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No enforcement of USDOT number requirement for private trucks in intrastate farm operations

AgDM Newsletter
April 2011

The Federal Motor Carrier Safety Administration (FMCSA) was established within the Department of Transportation (USDOT) on Jan. 1, 2000.  The FMCSA’s primary mission is to prevent commercial motor vehicle-related fatalities and injuries. Strategies for achieving this mission include registration of commercial vehicles and partnering with state enforcement agencies, such as the Iowa Department of Transportation (Iowa DOT), to implement safety regulations and related inspections.

During 2010 and early 2011, Iowa farmers were presented with conflicting information regarding requirements for farm trucks used solely within Iowa (referred to as “intrastate” operations) and the need to obtain and display USDOT numbers. The Iowa DOT first published information announcing that enforcement of such a requirement would begin in 2010, and later pushed back the enforcement date to January 2011.

As of April 2011, Iowa DOT Motor Vehicle Enforcement Officer Ron Schipper confirms that enforcement of this requirement is not being implemented by the DOT.  Specifically, Iowa farmers who privately (not for-hire) operate farm trucks entirely within the State of Iowa are not being required to obtain and display USDOT numbers.

Iowa DOT emphasizes that if the farm truck crosses state lines, the truck is then involved in interstate commerce, and USDOT registration is required.

Further, if the farm truck is operated for-hire – such as hauling livestock, chemicals or commodities for other operations – the USDOT registration and applicable regulations apply to the vehicle.

If there is any possibility that the truck will cross state lines in the course of farm operations, or if the truck may be used for-hire, farmers should consider USDOT registration. The proper form to request a USDOT number is the MCS-150. This form can best be obtained by going to the website at where complete, step-by-step instructions are available. The direct link to the form is:

Review of farm vehicle safety requirements

With spring planting just around the corner, it is worth noting that whether or not a farm vehicle is USDOT-registered, the legal requirements for proper lighting and marking of farm tractors, towed equipment and self-propelled implements of husbandry remain in place. This is the time of year to review the minimum requirements for lighting safety equipment and slow-moving vehicle (SMV) emblem use. According to the Iowa DOT, these are the minimum requirements:

  • Steady white headlamp: All animal-drawn vehicles and self-propelled implements of husbandry must be equipped with at least one lighted lamp or lantern exhibiting a white light visible from a distance of 500 feet in front of the vehicle.
  • Steady red tail lamp: All self-propelled implements of husbandry must be equipped with a lamp or lantern exhibiting a red light visible from a distance of 500 feet behind the vehicle.
  • Flashing amber light:
    -  Animal-drawn vehicles must be equipped with a flashing amber light visible from a distance of 500 feet behind the vehicle.
    -  A farm tractor, farm tractor with towed equipment or self-propelled implement of husbandry operated on a primary or secondary road at a speed of 35 mph or less must be equipped with and display an amber flashing light visible from the rear. If the amber flashing light is obstructed by the towed equipment, the towed equipment must also be equipped with and display an amber flashing light.
  • Lighted white, red or amber lamps or lanterns are required at all times from sunset to sunrise, and at other times when conditions such as fog, snow, sleet or rain provide insufficient lighting to render clearly discernible persons and vehicles on the highway at a distance of 500 feet ahead.
  • SMV emblem: When operated on a highway at a speed of 35 mph or less, every farm tractor, tractor with towed equipment, self-propelled implement of husbandry, horse-drawn vehicle or any other vehicle principally designed for use off the highway must be equipped with a SMV emblem visible from the rear of the slow-moving vehicle. SMV emblems (consisting of a fluorescent, red-orange equilateral triangle with a red retroreflective border) must be mounted with the point of the triangle upward, and may be permanently mounted or movable in a manner that provides secure and rigid attachment. SMV emblems must be mounted on the rear of the vehicle and either centered or as near to the left of center of the vehicle or equipment as practical so that it is clearly visible.  Any towed wagons or other implements must also be equipped with a SMV emblem that is clearly visible to the driver of a vehicle approaching from the rear. The effective reflectivity and fluorescence of the emblem must be sufficient so that the triangular shape is readily identifiable both day and night. If the slow-moving vehicle operates at speeds greater than 35 mph, the SMV emblem must be removed or hidden from view. Persons operating horse-drawn vehicles with religious objections to using a reflective triangle device should contact the Iowa DOT for alternate regulations.

Additional ways to make farm vehicles and equipment more visible, beyond the minimum requirements, include the following suggestions:

  • Use two red tail lamps, rather than the one that is required.
  • Use two white head lamps, rather than the one that is required.
  • Use retroreflective tape or conspicuity tape that is visible at night from a distance of 1,200 feet when directly exposed to the high beam of headlamps.
  • Use amber reflectors to mark the front of towed implements that protrude beyond the width of the towing farm tractor.
  • Make sure the SMV sign is clean and not faded and that all lights are free of dust and dirt.
  • If a tractor or self-propelled implement is wider than 8.5 feet, the Iowa DOT recommends displaying steady amber warning lights at the widest part of the vehicle.

For more information about farm truck and implement requirements, farmers may wish to review materials contained on pages 59-69 of the Iowa Truck Information Guide (2010-2011 version) available at These materials outline truck and implement equipment requirements as well as licensing regulations. If farmers have questions about these regulations, the Iowa DOT can also be contacted at 1-800-925-6469.


Melissa O'Rourke, extension farm and agribusiness management specialist, 563-382-2949,