What do you check before a carrier you don’t know hauls your fuel?
Check five things, in this order: the carrier’s authority, its insurance, its cargo tank, its driver’s licence and its terminal access. Each one is a document or a public record, so none of it depends on how the carrier sounds on the phone.
A generic carrier checklist built for dry vans stops at “authority active, insurance on file.” Fuel adds three checks a dry-van list never asks for: the hazmat insurance level, the tank’s inspection status, and the driver’s endorsements. A carrier can pass the first two and still be unable to legally lift your load.
If you are the one hauling, see how to start a fuel hauling business. This post is for the shipper’s side: what you ask a stranger for before you give them a load. (Some people call this vetting an “external hauling company.” In the US it is just a carrier you haven’t used before.)
Is the carrier’s operating authority active?
Start with the public record, not the carrier’s own paperwork. Look the company up by USDOT number or MC number in FMCSA’s public SAFER and licensing-and-insurance lookups, and confirm three things:
- The USDOT number belongs to the company named on your rate confirmation, not a similar one.
- The operating authority, where the carrier needs it, shows as authorized, not “NOT AUTHORIZED” or out of service.
- The insurance filing the record shows is current.
Match the legal name and address on the record to the name on the certificate of insurance and the bill of lading. A mismatch is the first sign that the truck at your rack belongs to someone other than the carrier you vetted. The same goes for a load passed on to another carrier: if you did not vet the truck that shows up, you have not vetted the carrier.
Some carriers operate only inside one state and follow state rules rather than interstate authority. Ask which applies and what they hold, rather than assuming.
What insurance minimum applies to hauling fuel?
Federal rules set the minimum public liability level by what is in the tank, and fuel is not at the nonhazardous level. The schedule is in 49 CFR 387.9. These are the rows that apply to a vehicle with a gross vehicle weight rating of 10,001 pounds or more:
| Table entry | Commodity, as the rule states it | Minimum |
|---|---|---|
| (1) For-hire, interstate | Property (nonhazardous) | $750,000 |
| (2) For-hire and private | Hazardous substances transported in bulk in cargo tanks; in bulk Division 1.1, 1.2 or 1.3 materials; in bulk Division 2.1 or 2.2 material; and the other categories the rule lists | $5,000,000 |
| (3) For-hire and private | Oil listed in 49 CFR 172.101; hazardous waste, hazardous materials, or hazardous substances listed in 49 CFR 172.101, but not mentioned in entry (2) or (4) | $1,000,000 |
Read the rule for the entry that fits what you are shipping. Entry (2) names specific categories, and entry (3) catches the listed oils and hazardous materials not named in (2) or (4). Confirm with the carrier’s insurer, or your own, which entry covers your product; the table is the floor the regulation sets, and your own contract can require more.
Worked example (illustrative numbers): say a carrier’s certificate shows $750,000 of auto liability. That is the nonhazardous level in entry (1). For a bulk fuel load, the lowest level the table sets for listed oils and hazardous materials is $1,000,000, so the certificate falls short however clean the rest of the packet looks. Send it back and ask for a certificate at the right level before the truck is dispatched.
Then read the certificate itself:
| On the certificate | What to confirm |
|---|---|
| Insured name | Matches the carrier on the authority record |
| Policy dates | In force on the day of the load, not only the day you received it |
| Auto liability limit | At or above the level for your commodity |
| Certificate holder | Your company, so the insurer notifies you of cancellation |
| Producer or agent contact | A real person you could call to confirm the policy |
A certificate is a snapshot. Ask for a fresh one when you start with a new carrier, and again when the policy renews.
Is the cargo tank current on its inspections?
A specification cargo tank cannot be filled once a required test or inspection is due. 49 CFR 180.407 says a tank for which a test or inspection “has become due, may not be filled and offered for transportation or transported until the test or inspection has been successfully completed.”
The periodic table in the same section sets the intervals. For most cargo tanks it lists an external visual inspection every year, a leakage test every year, and an internal visual inspection and pressure test every five years. Some tank types and services have shorter or longer intervals, so treat these as the common case, not a rule for every tank.
As a supplier or broker, ask the carrier for:
- The tank’s most recent inspection and test records, with dates.
- Which tank, by unit number or plate, will run your load.
- A look at the markings if you can see the truck at the rack. The rule says a tank that passes a test or inspection must be marked under 49 CFR 180.415, so a tank with no current marking is a question to ask before loading.
A tank that fails must be repaired and retested, or taken out of hazardous materials service. If a carrier cannot give you test dates for the tank, do not load it.
Does the driver hold the right endorsements?
Ask to see a CDL with the tank vehicle and hazardous materials endorsements. 49 CFR 383.93 requires a state-issued endorsement to operate a commercial motor vehicle that is a tank vehicle or is used to transport hazardous materials, and each endorsement requires a knowledge test.
Two points trip up shippers. First, endorsements belong to the driver, not the company, so a carrier with qualified drivers can still send an unqualified one. Second, you confirm one from the licence itself, or from the driver’s motor vehicle record the carrier keeps on file, not from the carrier’s say-so. Ask the carrier to commit in writing that only endorsed drivers will run your loads, and check at pickup.
Will the carrier actually be able to load?
Being legal on the road is not the same as being able to lift your product. Terminals decide who loads, and a carded terminal rack will not release product to a driver it has not authorised. On top of the terminal’s own credentials, the supplier whose fuel it is typically issues a loading number that ties the carrier, terminal and destination together.
So ask early: which terminals is this carrier carded at, and has the driver loaded at the one you use? A carrier that passes every check above and is not carded at your rack cannot take the load. Settle it before you commit, not when the truck is idling at the gate.
What does the whole checklist look like in one place?
| Check | Where to look | Pass looks like |
|---|---|---|
| Authority | FMCSA public SAFER and licensing lookups | Name matches; authority shows as authorized; insurance filing shown |
| Hazmat insurance | Certificate of insurance against 49 CFR 387.9 | Limit at or above the entry for your commodity; policy in force; you are the holder |
| Cargo tank | Inspection and test records; markings under 49 CFR 180.415 | No test or inspection overdue under 180.407; the unit named matches the truck |
| Driver | CDL, checked at pickup | Tank vehicle and hazardous materials endorsements present |
| Terminal access | The carrier, then the terminal | Carded at your rack; loading number issued |
Keep the packet, with the date you checked each item. What the carrier owes you after the load, such as the bill of lading and a signed ticket, is a separate question from whether it should have been given the load. For what a carrier charges once it passes, see fuel hauling cost per gallon and how fuel brokers get paid.
How Energy Connect handles it
The checks above are yours to make, against public records and the carrier’s own documents, whichever tools you use to dispatch. Treat any carrier data a dispatch or load-board tool shows you as a pointer to the public record, not a substitute for checking it.