Do I need a DOT and MC Number

As a limo company do I need a DOT and MC number?


The Federal Motor Carrier Safety Administration (FMCSA) issues two numbers to companies engaging in commercial transportation. The first is the United States Department of Transportation, or DOT number. The DOT number serves as a unique identification number for all motor carriers for the purpose of collecting safety data, compliance information, and accident investigations. The second is the FMCSA Motor Carrier, or MC number, often referred to as operating authority. An MC number is another unique number assigned to carriers that transport passengers.

Most people think that interstate commerce means crossing state lines in the vehicle, but they’re wrong. In May 2014, the FMCSA released an updated explanation to interstate commerce. The clarification explained that the airport is a port of entry for interstate cargo, mainly your passengers. That means that if you pick up an out of state passenger, or accept bookings for a CMV from out of state affiliates, you are engaged in interstate commerce.

So what does all this mean?

This means that most limo companies must be registered with the DOT and have an MC number. If you operate any vehicles over 8 passengers, this also means that each driver in your fleet must comply with federal law, and you as an owner must maintain vehicle and driver records as required by the FMCSA. These include complete driver qualification files, hours of service records, previous employer checks, and records of vehicle maintenance. This also means that you can be selected for roadside inspections or for a full DOT audit at any time.

Where do I Start?

Start by familiarizing yourself with the rules at

More helpful hints can also be found at or you can call us at (210)259-7470.

DQ File Checklist

Upon being audited one of the first things an inspector will want to see is a companies driver qualification (DQ) files. There is a good reason for this; it is typically the place where they can find the highest violation rate among carriers. Why is this, they tell you exactly what needs to go it these files so why is it so hard to get it right?

DQ files are a labor intensive administrative task that rarely is done by a person that understands the importance, or the procedures that need to go into these federally required files. Steps are often overlooked either because the person doing them doesn’t know it needs to be done, or because they have a dispatch department telling them that they have to have drivers to cover the next ride.

Here is a DQ File Checklist to help you know what needs to be in a DQ file and at what point in the hiring process it need to be done before a driver can get behind the wheel?


  • 391.23 Applicant was notified of their rights concerning Safety Performance History


  • Applicant signed Fair Credit Reporting Act Disclosure*


  • 391.21 Completed Driver Specific Application
  • Receipt of Substance Abuse Policy – Prior to testing (CDL)
  • Negative Pre-employment Drug Screen Results Received (CDL)
  • Certification that the Applicant Did Not Fail or Refuse Any Drug or Alcohol Screening for a Company They Did Not Become Employed By Within the Last Two Years (CDL)
  • 391.31 OR 391.33(a)(1) Certificate Road Test or Copy of Driver CDL
  • 380.509(b) Entry Level Driver Training Certificate if the driver is a new CDL 380.509(b)
  • 391.43 Copy of the Driver’s Current Medical Card
  • 391.11 AND 391.13 Certify the Applicant’s Qualification
  • Verify that the driver was certified by a medical examiner listed on the National Registry
  • Driver Certification of Last 7 Days of Duty Status*


  • 391.23 MVR from Every State Driver has been Licensed in over the Last Three Years
  • Written Authorization to Obtain Drug and Alcohol History*
  • 391.53  Safety Performance History or Good Faith Effort for all DOT-Regulated Employers over the Last Three Years


  • 391.25 Obtain MVR for the last 12 months
  • 391.27 Driver Certification of Traffic Convictions
  • 391.25 Annual Review of Driver Qualification

All DQ files must be maintained for 3 years after the driver leaves the company.

Contact us to make sure all of your DQ files are always done correctly.

Bus Maintenance

Bus Maintenance Plan

Vehicle and bus maintenance is an ongoing part of any commercial fleet, but is even more demanding in the world of limo and bus providers. As one truck driver told me, “Freight don’t talk!”

Ongoing fleet maintenance record keeping and repairs is a lengthy, complicated subject, so this post will only cover part 396 of FMCSA regulations.

Systematic maintenance is required by 396.3. This means the motor carrier must have a maintenance plan, and show adherence to the plan. FMCSA does not regulate maintenance intervals or best practices. The only requirement about lubricants is that the vehicle is “properly lubricated” and free of leaks.

The motor carrier must test all push-out windows, emergency doors and emergency door marking lights at least every 90 days. As a best practice, such checks should be done monthly or alternating months in order to ensure 90 days is not exceed.

Bus maintenance records must include markings with make, VIN, year and tire size, as well as leasing company if applicable.
Records should also include evidence of 90 ­day inspections, as well as records of inspection, repairs and maintenance performed.

Driver vehicle inspection reports for each vehicle must be kept on file for 3 months. More information on these reports can be found HERE. As a best practice, evidence repairs were completed may be attached to the original report as well as the required certification by the motor carrier. Technological advances are allowing companies to perform better daily vehicle inspections, and be more efficient in tracking not just mechanical damage, but body damage as well.  To learn more about this visit Pocket Fleet Manager or Limo Logs.

Annual inspections are required for all DOT vehicles. Originals are part of the required vehicle record and must be kept for 14 months.

Part 396.7 spells out that no motor vehicle shall be operated in such a condition likely to cause accident or breakdown. The only exemption is if it less hazardous to proceed to the nearest safe place to conduct repairs.

If a roadside inspection finds any violation or defect, the motor carrier has 15 days to certify that the violation has been corrected and return it to the issuing agency. Copies must be kept by the motor carrier for 12 months.


Brake inspectors utilized by a motor carrier must meet the requirements outlined in 396.25. Evidence of inspector qualifications must be kept on file for at least one year after the inspector’s last date of work or utilization.

Systematic bus maintenance is not only a best practice, it’s the law. Limo & Bus Compliance can work with you to create a plan that minimizes your downtime, keeps you compliant and extends the life of your vehicles.

Driver Vehicle Inspection Report (DVIR)

What is a DVIR?

A Driver Vehicle Inspection Report (DVIR) is a record of inspection done on commercial motor vehicles in accordance with 396.11. This report is required for all passenger carrying commercial motor vehicles falling under the purview of the FMCSA.

A recent exemption for the recording of satisfactory inspections does not apply to passenger carriers.

When should an inspection be done?

An inspection should be done daily prior to beginning work in each new vehicle, and upon completion of work in each vehicle.

What is included in the inspection?

A proper inspection must include at minimum:

• Inspection of brakes and parking brake
• Steering mechanism
• Lights and reflectors
• Tires
• Horn
• Windshield wipers
• Rear vision mirrors
• Wheels and rims
• Emergency Equipment

How should the inspection be documented?

The driver should document both pre-trip and post-trip inspections on their driver daily log. This inspection should also be recorded in the Driver Vehicle Inspection Report (DVIR) book for all vehicles that seat 9 or more passengers (including driver).

Our recommendation is that if a company is utilizing paper inspection sheets then the only defects to be recorded on this form are those that would affect the safety of operation of the vehicle or result in its mechanical breakdown. If such defect is found on the pre-trip inspection – the driver shall not operate the vehicle.

Any defect that does not affect the safety of operation of the vehicle or result in its mechanical breakdownshould be recorded on a separate form.

A new and more efficient option for documenting all defects, and tracking maintenance as well as tracking body damage is by using Pocket Fleet Manager or Limo Logs.  Both programs not only track required vehicle maintenance, but also assist in tracking other areas of compliance as well.

What happens if a defect is found?

If a defect is found that would affect the safety of operation of the vehicle or result in its mechanical breakdown, the vehicle is immediately out of service. The driver should mark the DVIR as unsatisfactory and immediately notify their chain of command or designated company representative.

Prior to returning the vehicle to duty the company or its agent must certify that the repairs have been completed or that the repair was not necessary to prevent unsafe operation or mechanical breakdown. The report must also be signed by the next authorized operator of the vehicle certifying that the repairs were completed.

How long should DVIRs be kept?
The FMCSA requires that DVIRs and related documentation be kept for 3 months from the date received.



Why Outsource Compliance
Compliance is an ever-changing environment, and your business deserves your full attention. Instead of dedicating precious management time to maintaining a compliance program, documents can simply be scanned by an overnight dispatcher. By outsourcing to a professional DOT Compliance company, you can rest easy knowing that you are always audit ready at a fraction of the cost.

How Does it Work
We will provide you with packets to complete, simply fill them out and send them back. For vehicle inspection reports and driver logs, all you have to do is scan them to us and we will send you back a weekly report. For those that prefer an in-person touch, we can come to your facility and conduct a mock audit or staff training. Should a question arise, we’re only a phone call away.

Driver Qualification Files
The employer must maintain driver qualification files on any driver who operates a commercial motor vehicle (CMV). A CMV is defined as any vehicle with a GMVR of over 10,000 lbs, or designed to carry 9 or more people.
Click Here

What needs to be in a driver qualification file?
Driver Qualification Files must contain the following:
• Driver’s application for employment
• Inquiry to previous employers — driving record for
last 3 years;
• Annual inquiry and review of driving record;
• Annual driver’s certification of violations and annual
• Driver’s road test and certificate, or the equivalent to the
road test;
• Medical examiner’s certificate; and
• If granted, a waiver of physical disqualification for a person
with a loss or impairment of limbs as specified in § 391.49.
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Do I need to track Hours of Service for my non-CDL drivers?
Any driver that leaves the state or goes to the airport in a vehicle designed for 9 of more passengers is an interstate commercial motor vehicle operator.  These driver are subject to the same Hours of Service regulations as a CDL driver.  That means you are responsible for ensuring compliance with the 70-hour 8-day or 60-hour 7-day rules; including non-driving time for other employers.  You must also ensure these drivers do not exceed the daily hours of service regulations for passenger carriers.

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Should I use the 100 Air-Mile Rule or keep traditional logs?
Commonly referred to as the 100 Air-Mile Rule, this exception allows the company to maintain records of in-time, out-time and hours worked instead of traditional logs.  This exception requires that the driver not exceed a 100 Air-Mile radius (for most states) and not work more than 12 consecutive hours, regardless of off-duty time.  This means that if the driver comes to work at 7am, they are not eligible to work past 7pm.  This deviation from the typical 10 driving, 15 on duty rule, can cause a shortage of CDL drivers in many operations.  We’ll work with you to evaluate your needs, train your staff, and decide which method is best for your company

What if I remove a couple seats?
The DOT recognizes the manufacturers vehicle rating or the number the vehicle carries, whichever is greater. Removing seats has no bearing on whether or not it is considered a commercial motor vehicle.

How do I know what drivers to include in my drug pool?
Generally, all CDL drivers who operate commercial motor vehicles are subject to DOT drug and alcohol testing (§382.103). This includes all full-time, part-time, intermittent, backup and international drivers.

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My driver was just in an accident, do I need to test them?
To maintain compliance only send a driver for a DOT Post-Accident test be done if they meet the requirements below:

Type of accident involved
i. Human fatality – YES
ii. Bodily injury – Only if the driver was cited
iii. A vehicle is towed – Only if the driver was cited

Non-DOT tests may be used for other instances if supported by company policy.

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I only have one sprinter. Do I really need a DOT number?
YES: If you transport passengers to and from the airport, or cross state lines in any vehicle designed to transport more than 9 passengers you must have a Motor Carrier and DOT number. You are also required to maintain fully documented compliance records.

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Logs for Non-CDLs – Why you may want to require them

If you’re reading this, I’ll assume your goal is to be safe and compliant.  One of the hardest areas for most of our industry clients is the implementation of hours of service tracking (LOGS), for non-CDL drivers who operate vans or limos.

If you’re reading this, I’ll assume your goal is to be safe and compliant.  One of the hardest areas for most of our industry clients is the implementation of hours of service tracking (LOGS), for non-CDL drivers who operate vans or limos.

Please do not use the 100 Air-Mile Exception without reading our FAQ Page.

As we’ve covered earlier, any driver operating a van or limo and going to the airport (arrival or departure) must follow most of the same rules as a CDL operating in interstate commerce.  From a practical standpoint, there are three separate implementation strategies to gain compliance.

  • Option 1:  Only use CDL drivers in vans and limos
    • Pros
      • No additional training or pushback
      • No additional cost
      • Fewer logs to audit
    • Cons
      • Shortage of CDLs
      • Reduces dispatch flexibility
  • Option 2:  Create a pool of van/limo eligible non-CDL drivers
    • Pros
      • More dispatching choices
      • Fewer individuals to train
      • Flexibility with hours of service overages in sedans and SUVs
    • Cons
      • More liability than following HOS regulations for all
      • Can create challenges with last minute van/limo runs
      • Moderate dispatch flexibility
      • Additional cost for Med Cards
  • Option 3:  Train and qualify all drivers for all vehicle types that their license allows
    • Pros
      • Most flexibility in vans and limos
      • Safest, least liability
      • Lessens risk of non-compliance
      • Larger sample of correct logs/dq files to offset errors
    • Cons
      • Pushback from drivers
      • Additional training
      • Additional log verification/HOS tracking
      • Additional cost for Med Cards

There is no one size fits all solution, but hopefully this information will help streamline the discussion in your organization.

Click here for more information on rules concerning HOS 


ELDs are electronic logging devices. These units plug into the vehicle and are designed to automatically create a record each time the vehicle moves. The goal is prevent companies and drivers from creating false logs in an effort to cover more distance or work more hours.

Depending on your operation, you may not need ELD’s.  The FMCSA exempts any driver who is covered by the 100 air mile exemption and does not exceed it more than 8 times in a 30 day period is not required to utilize ELD’s.

This means, if your drivers generally start at and return to base within 12 hours and stay within 115 miles, they probably do not need ELDs.

See our webinar and summary for LCT Magazine.

ELDs work with electronic logs, but having electronic logs does not require ELDs. For most companies they’re simply an added expense and an administrative nightmare. Imagine the burden created by having to log every time a vehicle moves around the lot.

Limo & Bus Compliance will help you decide if you need ELDs and if you do, we have a fully integrated solution with LimoLogs. If you don’t, we invite you to explore LimoLogs or PocketFleetManager to help simplify your compliance and fleet management.

For those companies who have chosen another solution, we offer outsourced program management for all the most common providers.

For more information on Limo Logs CLICK HERE

If you are looking for a DVIR solution, that doesn’t add logs check out Pocket Fleet Manager.