FMCSA Eliminates “Order for Service” Requirement from HHG | Benesch

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In a regulatory victory, interstate household goods movers recently saw the universe of required documents shrink by one key document. In 2017, the Federal Motor Carrier Safety Administration (FMCSA) convened a Federal Advisory Committee, as required by Congress under the FAST Act. The goal for the Committee was to examine the regulation of paperwork while remaining vigilant against abuse by the moving public. Jonathan Todd, a partner in Benesch’s Transportation & Logistics Practice, represented the industry as a voting member of the committee.

Recommended changes to 49 CFR Part 375 were delivered to Congress and published on February 27, 2019. The recommendations included eliminating the long-standing requirement for a written service order document in favor of using the bill of lading (BOWL). These efforts resulted in the FMCSA issuing a final rule on July 27, 2022, which implemented 10 of the 11 recommendations under consideration.

The final rule removes the service order requirement for household goods movers. In its place, FMCSA now uses the bill of lading to capture the intent of the service order. Bill of Lading regulatory requirements have been updated to reflect information previously entered into the service order. These new elements that must be present on household goods bills of lading are: (1) each attachment to the bill of lading, including, if not provided elsewhere, the binding or non-binding estimate and the inventory ; (2) any identification or registration number assigned to the shipment; and (3) a statement that the bill of lading incorporates by reference all services included in the estimate [see 49 CFR 375.505(b)].

This development allows household goods movers to reduce the overall administrative burden of shipping formalities by eliminating one of three key documents (estimate and bill of lading remain). Although short-term updates are required to accomplish this change, the net effect is positive for the industry and removes the risk of error in the issuance and processing of required documents.

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