Ask Thorn Valley - August 2018

We were asked about obtaining CAB (Central Analysis Bureau) reports for Moving & Storage companies who operate under both their authority locally, and major national moving company authority, depending upon the particular job. I finally had a moment to analyze this one and here are my initial thoughts, and supporting argument;

  • Why bother with CAB ("SMS on steroids") - especially if we are mainly focusing on smaller, independents?
  • The following link will take you directly to the HHG quick search > https://ai.fmcsa.dot.gov/hhg/search.asp
    • e.g. I searched "mover" in carrier name field and got 1,369 hits with list of any FMCSA consumer HHG complaints on records, plus SMS data on file

I think this search feature would be more helpful for the UW. There’s no login required, and it’s a quick check for carrier registration. If SMS data does come back, that might deserve a deeper dive, and perhaps a CAB report might be in order. These smaller HHG movers are basically Owner/Operators who can lease themselves out to the larger HHG motor carriers(e.g. they need to go interstate), or operate under their own authority (intrastate). I’m not worried about stacked coverage in this case if I’m not insuring the larger carrier – the onus would be on them to indemnify, and they would take ownership for any and all roadside violations and crashes attributable to the Owner/Operator while their vehicle (not the driver) displays the larger carrier’s USDOT markings and on the Bill of Lading (BOL).

While it is true that some states do not regulate intrastate carriers, by-and-large, if the fleet operates CDL trucks (26,001+ lbs. GVW) normally intrastate carriers are required to at least register with USDOT. Some states still require registration of the "non-CDL CMV" (i.e. 10,001 – 26,000 lb. GVW) even if they are intrastate, and usually issue a unique identifier. For example Indiana identifies intrastate, non-CDL CMV’s by the USDOT# suffix letters "IN", while their registration is not viewable on Safer. Another good example is CA. Although it’s been our experience that CA is a bit nebulous as to the CDL/non-CDL distinction, CA does require Federal registration. The unique thing about CA is that once registered, intrastate motor carriers are not required to update their MCS-150 filing every 2 years. However, (CA) SMS violations will still appear once registered. What this means for the US is they can use the above website and track CA-based intrastate movers without having to go through CAB. Another example is neighboring NV, and similarly with TX – unless the motor carrier is 26,001+ (CDL) regulated, they don’t have to register, so CAB or the HHG website will not provide any information for those intrastate carriers.

Yes, the HHG moving industry is unique. It does take a lot of couches to exceed 26,001 lbs. GVW. Thus, we see many moving trucks with "granny’s attic" over-the-cab storage capacity (U-Haul, Two-Men and a Truck, etc.) Those vehicles have manufacturers recommended GVW of 25,999. And a typical state registration cutoff (IN for example) is "TK – 26,000 lbs." So 6 Men and 3 Trucks can move a sizeable household, and is how they navigate the myriad of federal/interstate and intrastate rules. But – once they hit the state line - all bets are off. Any CMV 10,001+ lbs. travelling interstate must register with FMCSA - and are on the radar – Safersys, SMS or CAB – choose your preference depending upon the size/complexity of the operation. In this specific example, unless there is a financial (insurance) relationship with the larger carrier, I believe the UW is not going to have much success getting the larger carrier to sort out CAB data for the various O/O’s they lease to under their authority.