“The Department of Transportation [DOT] rules and regulations are complex. This handout takes a difficult subject matter and provides the information in a format that makes it easier to understand for production companies operating vehicles under their own DOT numbers” says Scott Taylor (Taylor & Taylor Associates). Over several months, since the new ELD regulations went into effect at the end of 2017, Taylor has been working with compliance experts to develop an easy-to-read document tailored for our industry. Experts from two LA-based companies made significant contributions: Lisa Dinson of Motion Picture Compliance Solutions, Inc. (MPCS), a technology company with special emphasis on DOT compliance, and Leigh Miller of DOT Production Consulting (dotPC), a company that focusses on providing compliance resources for commercial production companies.
The document has five major sections. It describes general rules that need to be considered when complying with DOT rules and regulations. It describes the specific procedures for operating a commercial motor vehicle (10,001 pounds and over). It lists the violations that are grounds for an automatic failure of the DOT and CHP audit regarding DOT and CA numbers. It describes the items required in the vehicle and available for inspection. And, lastly, it defines the often-confusing terms used in DOT and ELD requirements.
PERG got behind development of the document believing it would have value for rental companies as well as production companies. Mark Wofford (PC&E in Atlanta), a PERG council member, explains why PERG felt it was important to develop this document. “The issues our customers face become issues we need to be able to help them solve,” he says. “We rent vehicles for commercial productions and the trucks are typically driven by someone hired by the production company. A lot of our clients come here from California to film a project, and it’s important that we have a clear understanding of compliance issues so that we can better speak to the production staff about their responsibilities.”
While the document was produced in Los Angeles, the rules apply nationally. Derek Hammer runs Hammer Lighting and Grip in Indianapolis and was one of the PERG members who helped vet the document. “These are issues that have begun affecting productions of all sizes in all locales and are not just isolated to the big production cities,” he says. “DOT regulations are federal rules and are enforced by state Motor Carrier Enforcement officers in all 50 states.” Like many grip and lighting rental companies, Hammer runs a fleet of vehicles and is well acquainted with DOT requirements. He acknowledges that understanding what all the regulations mean takes some commitment, but he feels it is essential to a well-run business. “Enforcement is a formidable aspect of this situation, but the insurance and liability concerns may in fact be of greater importance in production. The penalties for non-compliance could be far greater if a driver is involved in an accident that injures another person.”
Lisa Dinson, of MPCS, says compliance is a particularly thorny issue for our industry, and explains why a custom solution makes things a lot easier. “Motor carriers (i.e. studios and independent productions) in the entertainment industry do not conduct typical “over the road” transportation business, yet all state and federal DOT regulations do apply.” She explains it is an inherent “square peg, round hole” problem. “The team of experts at MPCS developed a comprehensive, accessible, and dynamically flexible compliance platform to service the motion picture, commercial, special event and digital media industries.” MPCS assists with various types of services, auditing hours of service, managing driver qualification paperwork and driver records, providing background screenings that verify driver’s previous employment and licensing, conducting drug and alcohol testing and entering drivers into a national industry pool once a clean record is established.
Making a company into a compliant motor carrier can be a long, tedious and confusing process, and may be more than some have bargained for. A company like dotPC takes the job of compliance off the production company’s plate. They sum up their business model this way “dotPC does all the work for you so you can focus on what you do best – filming!” (dotPC website).
dotPC fills out the forms, sends in all the paperwork, and tracks the status of the company’s certifications. Miller explains “dotPC provides trained DOT Coordinators who work alongside production teams and MPCS to ensure driver compliance with each job. Our goal is to educate production companies and crew on the rules and regulations, in and around their already busy schedules.” The coordinator uploads all required paperwork to the MPCS portal, keeps organized files for each job, and alerts production to any potential issues such as Hours of Service. For many productions, this is an ideal solution.
We invite PERG members to download the document and let us know about any questions and challenges that you face in this area.
Download from the Initiatives page of the PERG website.
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