You’ve probably heard about it. You may have even encountered it. More and more states are teaming up with the U.S. Department of Transportation’s Federal Motor Carrier Safety Administration to implement something called the “Performance and Registration Information Systems Management” program, or PRISM for short.
Basically, PRISM is a federal-state partnership intended to improve commercial motor vehicle safety. In its purest sense, PRISM simply enables state vehicle registration agencies to make sure trucking companies don’t keep their International Registration Plan license plate privileges if the U.S. DOT has ordered them to cease interstate operations.
So what does all this mean for you as an owner-operator? Most likely, it’s not as drastic as you may have heard at your favorite truckstop.
The IRP plate renewal process is where it all comes together. It’s also the place where PRISM is most likely to directly affect you in terms of paperwork or additional information needed to renew your IRP plate. Things pretty much boil down to who applies for and renews the IRP plate on your truck. In the following sections, we’ll briefly explain how PRISM may affect you depending on whether you, or a company to whom you are leased, handles the IRP license plates on your truck.
Owner-operators whose trucks are registered by a company to whom they are leased
If you are leased to a company that handles the IRP plate renewal on your truck, then PRISM will probably be transparent to you. This is most common if you don’t have your own operating authority and don’t operate as a motor carrier in your own right. Instead, you simply lease on to a company that handles the license plate renewal process, payment of registration fees etc.
If this is the case, then it should be smooth sailing. You won’t have to obtain a U.S. DOT number, or supply additional paperwork to keep your truck moving. In fact, chances are you won’t hear much about PRISM at all unless the company to whom you are leased starts having safety issues with the U.S. DOT. If that happens, the state license plate agency will send you a letter stating: “Dear Mr. Truck Owner: The company you have your truck leased to is facing a possible federal shutdown order. If that happens, the plate on your vehicle may be suspended.”
Owner-operators who register their own trucks
Many owner-operators apply for and renew their IRP license plates themselves. If that describes you, then you undoubtedly want to know what kind of paperwork and information you are going to need to renew your IRP plate once your base state joins PRISM.
The following should help you sort things out.
The state IRP office is going to be interested in information that can easily be categorized into two areas: U.S. DOT number information; and Form MCS-150 update information.
U.S. DOT number information
For starters, you’ll have to provide your U.S. DOT number and your federal employer identification number (FEIN) or Social Security number. If you have your own operating authority, you should already have a U.S. DOT number. If you don’t have your own operating authority and have never operated as a motor carrier yourself, chances are you don’t have a U.S. DOT number yet. That’s because, up until the PRISM program came along, you weren’t required to have one.
Fortunately, all you have to do is go online to http://www.usdotnumberregistration.com/ and follow the simple instructions to obtain a “Registrant” number. If you don’t have Internet access, your IRP office should be able to issue you a number. It’s extremely important to understand that this number does not provide you with operating authority and should not, under any circumstances, be marked on the side of your truck.
A “registrant” U.S. DOT number simply serves as a record for the U.S. DOT and states to know that you exist as somebody who registers commercial motor vehicles.
The next thing you’ll need is the U.S. DOT number and FEIN or Social Security number of the motor carrier that will be responsible for the safety of your vehicle during the registration year. If you are leased to a company, and that lease is expected to last for at least 30 more days, the company to whom you are leased is considered the motor carrier responsible for safety. Simply stated, the motor carrier responsible for safety is the company that U.S. DOT ultimately holds accountable for things like hours-of-service compliance, drug and alcohol testing, and vehicle maintenance.
In some instances though, you won’t be under a lease agreement to a motor carrier at the time of registration. If that’s the case, you won’t need to provide an additional U.S. DOT number.
Form MCS-150 update information
Under the PRISM program, state vehicle registration agencies work with the FMCSA to ensure motor carriers keep their company data up to date. This includes things like their business address, number of trucks and drivers, etc. To facilitate this objective, the state checks the “MCS-150 date of last update” associated with every U.S. DOT number on an IRP account. If the “MCS-150 date of last update” is over 12 months old at the time of registration, the state will require an updated Form MCS-150 from the company associated with that U.S. DOT number. You can check the “MCS-150 date of last update” for any U.S. DOT number online at http://www.safersys.org. Companies may now update their MCS-150 data electronically online at http://www.usdotnumberregistration.com/. If the data is updated online, you won’t have to come up with a paper form to renew your license plates.
If you’re an IRP account holder and register your truck in a PRISM state, you’ll be required to supply some additional information at IRP renewal time. Simply put, you’ll need to provide:
- Your U.S. DOT number and the appropriate federal employer identification number (FEIN) (or Social Security number);
- The U.S. DOT number and FEIN (or Social Security number) of the motor carrier responsible for safety at the time of registration; and
- An updated Form MCS-150 for every U.S. DOT number on the IRP account IF one has not been updated within the past 12 months.
With this information, no truck is registered through the IRP without identifying an entity responsible for safety. And more importantly, the safety status of every truck is checked to make sure the company hasn’t been ordered to cease interstate operations by the U.S. DOT.
There’s no question it’s a little extra work. But in the end, it’s a small price to pay to ensure companies don’t keep or renew license plates when they have been ordered to stop operating. We all benefit from safer highways, especially owner-operators who are so vital to our nation’s economy.
by Bryan Price Federal Motor Carrier Safety Administration
U.S. Department of Transportation