CMV Definition Clarification

A clarification of the definition of CMV GCWR in Part 383. In the scenario "a driver with a truck with a G.V.W.R of 17,000 lbs. towing a trailer with a G.V.W.R of 14,000 lbs. The power unit does not have a G.C.W.R. listed on the V.I.N. plate. Traditionally we would add the G.V.W.R.'s together and since the combined weight ratings are over 26,000 lbs. and the trailer is rated over 10,000 lbs the driver of this vehicle would require a Class A CDL." However upon re-reading the definition of Gross Combination Weight Rating this method would be incorrect. If a vehicle had no G.C.W.R. we would use the G.V.W.R. of the power unit, in this case 17,000 lbs and we would have to weigh the trailer to determine if the actual weight of the towed unit was over 10,000 lbs. This method is not only contradictory to the way it is being enforced but also clearly contradictory to the way it is being instructed in the NAS Level I inspection training course.

This issue was raised by Kevin Stewart, PSP Commercial Vehicle Safety Section, regarding a carrier complaint. Kevin is also on the Training Committee and NAS Part "A" and "B" certified.

Request the Driver Committee to review the actual definition and provide guidance to the Training Committee on the NAS Part "A" training program.