FMCSA interpretation of GCWR

   / FMCSA interpretation of GCWR #1  

Duffster

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So I emailed the WI office of the FMCSA for a clarification of the term GCWR for Dmace.

This is what I sent.

Hello Mark

Per our converstation on the phone I am looking for a clarification of the term of "GCWR" as used to decide whether or not a class A CDL would be required.

This is the definition that I have found on the FMCSA site.

Gross combination weight rating (GCWR) means the value specified by the manufacturer as the loaded weight of a combination (articulated) vehicle. In the absence of a value specified by the manufacturer, GCWR will be determined by adding the GVWR of the power unit and the total weight of the towed unit and any load thereon.

This is the definition of "GCWR" as found on the Ford site.

GCWR (Gross Combination Weight Rating)

Weight specified by the manufacturer as the maximum loaded weight of a towing vehicle and its trailer. The sum of the loaded vehicle weight of the truck and trailer should not exceed the GCWR.GCWR = vehicle curb weight + payload + trailer weight + driver and passengers.

Ford Vehicle Glossary | The Official Site of Ford Vehicles | FordVehicles.com

Here is a spec sheet showing all of the configurations of Ford superduty. It shows a "GCWR" and towing rating.

2011 Ford Super Duty | View Towing Specifications | FordVehicles.com

So this is where we need some clarification.

It is my understanding that GCWR= GVWR(truck) + GVWR(trailer).

My colleagues are saying that if we had a Ford configured so that it has a GCWR of 26,001 or more as listed in the specs that it would need a class A to tow any trailer 10,001 or over. Or on the inverse a truck configured so that Ford listed it's "GCWR" at 26,000 or less it would not need a CDL no matter what the trailer was rated for.

It is also my understanding that the "GCWR" as given by Ford is not a legal rating since it is not listed on the door label like GVWR and GAWR are.

I hope you understand my question and please feel free to ask any questioons you need to clarify anything.

Thanks

Duffster

This is what i got in return.

Duffster,

Yes, the GCWR = GVWR (truck) + GVWR(trailer). This would be taken off the spec plate of both vehicles. We don稚 care what Ford痴 website states. All inspector and investigators are trained to review the spec plate of the vehicle(s) they are inspecting.

The GCWR on that website is basically stating what the manufacture has specified the weight that vehicle can haul, including the weight the power unit and trailer.

What is the issue? Does someone not want to obtain a CDL?

Mark G. Oesterle

Division Administrator

Federal Motor Carrier Safety Administration

1 Point Place, Suite 101

Madison, WI 53719

Office 608-662-2010

Fax 608-829-7540

These interpretations might help with your questions;

Question 3: If a vehicleç—´ GVWR plate and/or VIN number are missing but its actual gross weight is 26,001 pounds or more, may an enforcement officer use the latter instead of GVWR to determine the applicability of the Part 383?

Guidance: Yes. The only apparent reason to remove the manufacturerç—´ GVWR plate or VIN number is to make it impossible for roadside enforcement officers to determine the applicability of part 383, which has a GVWR threshold of 26,001 pounds. In order to frustrate willful evasion of safety regulations, an officer may therefore presume that a vehicle which does not have a manufacturerç—´ GVWR plate and/or does not have a VIN number has a GVWR of 26,001 pounds or more if: (1) It has a size and configuration normally associated with vehicles that have a GVWR of 26,001 pounds or more; and (2) It has an actual gross weight of 26,001 pounds or more.

A motor carrier or driver may rebut the presumption by providing the enforcement officer the GVWR plate, the VIN number or other information of comparable reliability which demonstrates, or allows the officer to determine, that the GVWR of the vehicle is below the jurisdictional weight threshold.

Question 4: If a vehicle with a manufacturerç—´ GVWR of less than 26,001 pounds has been structurally modified to carry a heavier load, may an enforcement officer use the higher actual gross weight of the vehicle, instead of the GVWR, to determine the applicability of part 383?

Guidance: Yes. The motor carrier痴 intent to increase the weight rating is shown by the structural modifications. When the vehicle is used to perform functions normally performed by a vehicle with a higher GVWR, ァ390.33 allows an enforcement officer to treat the actual gross weight as the GVWR of the modified vehicle.

Question 6: A driver operates a tractor of exactly 26,000 pounds GVWR, towing a trailer of exactly 10,000 pounds GVWR, for a GCWR of 36,000 pounds. HM and passengers are not involved. Is it a CMV and does the driver need a CDL?

Guidance: No to both questions. Although the vehicle has a GCWR of 36,000 pounds, it is not a CMV under any part of the definition of that term in ァ383.5, and a CDL is not federally required.

Question 12: A driver operates a combination vehicle with a gross combination weight rating (GCWR) of more than 26,000 pounds. The tractor is towing a semitrailer and a full trailer, each with a gross vehicle weight rating (GVWR) of less than 10,001 pounds. Is this combination a Group A vehicle that requires a driver with a Class A commercial driverç—´ license (CDL)?

Guidance: Yes. The GVWR for multiple towed units are added to determine whether the 10,000 pound GVWR threshold has been met. If the total GVWR for the two trailers is at least 10,001 pounds, and the tractorç—´ GVWR is sufficient to produce a GCWR of at least 26,001 pounds, the combination is a Group A vehicle requiring a driver with a Class A CDL with a double/triple trailers endorsement. For example, a combination vehicle with a GCWR of 36,000 pounds includes a semitrailer and a trailer, each of which has a GVWR of 6,000 pounds. This is a Group A vehicle having a GCWR of 36,000 pounds inclusive of two towed units having a combined GVWR of 12,000 pounds.

Are drivers of double and triple saddle mount combinations required to have the double/triple trailers endorsement on their CDLs?

Guidance: Yes, if the following conditions apply:

裕here is more than one point of articulation in the combination;

裕he GCWR is 26,001 or more pounds; and

裕he combined GVWR of the vehicle(s) being towed is in excess of 10,000 pounds.

Question 2: Is a driver of a combination vehicle with a GCWR of less than 26,001 pounds required to obtain a CDL even if the trailer GVWR is more than 10,000 pounds?

Guidance: No, because the GCWR is less than 26,001 pounds. The driver would need a CDL if the vehicle is transporting HM requiring the vehicle to be placarded or if it is designed to transport 16 or more persons.

Question 5: Do tow truck operators need CDLs? If so, in what vehicle group(s)?

Guidance: For CDL purposes, the tow truck and its towed vehicle are treated the same as any other powered unit towing a non-powered unit:

*f the GCWR of the tow truck and its towed vehicle is 26,001 pounds or more, and the towed vehicle alone exceeds 10,000 pounds GVWR, then the driver needs a Group A CDL.

*f the GVWR of the tow truck alone is 26,001 pounds or more, and the driver either (a) drives the tow truck without a vehicle in tow, or (b) drives the tow truck with a towed vehicle of 10,000 pounds or less GVWR, then the driver needs a Group B CDL.

輸 driver of a tow truck or towing configuration that does not fit either configuration description above, requires a Group C CDL only if he or she tows a vehicle required to be placarded for hazardous materials on a �subsequent move,鋳 i.e. after the initial movement of the disabled vehicle to the nearest storage or repair facility.

Mark G. Oesterle

Division Administrator

Federal Motor Carrier Safety Administration

1 Point Place, Suite 101

Madison, WI 53719

Office 608-662-2010

Fax 608-829-7540
 
   / FMCSA interpretation of GCWR #4  
So... does this about cover it?

(Did not include class c logic -- which is where the last "no cdl" at the bottom right should lead to... with no passenger busses or hasmat vehicles in the picture, this should be accuate I think)

Start at the top and work your way down:
 

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   / FMCSA interpretation of GCWR #6  
So... does this about cover it?

most states also include exceptions for "farm" equipment and fire fighting aperatus.


i mention the farm equipment as many of us could define our truck/trailer combos as used to haul/maintain/work our farm property and therefore covered under farm exemption.

but still requireing the poper class based on weight just not a CDL
 
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   / FMCSA interpretation of GCWR #7  
most states also include exceptions for "farm" equipment and fire fighting aperatus.


i mention the farm equipment as many of us could define our truck/trailer combos as used to haul/maintain/work our farm property and therefore covered under farm exemption.

but still requireing the poper class based on weight just not a CDL

I wan't going to get into states and their rules since they can deviate from the federal. There are certains waivers allowed that the states may choose to implement (farmers for example). They can also implement more stringent rules. They cannot "ease" the rules with the exception of special cases. The farmer being one.

By the way, in my searching I found this: http://www.dol.wa.gov/driverslicense/cdlvehicles.html It is a much better diagram that what I made! Since it did come off of Washington's website, it "could" have some Washington specifics there... but it appears to be the basic federal rules in the diagram.
 
   / FMCSA interpretation of GCWR #8  
I have a F650 Flatbed truck rated at 26,000 with farm plates. I also haul a trailer at times that is rated at 20K with farm plates as well. The overall GCWR of the truck/trailer is 40,000 lbs. As long as I do not exceed the 40K limit or over load the truck beyond 26,000 I am legal for farm use. I have talked to the DOT and State patrol office a few times and in Wisconsin under the farm exception rules I am legal.
 
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   / FMCSA interpretation of GCWR #9  
I have a F650 Flatbed truck rated at 26,000 with farm plates. I also haul a trailer at times that is rated at 20K with farm plates as well. The overall GCWR of the truck/trailer is 40,000 lbs. As long as I do not exceed the 40K limit or over load the truck beyond 26,000 I am legal for farm use. I have talked to the DOT and State patrol office a few times and in Wisconsin under the farm exception rules I am legal.

Ditto here. Just ran a 26k dump truck pulling a 14k trailer on 11 runs yesterday. All plated farm.

Chris.
 
   / FMCSA interpretation of GCWR #10  
May I ask a question at the risk of making the farmers angry? Why are farmers excluded from the CDL requirements?

Don't get me wrong, I am in no way "against" farmers. I have members of my family farm and I live among farmers... some of who are very close friends.

However, farmers operate some of the biggest, heaviest and dangerous pieces of equipment out there. I find it very odd they they are given carte blanche in terms of equipment they can drive on the road.

And all of the farmers I know pretty much claim "farm use" for everything in order to get away with as much as they can. I'm not being judgemental, I'm just sayin'.

Farmers certainly are commercial.

The "RV" exclusion is even more ridiculous to me. There you have people that are not used to driving big machines hitting the road.

At least the farmer is used to driving his big stuff. Except maybe his 16 year old kid blasting down the road with a combine... but that is for another discussion...
 
 
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