Yes, URS Will Affect You

When the Federal Motor Carrier Safety Administration adopted the Unified Registration System rule in August 2013, one part that became effective almost immediately was the requirement to complete the biennial update. As of Nov. 1, 2013, motor carriers holding a USDOT number were required to update their information with FMCSA on a biennial (two-year) basis according to the schedule in 49 CFR §390.19, or face deactivation of their USDOT number.

The requirement to complete the biennial update was actually not new; FMCSA simply put some serious consequences in place if a carrier did not keep its information up to date. Since this part of URS has been in place for over three years now, all carriers existing as of Nov. 1, 2013, have been required to complete a biennial update.

See? Most of you have already been affected by URS. But that’s just the beginning.

The biennial update requirement was a relatively minor kickoff to the many changes that will be implemented by URS. There’s much more to come that will change the way all motor carriers interact with the FMCSA. It is a big deal.

Starting Jan. 14, 2017

One of the biggest and most notable changes that will affect all motor carriers is that starting Jan. 14, 2017, all carriers will start using the new MCSA-1 online-only form. The MCS-150 no longer will exist. New entrants, meaning new carriers, brokers, freight forwarders, etc., that have never had a USDOT number or federal authority, are currently required to apply for a USDOT number and authority (if needed) using the FMCSA’s new online-only MCSA-1 form. The new MCSA-1 is currently available on FMCSA’s website, but again, until Jan. 14, is to be used only by new entrant entities applying for a new USDOT number.

Also starting on Jan. 14, the USDOT number will become a carrier’s sole identifier and the motor carrier numbers will no longer be issued. Newly issued USDOT numbers and authorities will be “inactive” until all required filings are completed.

And new entrants will be subject to a $300 “safety registration” fee. This means that if a new motor carrier is requesting a USDOT number and for-hire operating authority, the fee will be $600: $300 for the safety registration and $300 for the for-hire authority. Completing the biennial update is currently free and will remain free when URS is fully implemented.

All entities will also be required to notify FMCSA of any changes to legal name, form of business, or address within 30 days of the precipitating change.

Finally, new carriers that haven’t had to make certain filings will now be required to do so. New private hazmat and new for-hire carriers of exempt commodities will be required to file evidence of financial responsibility. And all new private carriers and for-hire carriers of exempt commodities will be required to make process agent designations.

By April 14, 2017

The last part of URS involves new filings for existing carriers (carriers that existed prior to Jan. 14, 2017). The FMCSA is giving existing carriers a little more time to comply with the new rules. By April 14, 2017, all existing private carriers and for-hire carriers of exempt commodities must make process agent designations. This is going to be a completely new requirement for these carriers, as prior to URS implementation, only for-hire carriers, brokers, and freight-forwarders were required to make such designations. 

Existing private hazmat carriers and for-hire carriers of exempt commodities will have to provide evidence of financial responsibility to FMCSA by April 14, 2017.

Going forward

URS really does affect all motor carriers — for-hire, private, or exempt. The extent to which you’ll be affected will depend on the type of carrier you are and the type of operation you have. Existing for-hire carriers might not be affected as much – until they go to complete their regularly scheduled biennial update after Jan. 14, 2017. Since the new MCSA-1 online-only form will be used for this purpose, it could take a year or more before a carrier may need to complete the biennial update using the new form and system.

All existing private carriers and for-hire carriers of exempt commodities must make a process agent designation filing, which is something they’ve never had to do before. And for-hire carriers of exempt commodities and private hazmat carriers must file evidence of financial responsibility, which is also something these types of carriers have never had to do before.

URS has streamlined several authority applications and processes into one system. The initial implementation efforts of the URS have cleaned up the FMCSA’s databases and has helped FMCSA more easily identify “reincarnated carriers.” And the new MCSA-1 “smart form” and process are expected to save carriers time in the long run.

More information on the URS final rule can be found at www.fmcsa.dot.gov/registration.

Heather Ness is editor – Transport Operations for J.J. Keller & Associates. She provides regulatory support for a variety of products including manuals, online services, forms, handbooks, and software. This article was authored under the guidance and editorial standards of HDT’s editors to provide useful information to our readers.