Trailering a L47 TLB

[mcmxi]

I've posted this before, but here's a GVWR/CDL guide that I put together. There is an incredible amount of mythology and misinformation regarding state and federal requirements as they pertain to hauling or towing. It's no surprise that there are "officials" out there that don't know the law either.

This flow chart is only applicable to "commercial" use of a vehicle and is not necessarily applicable to private use of a vehicle. Most of us are not engaged in a commercial enterprise when we haul our tractors around so are not held to the same regulations. This is why we see people hauling massive campers around all summer long without a CDL, and we don't see huge lines of non-commercial truck/camper or truck/trailer combinations stuck at weigh stations. There's a clue in the Commercial part of Commercial Driver License. If you're not involved in commerce then you don't require a CDL.

If you have a commercial sign or logo on your tow vehicle you might want to take a look at the flow chart below. The Kubota dealer in Sheridan, WY and the one near me have been stopped many times when hauling a tractor or other piece of equipment but they're towing for commercial reasons so they're held to a different standard.

 

[mcmxi]

Here's one of the better webpages I've found regarding the need for a CDL.

Trailer Towing: When Do You Need a CDL? – Tracey Road Equipment

www.traceyroad.com

 

[troverman]

I'm not sure about the second item on your flow-chart. What exactly does the trailer being 10k have to do with it? The rule on CDL is 26,001lbs or more, whether achieved as a truck and trailer or single vehicle. The type of CDL is determined by other factors which you list. Here's an example: if you are driving a RAM 5500 dump truck, it has a GVWR of 19,500lbs. This means if you tow a trailer behind that truck, it can only weigh 6500lbs. One more pound, even though the trailer is well under 10k, requires a CDL.
Furthermore, the "hotshot trucking" industry thrives on drivers operating a 3/4 ton pickup and a long gooseneck trailer rated at 16k. Together, they make up 26k GCWR and fall under CDL requirements. There are still other requirements, such as logbooks, weigh stations, etc but no CDL is required.

One of the dumbest rules is how a 3/4 ton pickup can tow a gooseneck grossing 16k but a 1-ton, single rear wheel truck cannot pull the same trailer without a CDL. There is essentially no different between a 3/4 ton and 1-ton SRW truck aside from some minor suspension / axle differences.

 

[mcmxi]

I'm not sure about the second item on your flow-chart. What exactly does the trailer being 10k have to do with it?

Because that's Federal Law as it pertains to the commercial use of a trailer. If the trailer GVW/GVWR is 10,000lb or over a Class A CDL is required, but if the GVW/GVWR of the trailer is less than 10,000lb a Class B CDL is required ... for commercial use. Follow the arrows ... it's kind of obvious.

 

[troverman]

Because that's Federal Law as it pertains to the commercial use of a trailer. If the trailer GVW/GVWR is 10,000lb or over a Class A CDL is required, but if the GVW/GVWR of the trailer is less than 10,000lb a Class B CDL is required ... for commercial use. Follow the arrows ... it's kind of obvious.

I'm going to respectfully disagree. My employee has been pulled over by State Police for speeding while driving my 2500 truck and a 30 foot 15,900lb gooseneck. The employee's standard non commercial license was not an issue.

 

[fried1765]

I'm going to respectfully disagree. My employee has been pulled over by State Police for speeding while driving my 2500 truck and a 30 foot 15,900lb gooseneck. The employee's standard non commercial license was not an issue.

Curosity: Does your 2500 truck, have a commercial registration?

 

[mcmxi]

I'm going to respectfully disagree. My employee has been pulled over by State Police for speeding while driving my 2500 truck and a 30 foot 15,900lb gooseneck. The employee's standard non commercial license was not an issue.

I will respectfully disagree too. Whether or not a State Trooper (or whatever he/she was) cited your employee for not having a Class A license is absolutely irrelevant as to whether or not a Class A CDL was required in that situation. The Federal rules for commercial use of a tow vehicle with or without a trailer are very clear, regardless of whether or not they are enforced by a LE officer during a stop.

If your truck is being used for a business, and your employee was pulling that trailer for your business, then he should absolutely have a CDL according to Federal regulations. This is not my opinion, just a statement of fact based on readily available regulations.

 

[dirtydeed]

MCMXI stated it correctly.

Its GCWR of 26,001 or greater. Many people mess up on the GVWR of the towed vehicle (trailer). That 10K requirement ONLY determines which CLASS of CDL that you would need on once you cross the 26,001 threshold. Class A for 10,001 and over, Class B for 10,000 and under for the towed vehicle.

In your example Troverman, Ram 5500 at 19.5K GVWR plus a trailer at say, 9K requires a Class B CDL. That same truck pulling a heavier trailer in excess 10,000 lbs (GVWR) would require a Class A CDL.

Also, what a lot of people miss, is you have to use the GVW"R" (rating) of both vehicles. It doesn't matter if the trailer is empty or not.

The larger question is if you are actually "commercial" in your state.

 

[dirtydeed]

I'm going to respectfully disagree. My employee has been pulled over by State Police for speeding while driving my 2500 truck and a 30 foot 15,900lb gooseneck. The employee's standard non commercial license was not an issue.

What is the GVWR of that 2500? I'm betting it's 10K. If that's true, your employee was under the 26,001 threshold.

 

[mcmxi]

What is the GVWR of that 2500? I'm betting it's 10K. If that's true, your employee was under the 26,001 threshold.

Good point. I assumed the truck and trailer were over 26,000lb.

 

[troverman]

Morning gentlemen, to answer your questions:
The RAM is registered to my business. The GVWR is 10k, and with the trailer was just under the 26k threshold. If I'm understanding mcmxi correctly, he is saying that doesn't matter because the trailer itself is >10k GVWR and CDL is required. I'm aware any combination over 26k is CDL A territory. I don't allow employees without a CDL A to operate my combinations that exceed this. However, my understanding is that, for instance, my F-550 (19.5k) can tow a 6,000lb GVWR trailer without requiring the operator to possess a CDL at all, and we do this at times. Likewise, my 350 dually (14k GVWR) cannot pull the 15.9k gooseneck without a CDL A operator, but it can pull a 12k deckover on a regular operator's license. I'm in NH and I've actually spoken to the instructor of the CDL school we use, and this is my understanding.

 

[dirtydeed]

Morning gentlemen, to answer your questions:
The RAM is registered to my business. The GVWR is 10k, and with the trailer was just under the 26k threshold. If I'm understanding mcmxi correctly, he is saying that doesn't matter because the trailer itself is >10k GVWR and CDL is required. I'm aware any combination over 26k is CDL A territory. I don't allow employees without a CDL A to operate my combinations that exceed this. However, my understanding is that, for instance, my F-550 (19.5k) can tow a 6,000lb GVWR trailer without requiring the operator to possess a CDL at all, and we do this at times. Likewise, my 350 dually (14k GVWR) cannot pull the 15.9k gooseneck without a CDL A operator, but it can pull a 12k deckover on a regular operator's license. I'm in NH and I've actually spoken to the instructor of the CDL school we use, and this is my understanding.

Troverman, I would agree with almost all of your answers.

- any combination over 26K is CDL territory, but trailer under 10K is Class B, trailer over 10K is Class A. Of course, Class A would also cover any Class B setup as well.

Regarding under 26K GCWR, you do not need a CDL regardless of the trailer GVWR. I have heard from some folks that suggest a medical card when towing a trailer over 10K. I have not seen that requirement in writing.

I also have a 14K GVWR truck that I could pull up to 12K trailer to stay under CDL requirement. However, the GCWR on that truck (specified by manufacturer) is only 24K. I don't think LEO's care about what the manufacturer recommends...only that you are under 26K combined and that you don't exceed the GVWR on either the tow vehicle or trailer.

 

[dirtydeed]

maybe this will help as well. Copied from PA CDL website FAQ:

The Federal Commercial Motor Vehicle Safety Act of 1986 mandated new requirements for the testing and licensing of commercial motor vehicle operators. While detailed information on these requirements may be found in the Commercial Driver’s Manual (PUB 223), these Frequently Asked Questions will provide you with a brief overview of the CDL program as a whole.

1. Who must have a commercial driver’s license (CDL)?
Anyone who drives a commercial motor vehicle. The definition of a commercial motor vehicle is:

• a combination of vehicles with a gross vehicle weight rating of 26,001 or more pounds, provided the vehicle being towed is in excess of 10,000 pounds;
• a single vehicle with a gross vehicle weight rating of 26,001 or more pounds;
• a vehicle designed to transport 16 or more passengers, including the driver;
• a school bus; or
• any vehicle that is transporting hazardous materials and is required to be placarded in accordance with State and Federal regulations.

Commercial motor vehicles do not include:

• implements of husbandry;
• any motor home or recreational trailer operated solely for personal use; or
• motorized construction equipment, including, but not limited to, motorscrapers, backhoes, motorgraders, compactors, excavators, tractors, trenchers and bulldozers.

and number 4 pertains to "ClASSES":

4. What are the classes of commercial driver licenses?
In accordance with the licensing requirements of the Commercial Motor Vehicle Safety Act, the license classifications are:
CLASS A - combination vehicle with a gross vehicle weight rating of 26,001 pounds or more, provided the gross vehicle weight rating of the vehicle being towed is in excess of 10,000 pounds.
CLASS B - single vehicles with a gross vehicle weight rating of 26,001 pounds or more, or any such vehicle towing a vehicle not in excess of 10,000 pounds.
CLASS C - single vehicles with a gross vehicle weight rating of less than 26,001 pounds if the vehicle is: transporting hazardous materials requiring placarding; is designed to transport 16 or more passengers, including the driver; or, is a school bus.

 

[troverman]

I'm confused about the Class B license - I always understood its purpose for heavy non-combination vehicles, such as a straight truck in excess of 26k GVWR, and towing anything behind that vehicle would require a Class A.

If I'm reading it correctly, Class B CDL would be acceptable for any vehicle with a GVWR of >26k so long as the trailer was <10,001lbs. Meaning a Class 8 10-wheeler dump operator could tow a 10k trailer on a Class B CDL. Correct?

 

[dirtydeed]

If I'm reading it correctly, Class B CDL would be acceptable for any vehicle with a GVWR of >26k so long as the trailer was <10,001lbs. Meaning a Class 8 10-wheeler dump operator could tow a 10k trailer on a Class B CDL. Correct?

Correct.

 

[troverman]

Thanks for your explanation, and mcmxi as well.

 

[mcmxi]

maybe this will help as well. Copied from PA CDL website FAQ:

The Federal Commercial Motor Vehicle Safety Act of 1986 mandated new requirements for the testing and licensing of commercial motor vehicle operators. While detailed information on these requirements may be found in the Commercial Driver’s Manual (PUB 223), these Frequently Asked Questions will provide you with a brief overview of the CDL program as a whole.

1. Who must have a commercial driver’s license (CDL)?
Anyone who drives a commercial motor vehicle. The definition of a commercial motor vehicle is:

• a combination of vehicles with a gross vehicle weight rating of 26,001 or more pounds, provided the vehicle being towed is in excess of 10,000 pounds;
• a single vehicle with a gross vehicle weight rating of 26,001 or more pounds;
• a vehicle designed to transport 16 or more passengers, including the driver;
• a school bus; or
• any vehicle that is transporting hazardous materials and is required to be placarded in accordance with State and Federal regulations.

@dirtydeed, thanks for posting this. I'm going to need to do some digging to confirm whether PA's interpretation of the definition of a commercial motor vehicle is nationally recognized.

 

[dirtydeed]

@dirtydeed, thanks for posting this. I'm going to need to do some digging to confirm whether PA's interpretation of the definition of a commercial motor vehicle is nationally recognized.

I doubt that it's the same across all states. I was really looking into DOT requirements (both USDOT# and PADOT#) for myself. I came to the conclusion that neither apply to me (thankfully). One of the tell-tale signs of "commercial" vehicles is Interstate commerce, which, I don't partake in.

anyway, here is where I found those CDL requirements. https://www.dmv.pa.gov/Pages/FAQ Pages/Commercial-Driver’s-License-FAQ.aspx#Q1

I realize that you aren't in PA and likely couldn't care less. But, I think I'm going to print a copy of these and keep a hard copy in my truck!

 

[fried1765]

Some states interpret the 49 C.F.R. § 383.5 to read that any trailer RATED over 10,000 pounds requires a CDL even if it is empty.
Even if you have a HD dully rated with a Class 5 hitch, you still are not able to tow 10,001 pounds without CDL.

I do not believe that this is correct.
If it were so, how could I drive a 30K lb. motor home with no CDL?
I think private use v/s commercial use are the differentiating issues here.

 

[jyoutz]

@dirtydeed, thanks for posting this. I'm going to need to do some digging to confirm whether PA's interpretation of the definition of a commercial motor vehicle is nationally recognized.

If that is the case, just about everyone I see pulling a trailer in western states is in violation. Heck, the rancher pulling a stock trailer with 6 steers is in CDL category. IDK very many ranchers with CDLs.