INFORMATION: Implementing the Performance and Registration Information Systems Management Change Eliminating the Registrant-Only Designation PURPOSE

This guidance is related to the Federal Motor Carrier Safety Administration (FMCSA) notice in the Federal Register on August 9, 2010, (FR 75 47883) that announced a Performance and Registration Information Systems Management (PRISM) procedural change eliminating the company operation designation Vehicle Registrant Only and changing the PRISM procedure that required vehicle registration agencies in PRISM States to collect a U.S. Department of Transportation (USDOT) number from certain entities. This change was originally to take effect on September 1, 2011. However, based on feedback from the industry to the implementation date was extended to September 1, 2012. (FR 76 54288) BACKGROUND Since 1999, the Vehicle Registrant Only (Registrant) company operation type has been an option available when registering for a USDOT number. This company operation type designates the company as a non-motor carrier. Therefore, it is not authorized to operate in interstate commerce. Two reasons to obtain a Registrant-Only USDOT number were: 1. The company owns and registers its commercial trucks for the sole purpose of renting or leasing them to motor carriers that will operate the trucks to transport goods. 2. The company is an owner-operator that is leased to a motor carrier and will never operate the truck(s) under its own USDOT number or Operating Authority. The procedures for participating PRISM States have required a USDOT number for everyone that must register a vehicle. Currently, over 200,000 Registrant-Only USDOT numbers exist in FMCSA databases. There are two problems that have resulted from the use of Registrant-Only USDOT numbers: 1. Data quality: There should be no safety events (inspections or crashes) associated with these Vehicle Registrant-Only companies, since there is no authority to operate as motor carriers. However, safety events are being improperly attributed to the USDOT number of the Registrant-Only entity instead of the USDOT number of the motor carrier responsible for safety. This has required significant effort to correct the attribution of safety events. 2. Enforcement: Registrant-Only companies are not included in the Safety Management System (SMS); the Agency is not currently conducting safety investigations or New Entrant Safety Audits on those companies. Therefore, if the Registrant operates as a motor carrier, it is evading FMCSA oversight. The FMCSA is initiating a change to resolve these two issues. The Agency is eliminating the use of Registrant-Only USDOT numbers. In addition, the PRISM program is eliminating the procedure

requiring PRISM States to complete the USDOT number field on the vehicle registration when the company is, not a motor carrier. The PRISM States will be completing the necessary system changes at different times depending on the States available resources and priorities. Some States have already completed the system changes and no longer require a USDOT number for non-motor carrier owner-operators or non-motor carrier leasing companies. Other States are still in the process of completing the systems changes and plan to implement the change on or before September 1, 2012. A small number of States will be implementing the systems changes after September 1, 2012. GUIDANCE The FMCSA PRISM procedures will now require that Registrant-Only companies will be identified as such by a special indicator within the registration system, as opposed to using a USDOT number. It is suggested that State vehicle registration systems be changed so that the registration box for USDOT number accepts either an alpha or numeric value. For registrants that have the two types of operations noted above, REGONLY should be entered into the USDOT number field, or the field should be left blank. Some states may supply their own numeric identifier to track Registrants. Rental/leasing companies will still be able to register vehicles by providing the USDOT number of the motor carrier responsible for safety of the vehicle. If the motor carrier that is responsible for safety cannot be identified, with a corresponding TIN, then the leasing company or owner-operator must obtain their own USDOT number using one of the other available designations as the company operation. The Vehicle Registrant-Only designation will no longer exist as a Company Operation option on the Form MCS-150 or as an option on a cab registration card. Companies that currently have a Registrant-Only USDOT number will be advised via a letter from the Enforcement Division that their Registrant USDOT number will be made Inactive effective [DATE]. They will further be informed that, if they operate as a motor carrier, they will need to file an MCS150 updating their company operation type to one of the other options in box 22 of the Form MCS150 (Interstate Carrier, Intrastate Hazmat Carrier, Intrastate Non-Hazmat Carrier, Interstate Hazmat Shipper, Intrastate Hazmat Shipper). Some leasing companies and owner operators that are leased on to a motor carrier may need to update their MCS-150 changing their designation to motor carrier in some cases when the motor carrier responsible for safety cannot be identified by the lessor at the time of registration. A subset of the Registrant population, those with evidence of operations as a motor carrier, will be identified and notified via a separate mailing, issued at approximately the same time as the letter to the larger Registrant population, that their USDOT number will be changed from Registrant to Interstate Carrier. The Division Offices, in conjunction with States, should continue to review and investigate the inspection and crash events attributed to Inactive (former Registrant-Only) records and assign the events to the proper motor carrier record in the Motor Carrier Management Information System (MCMIS). When the event occurred as a Registrant however was in fact operating as a motor carrier,

the company operation designation must be changed to motor carrier, either interstate or intrastate, as appropriate. When completing or updating an MCS-150, companies or IRP/FMCSA staff completing the form on their behalf, are encouraged to use the box in section 23 marked Other and fill in Leasing Co when the vehicle registrant is a leasing company that will never operate as a motor carrier. Specific instructions for International Registration Plan (IRP) staff handling vehicle registrations for former Registrant-Only companies are included in the manuals for IRP staff. The manuals are located on the PRISM Web page on the FMCSA Web site and are titled PRISM Registration Staff Training Package. The address is: http://www.fmcsa.dot.gov/safety-security/prism/prismresources.aspx#Training EFFECTIVE DATE: This guidance is effective September 1, 2012. CONTACT: For questions concerning this guidance, contact Steve Parker, Transportation Specialist, Enforcement Division, at 202-366-3407 or by e-mail at stephen.parker@dot.gov ATTACHMENTS: (In process) Attachment A: Frequently Asked Questions (In process) Attachment B: Letter Informing Registrants of the PRISM Procedural Change and informing of the FMCSA intention to make the Registrant USDOT number Inactive (In Process) Attachment C: Letter Informing Certain Registrants of the PRISM Procedural Change and informing of the FMCSA intention to make the Registrant USDOT number an Interstate Carrier USDOT number