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INFORMATION: Implementing the Performance

and Registration Information Systems Management

Change Eliminating the Registrant-OnlyDesignation

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 September1, 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 orleasing 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 thetruck(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 theseVehicle 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

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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/prism-

resources.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