Pickup Truck and Trailer - Definition for CDL/Restriction Requirements

The use of hotshot units to transport product has seen an increase over the last number of years. These pickups and trailers use a variety of different different connections between the power unit and trailer. The typical connection is a ball and socket connection with the ball mount in the box of the pickup, often referred to as gooseneck connection. Sometimes we see the box removed and the ball is in the flatbed. Other times we may see no flatbed or box with the ball mounted to the frame of the pickup, similar to a truck/tractor in that no other freight may be transported and the vehicle can only be used to pull a trailer. We can also see a fifth wheel plate installed in all of the same options that a the ball installation was described above. Taking the skills test in one of the these combinations usually results in a truck/tractor restriction. The issue arises as, depending on how the hitch system is mounted and whether or not the pickup can only draw another vehicle or also transport cargo, can either meet the definition of a truck or a truck/tractor in 390.5. This confusion is causing drivers to have a truck/tractor restriction placed on their license when the skills test is taken, only to be placed OOS on a roadside inspection because the inspector feels it meets the definition of a truck/tractor, operating the same vehicle combination in both cases. Example of one type of connection is included.

Guidance as to exactly how these vehicles are to regulated, a truck or truck/tractor, needs to documented to provide consistency between jurisdictions on inspections and also between enforcement and jurisdictional drivers license divisions.

Add guidance to Ops Policy 15 as to how these vehicles are to be classified to improve consistency in enforcement.