One way that shoddy trucking companies stay a step ahead of the law is to ditch their old identities and apply for an authority under a new name. These reincarnated companies are called chameleon carriers, and in the United States the FMCSA has been working on a new Unified Registration System designed in part to screen out these unsafe or unsavory operators.
This vetting process will try to identify carriers with “chameleon attributes” by analyzing databases like SAFER, EMIS, MCMIS, and Dun & Bradstreet. If you have a record of a severe crash, an out-of-service order, an unsatisfactory or unfit rating, or a bankruptcy, it will factor into how you’re assessed.
This system only works if those databases contain valid, up-to-date information. For instance, the FMCSA is placing greater emphasis on cross-checking new MCS-150 applications against existing carrier records, looking for companies with a shared address and other clues about the applicant’s true identity.
It begs the question: if you have a USDOT number, when was the last time you checked your Motor Carrier Identification Report (MCS-150)?
Keeping Current with MCS-150
Your USDOT number is a unique identifier for agencies that collect and monitor information about audits, compliance reviews, crash investigations, and inspections involving your business, vehicles, and drivers.
By law, all motor carriers operating commercial motor vehicles in interstate commerce must update their MCS-150 information every 24 months based on a schedule in §390.19 of the Federal Motor Carrier Safety Regulations (FMCSRs), although you can update it whenever you need to (for instance, if there’s a change of address or the number of vehicles or drivers you have). Even if the information on your form has not changed, you still must file a biennial update.
Canadian carriers who travel to the U.S. fall under the very same regulations and have to keep their MCS-150 up to date.
This rule also applies to intermodal equipment providers and hazardous materials safety permit holders and applicants. Starting in October 2015, it will apply to freight brokers, freight forwarders, and cargo tank facilities as well.
What If I Don’t Update My MCS-150?
If you fail to keep your MSC-150 profile current, the FMCSA will issue a federal out-of-service order and set your USDOT number to “inactive” status, as if you’re no longer in business.
Without an active USDOT number, your vehicle registration may be suspended or revoked. You may also face fines of up to $1,000 a day for non-compliance and be subject to citations if you’re caught operating without a valid USDOT number.
How Do I Update My MCS-150?
You should get a warning letter 30 days before the deadline for your biennial update with instructions and a PIN so you can update the information online (applicants who file electronically must submit a valid credit card number as their electronic signature). FMCSA wants you to use the online application process since it has simple yes-or-no questions and automatically checks for errors. It’s also faster: biennial updates are processed immediately if done online but can take three or four weeks to process by fax or mail.
Of course, you can view and update your information any time using the FMCSA PORTAL at https://portal.fmcsa.dot.gov/login. If your information is more than 24 months old, update it right away.
Keeping your MCS-150 profile current is simple and it’s free, but it’s easy to forget about because you only need to do it every two years. If you don’t stay current, you could be seen as having chameleon attributes—and be stripped of your USDOT number.