Some issues reappear every few years, hopefully with experience they are addressed quickly and our actions have a positive impact on the length of time between reoccurrences. One issue that we have seen before is California Highway Patrol (CHP) officers erroneously issuing citations to California Public Utilities Commission (CPUC)-regulated Household Goods Carriers for failure to display a valid CA # on the side of their vehicles while legally transporting used household goods within California.

In the last two months, we have seen a larger-than-expected number of these erroneous citations being issued by officers at several CHP inspection facilities. It is probably impossible to completely eliminate these citations; the number of CA #-exempt vehicles is relatively small as a percentage of the total number of commercial vehicles. We definitely want to ensure that their issuance is not common and that the resolution of these citations is not onerous for the carrier, who has not violated California law.

 Fact: The Vehicle Code excerpt below exempts CPUC-
permitted carriers from displaying a CA # on the side of their vehicles while transporting used household goods.

 California Vehicle Code:
V C Section 34500 Required Regulations
Required Regulations 34500. 

The department shall regulate the safe operation of the following vehicles:

(j) Any other motortruck not specified in subdivisions (a) to (h), inclusive, or subdivision (k), that is regulated by the Department of Motor Vehicles, Public Utilities Commission, or United States Secretary of the Department of Transportation, but only for matters relating to hours of service and logbooks of drivers.

Erroneous Violations:

Section Violations
34620(A) VC Motor carrier permit required —
392.2AU — MCP REQUIRED
34507.5(B) VC /002 Intrastate carrier-no ID number displayed — t 390.21A —
NO CA # DISPLAYED

With the assistance of CMSA Legislative Advocate Chuck Cole, we were able to establish a line of communication with CHP officers assigned to the CHP Sacramento Office of Special

Representative. They agreed with us that CPUC-permitted HHGs Carriers who use their commercial vehicle for CPUC-regulated and/or reported work are not required to have a motor carrier of property permit or a CA # on the side of their equipment. We were informed that an interoffice memo explaining the misunderstanding would be sent to CHP inspection facilities. If one of your drivers received such a citation, the CHP office where it was issued should be contacted to have the record corrected.

While reviewing this issue with CHP Commercial Vehicle officers, I took advantage of the opportunity to ask for clarification of another question. Is it a California law that Class C commercial drivers operating Class C equipment for intrastate transportation are required to have a valid medical card?

The reason for the question, the answer to which is “NO” (for HHGs carriers not handling placarded hazardous materials), is that as a result of CSA 2010, Class C drivers in Class C vehicles must have a valid medical card for interstate transportation. I have been informed by at least one CMSA member that a CHP officer, while writing a citation for the interstate violation, stated that the same rules hold true for California intrastate work. This is NOT correct.