 hours in 8 days, unless you have a 34 hour off-duty period, which resets it back to zero.

Yes, there are occasionally emergency exemptions which are issued.  For example, I got an email this morning from the Pennsylvania Motor Truck Association informing me the DOT has issued an hours of service exemption for carriers assisting in the Gulf of Mexico cleanup.  I don&#039;t know if any waiver has been issued for the Nashville floods.  I looked on DOT&#039;s website I didn&#039;t see any.

I once took a 26.2 mile tour of Nashville (I ran the Nashville Marathon).  Nice town.</description>
		<content:encoded><![CDATA[<p>Paul:  welcome to my little corner of the Internet.  I&#8217;ll try to answer your question.  I do not think you would fall under the 100 air mile exemption, so I would say you should be logging every day.  You would fall under the 70 hours in 8 day rule, as it sounds like your company will occasionally work on any and all days of the week, including Sunday.</p>
<p>You fall under the 14 hour rule.  There are some exceptions, but generally speaking you get 14 hours a day, and then must take a 10 hour break.  As to your current situation&#8230; are you over hours?  Yeah, probably.  You only get 70 hours in 8 days, unless you have a 34 hour off-duty period, which resets it back to zero.</p>
<p>Yes, there are occasionally emergency exemptions which are issued.  For example, I got an email this morning from the Pennsylvania Motor Truck Association informing me the DOT has issued an hours of service exemption for carriers assisting in the Gulf of Mexico cleanup.  I don&#8217;t know if any waiver has been issued for the Nashville floods.  I looked on DOT&#8217;s website I didn&#8217;t see any.</p>
<p>I once took a 26.2 mile tour of Nashville (I ran the Nashville Marathon).  Nice town.</p>
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		<title>By: Paul</title>
		<link>http://www.arnoldsafetyblog.com/do-you-have-a-question/comment-page-1/#comment-37387</link>
		<dc:creator>Paul</dc:creator>
		<pubDate>Mon, 10 May 2010 04:11:46 +0000</pubDate>
		<guid isPermaLink="false">http://www.fmcsacompliance.com/?p=38#comment-37387</guid>
		<description>Eric, I have several questions that are not your run of the mill. We are an emergency response company and do a lot of work for the railroad and storm clean-up. Our office is located in the St. Louis area. When called out we mobilize to affected area and set-up a local office or we contact our contractor who has a local office set-up. I understand that we must log in route to site, but once there do we fall under the 100 mile rule? If we are not on the roadways (we run high-rail dumps)do we fall under the 14 hr a day 60 hrs in 7 day rule? We often work long hours every day until the rail is back up and running. If I understand correctly, working 15 hrs a day seven days a week in our dumps, on the rail, puts us out of complaince everyday, not to mention we have run out of hours before the week is up. Are there special regulations regarding state of emergencys? We are currently in the Nashville area working on the rail and when that is completed we will start clean up of debris around the city. We tend to work seven days a week and 14-16 hours a day in these circumstances. I have worked 81.5 hours in the last 6 days. Our office says we need to fill out our log books, but they can&#039;t answer these questions. I&#039;m not sure how to fill this out since we would be way out of complaince. I can&#039;t seem to find any answers on the DOT site, please help. Thanks, Paul</description>
		<content:encoded><![CDATA[<p>Eric, I have several questions that are not your run of the mill. We are an emergency response company and do a lot of work for the railroad and storm clean-up. Our office is located in the St. Louis area. When called out we mobilize to affected area and set-up a local office or we contact our contractor who has a local office set-up. I understand that we must log in route to site, but once there do we fall under the 100 mile rule? If we are not on the roadways (we run high-rail dumps)do we fall under the 14 hr a day 60 hrs in 7 day rule? We often work long hours every day until the rail is back up and running. If I understand correctly, working 15 hrs a day seven days a week in our dumps, on the rail, puts us out of complaince everyday, not to mention we have run out of hours before the week is up. Are there special regulations regarding state of emergencys? We are currently in the Nashville area working on the rail and when that is completed we will start clean up of debris around the city. We tend to work seven days a week and 14-16 hours a day in these circumstances. I have worked 81.5 hours in the last 6 days. Our office says we need to fill out our log books, but they can&#8217;t answer these questions. I&#8217;m not sure how to fill this out since we would be way out of complaince. I can&#8217;t seem to find any answers on the DOT site, please help. Thanks, Paul</p>
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		<title>By: kary</title>
		<link>http://www.arnoldsafetyblog.com/do-you-have-a-question/comment-page-1/#comment-10838</link>
		<dc:creator>kary</dc:creator>
		<pubDate>Wed, 03 Dec 2008 23:08:18 +0000</pubDate>
		<guid isPermaLink="false">http://www.fmcsacompliance.com/?p=38#comment-10838</guid>
		<description>Hello, iam a subcontractor that hauls building material produts i drive a sixteen ft box truck 14,500 gvwr, do i have to have placards on it when im halling paint???</description>
		<content:encoded><![CDATA[<p>Hello, iam a subcontractor that hauls building material produts i drive a sixteen ft box truck 14,500 gvwr, do i have to have placards on it when im halling paint???</p>
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		<title>By: Tim</title>
		<link>http://www.arnoldsafetyblog.com/do-you-have-a-question/comment-page-1/#comment-8072</link>
		<dc:creator>Tim</dc:creator>
		<pubDate>Fri, 22 Aug 2008 01:45:38 +0000</pubDate>
		<guid isPermaLink="false">http://www.fmcsacompliance.com/?p=38#comment-8072</guid>
		<description>I drive a 1 1/2 to job and work all day then go to the room Do I have to log  truck use just to drive back to hotel  are there hrs restriction to this we work 10 - 12 hr days  with a 1 hr lunch hotel is 6 miles away</description>
		<content:encoded><![CDATA[<p>I drive a 1 1/2 to job and work all day then go to the room Do I have to log  truck use just to drive back to hotel  are there hrs restriction to this we work 10 &#8211; 12 hr days  with a 1 hr lunch hotel is 6 miles away</p>
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		<title>By: Eric Arnold</title>
		<link>http://www.arnoldsafetyblog.com/do-you-have-a-question/comment-page-1/#comment-7964</link>
		<dc:creator>Eric Arnold</dc:creator>
		<pubDate>Sat, 16 Aug 2008 14:57:46 +0000</pubDate>
		<guid isPermaLink="false">http://www.fmcsacompliance.com/?p=38#comment-7964</guid>
		<description>I think you can drive over there with your intrastate DOT number.  Your truck will not be impounded if you get stopped.  I don&#039;t think you will get a ticket for having an &quot;intrastate&quot; DOT number..... they&#039;ll probably be happy you have a number at all.  You will get a bunch of tickets if you don&#039;t have the other things, like a medical certificate, logbook, etc. though.</description>
		<content:encoded><![CDATA[<p>I think you can drive over there with your intrastate DOT number.  Your truck will not be impounded if you get stopped.  I don&#8217;t think you will get a ticket for having an &#8220;intrastate&#8221; DOT number&#8230;.. they&#8217;ll probably be happy you have a number at all.  You will get a bunch of tickets if you don&#8217;t have the other things, like a medical certificate, logbook, etc. though.</p>
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		<title>By: steve</title>
		<link>http://www.arnoldsafetyblog.com/do-you-have-a-question/comment-page-1/#comment-7951</link>
		<dc:creator>steve</dc:creator>
		<pubDate>Sat, 16 Aug 2008 03:24:41 +0000</pubDate>
		<guid isPermaLink="false">http://www.fmcsacompliance.com/?p=38#comment-7951</guid>
		<description>Eric,
 I have a non cdl truck listed  with dot as intrastate.  However a friend of mine lives one state over from me. I need to borrow a piece of equipment from him.  Can I drive over and pick this equipment up or If I drive over the state line will I be subjected to possiable impoundment 

thanks, Steve</description>
		<content:encoded><![CDATA[<p>Eric,<br />
 I have a non cdl truck listed  with dot as intrastate.  However a friend of mine lives one state over from me. I need to borrow a piece of equipment from him.  Can I drive over and pick this equipment up or If I drive over the state line will I be subjected to possiable impoundment </p>
<p>thanks, Steve</p>
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