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Compliance Review: FMCSA Regulations for Hotel-Related Transportation
Mariah Barr
6 mins read

Unless exempted, companies transporting passengers in commercial motor vehicles must comply with FMCSA safety regulations.

To most, it's very clear that property-carrying commercial motor vehicles (CMVs) such as tractor-trailers and waste management trucks are regulated by the Federal Motor Carrier Safety Administration (FMCSA), but what about passenger-carrying vehicles, such as hotel shuttle buses?

Generally, FMCSA safety regulations apply to companies with drivers who operate CMVs in interstate commerce, which involves crossing state lines. To find out if these regulations apply to your hotel shuttle business, you need to determine if your shuttles are considered CMVs and if your operations are for-hire.

To clear the air, this post will break down the following:

  • How interstate commerce relates to hotel-related transportation
  • An explanation of for-hire hotel shuttle transportation
  • How to tell if your shuttles are CMVs
  • How to determine if your shuttle drivers need commercial driver's licenses (CDLs)

The sooner you find out if your hotel shuttles are regulated by the FMCSA, the sooner you can get on track with your compliance.

Can passenger transportation be considered interstate commerce without crossing state lines?

Let's start with this complex regulatory statement: even if you transport passengers in one state, in some cases, it may be considered interstate commerce if your passengers began or will conclude their trips outside of the state you operate in.

To break this down, let's say a passenger's trip is prearranged to start in one state and end in another. If the traveler uses multiple modes of transportation (such as an airplane for one part and a shuttle bus service for the rest), each part of the trip is considered interstate commerce.

On the other hand, if a passenger did not make previous arrangements and uses transportation after arriving at an airport, that mode of transportation is not an extension of the trip and is not interstate commerce.

How can I tell if my company is for-hire?

If a company receives compensation for transporting passengers, it's considered to be a for-hire carrier. But sometimes the payment for their transportation services isn't obvious.

For instance, if a hotel owns a van to transport its customers to and from the airport and doesn't charge an extra fee for the service, it's still considered indirect compensation. The customers' payment for their rooms and other services includes the use of the hotel shuttle.

Unless they qualify for an exemption, all for-hire passenger carriers in interstate commerce must:

  • Obtain an FMCSA operating authority registration (no matter the size of your vehicles).
  • Purchase at least the minimum insurance coverage: $1.5 million for vehicles with a capacity of 15 or fewer passengers including the driver, or $5 million for vehicles with a capacity of 16 or more passengers including the driver.
  • Designate a representative who can be served court papers in any legal proceeding brought against you, often referred to as a process agent.

Bottom line: if you transport passengers as part of interstate commerce and you accept any type of payment for the transportation, you are a for-hire company in the eyes of the FMCSA.

How can I determine if my shuttle buses are CMVs?

Both for-hire and private passenger carriers are typically regulated by the FMCSA if their vehicles meet the definition of CMVs and are used to participate in interstate commerce.

Your hotel shuttles are CMVs if they meet one or more of the following criteria:

  • Have a gross vehicle weight (GVW) or gross vehicle weight rating (GVWR) of 10,001 pounds or more; or
  • Can transport 9+ passengers, including the driver, for compensation; or
  • Can transport 16+ passengers, including the driver, regardless of whether it is used for compensation

How do I know if my shuttle drivers need CDLs?

Drivers operating vehicles that meet one or more of the following criteria must have a CDL with the appropriate endorsement(s):

  • Have GVW or GVWR of 26,001 pounds or above; or
  • Can transport 16+ passengers, including the driver; or
  • Is of any size and transports hazardous materials

All CDL drivers must be enrolled in the DOT Clearinghouse as well as a DOT drug and alcohol testing program.

Get a DOT drug testing program now

FMCSA Compliance Solutions for Hotel-Related Transportation

Now that you know whether your company is exempt from FMCSA regulations or you must comply with them, if your situation is the latter, it's best to get on track with the compliance programs you need as soon as possible.

Foley's DOT compliance software consolidates all the solutions you need on one platform. From hiring and onboarding drivers to DOT drug and alcohol testing, DOT Clearinghouse services, and driver qualification files, we can get you started on the right foot toward complete FMCSA compliance.

Get a free software demo now and ensure you're meeting all FMCSA regulations before you're selected for an audit. Fill out the form below to get started.

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