Hotshot trucking requirements: CDL, DOT number, medical card, ELD and insurance

A hotshot rig, typically a heavy pickup pulling a gooseneck or flatbed trailer, needs a Class A CDL when the truck and trailer ratings add up to 26,001 pounds or more and the trailer is rated over 10,000 pounds. Below that it runs without a CDL, but once the combination reaches 10,001 pounds and hauls freight across state lines, it is a commercial motor vehicle: you need a USDOT number, a DOT medical card, hours-of-service records (usually an ELD) and annual inspections. A for-hire hotshot hauling for others across state lines also needs operating authority, a BOC-3 process agent filing and liability insurance on file. "Hotshot" is not a term in the regulations; the rules follow the weights and the kind of operation.

The two weight lines

Both definitions count the whole combination, not only the pickup. Under 383.5 and 390.5T, the gross combination weight rating is the greater of the rating on the power unit’s certification label or the sum of the GVWRs (or weights) of the truck and trailer. And both use rating or actual weight, whichever is greater, so an overloaded rig can cross a line its labels stay under.

Do you need a CDL for hotshot?

Add the GVWR on the pickup’s door label to the GVWR on the trailer’s VIN plate.

• Total 26,001 or more and trailer over 10,000: Group A, Class A CDL.
• Trailer 10,000 or less: never Group A. With a pickup well under 26,001 on its own, no CDL.
• Total 26,000 or less: no CDL, whatever the trailer, as long as actual weights stay within the ratings.

Example: common setups

Examples, applying 383.5 and 390.5T. The ratings are illustrative; use your own labels.

The first row shows the point many new hotshot drivers miss: a pickup under 10,001 pounds is not a CMV by itself, but hitched to a trailer the combination is. A loaded gooseneck in the 25,500 row that scales at 26,300 with a trailer weighing over 10,000 has become a Group A combination on the day, even though the labels say otherwise.

Some operators keep under 26,001 on purpose to run without a CDL; that is legal if the ratings and the actual weights both stay under the line. It also limits how much freight the rig can carry legally. If you want to haul the heavier loads, the how to get a CDL page sets out the steps, and the do you need a CDL page covers other vehicle types.

Registration: the USDOT number

A motor carrier conducting operations in interstate commerce must file Form MCS-150 with FMCSA before it begins operations and every 24 months after (390.19T(a)(1), (b)). That filing is what gives you a USDOT number. The number, preceded by "USDOT", and your legal or trade name as filed, go on both sides of the power unit in letters that contrast with the background and are readable from 50 feet in daylight when the vehicle is stopped (390.21T(b), (c)). Magnetic signs are common on pickups that also serve as personal vehicles; the rule sets the result, not the method.

Operating authority, BOC-3 and insurance for for-hire hotshots

If you haul other people’s freight for pay across state lines, you are a for-hire carrier and three more filings apply:

• Operating authority (the MC number): applications for authority to operate as a motor carrier of property are governed by Part 365 (365.101T(a)).
• BOC-3: a designation of agents for service of process on Form BOC-3, covering each state you are authorized to operate in and each state you pass through (366.2T, 366.4T(a)). Process agents are listed in the BOC-3 agent directory.
• Insurance: minimum public liability set in Part 387, summarized below.

A hotshot that only moves its owner’s own goods, for example a contractor carrying its own equipment, is a private carrier. It still needs the USDOT number and the safety rules when it meets the CMV definition, but not operating authority.

Insurance minimums

The Part 387 Subpart A minimums do not apply to a motor vehicle with a GVWR under 10,001 pounds, except for certain high-hazard materials (387.3(c)(1)). How a light pickup pulling a heavy trailer is rated for insurance purposes is a question to settle with your insurer and on your FMCSA filing before you haul; do not assume the pickup’s label alone decides it. These are federal floors. Brokers and shippers can require more by contract, and cargo coverage is a commercial matter the minimums above do not address.

The driver: qualification and medical card

A driver of a 10,001-pound CMV in interstate commerce must meet Part 391 whether or not a CDL is needed:

• be at least 21 and able to read and speak English well enough for the job (391.11(b)(1), (2));
• be medically certified by a registered examiner (391.41(a)). A non-CDL driver gets a paper certificate from the examiner (391.43(g)(2)(ii)) and carries it, or a copy, when on duty (391.41(a)(1)(i)). A CDL holder’s certificate goes to the state electronically; see the CDL medical card page;
• have a driver qualification file kept by the carrier, including the employment application, motor vehicle records, road test certificate or equivalent, and the medical certificate (391.51(b)). An owner-operator running under its own USDOT number keeps its own file.

Examiners are listed in the DOT physical directory.

Drug and alcohol testing

Part 382 testing applies to drivers subject to the CDL requirements of Part 383 (382.103(a)(1)). A non-CDL hotshot is outside it. A Class A hotshot is inside it, and an owner-operator who employs only himself must have a random testing program with a selection pool of two or more covered drivers, which in practice usually means joining a consortium (382.103(b)). The DOT drug testing guide covers the program.

Hours of service and the ELD

Hotshot drivers in interstate commerce run under the same limits as tractor-trailer drivers: 11 hours of driving inside a 14-hour window after 10 hours off, a 30-minute break after 8 hours of driving, and 60 or 70 hours in 7 or 8 days (395.3). The hours of service guide explains each limit, and the HOS calculator works them out for a given day.

Records of duty status are kept on an ELD (395.8(a)(1)(i)), with these exceptions that matter for hotshots:

• Short-haul, non-CDL (395.1(e)(2)): a driver of a property-carrying CMV that does not require a CDL, staying within 150 air miles of the normal reporting location and returning there each day, needs no log and may drive until the 14th hour on 5 days and the 16th hour on 2 days in any 7. The carrier keeps time records for 6 months.
• Short-haul, CDL (395.1(e)(1)): within 150 air miles, released within 14 hours, with time records instead of logs.
• 8 days in 30: a driver who needs a log on no more than 8 days in any 30-day period may use paper (395.8(a)(1)(ii)(A)).
• Pre-2000 vehicles: a vehicle manufactured before model year 2000, as shown by the VIN on the registration, may use paper logs (same paragraph).

Most hotshots run long distances, so most need an ELD. The device must be on FMCSA’s registered list; the ELD rule page covers the rules and the ELD directory lists devices.

Equipment, inspections and securement

• Annual inspection: every CMV must pass a periodic inspection at least once every 12 months, with the documentation on the vehicle, and in a combination each vehicle is inspected, so the pickup and the trailer each need one (396.17(a), (c)). See the annual DOT inspection guide; inspection stations are listed by county.
• Daily vehicle inspection report: drivers prepare a written report at the end of each day’s work on each vehicle (396.11(a)(1)), but no report is required if no defect or deficiency is found or reported (396.11(a)(2)(i)). The rule does not apply to a motor carrier operating only one CMV (396.11(a)(5)). The DVIR guide covers when it applies.
• Cargo securement: cargo must be secured so it cannot leak, spill, blow or fall from the vehicle, or shift enough to affect stability (393.100(b), (c)). Flatbed and gooseneck loads of pipe, machinery and building materials are where hotshots get cited.

Intrastate-only hotshots

The federal safety rules in Parts 390 to 396 apply to interstate commerce (390.3T(a)(1)). A hotshot that never carries freight moving in interstate commerce answers to its state’s rules instead, which often adopt the federal ones with their own weight thresholds. The CDL line at 26,001 pounds is the same in both, because Part 383 applies to interstate and intrastate commerce alike (383.3(a)). Remember that a load that started or will finish outside the state can be interstate commerce even on an in-state leg (390.5T).

Checklist for a new for-hire hotshot

1. Read the GVWR labels on the truck and trailer and decide whether you are building a CDL or non-CDL rig.
2. If CDL: get the Class A and join a drug and alcohol consortium.
3. Get a DOT medical certificate.
4. File the MCS-150 for a USDOT number before hauling; apply for operating authority; file a BOC-3; have your insurer file proof of coverage.
5. Mark the truck on both sides.
6. Install a registered ELD unless an exception applies.
7. Get annual inspections for the truck and the trailer and keep the proof on board.
8. Set up a qualification file for yourself and any driver you use.

State programs such as fuel tax reporting and apportioned registration have their own weight and axle thresholds; check them with your base state. The cost per mile calculator helps price loads once the fixed costs are known.

What inspectors check on a hotshot

• Truck and trailer labels against the driver’s license class.
• USDOT marking on both sides of the power unit.
• The driver’s medical certificate (paper, for non-CDL drivers) and the log or ELD.
• Annual inspection proof for each vehicle.
• Securement of the load, and weight at weigh stations.