Do I Need an MCS-90
to Haul Septage?
Not because of the septage. MCS-90 is tied to for-hire interstate motor carrier authority, not to what is in your tank. Domestic septage is not a hazardous material for transport purposes.
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The longer answer
With the sources, so you can check us.
What the endorsement is
A federally mandated endorsement guaranteeing payment of a public judgment regardless of policy conditions, with a reimbursement obligation running back from the insurer to the insured. It is a financial guarantee to the public, not coverage for you.
What triggers the requirement
Federal financial responsibility rules reach for-hire motor carriers transporting property in interstate or foreign commerce, plus carriers of hazardous materials, substances or wastes including in intrastate commerce. The hazmat limb is the one people assume applies to septage.
Why it does not reach domestic septage
EPA defines domestic septage as material from a works receiving only domestic sewage. It is not listed as a hazardous substance in the transport rules, and it is not a hazardous waste because it is regulated under a different part entirely rather than through the waste manifest system.
What does apply to your trucks
Weight thresholds. A USDOT number for interstate operation at 10,001 pounds, with many states applying it intrastate too, and a commercial driver licence at 26,001 pounds. A loaded vacuum truck generally clears both.
Sources: 40 CFR 503.9 (domestic septage), 49 CFR 171.8 (hazardous substance and waste definitions), 49 CFR 383.5 (CDL definitions)
What this means for your business
- A federally mandated endorsement guaranteeing payment of a public judgment regardless of policy conditions, with a reimbursement obligation running back from the insurer to the insured. It is a financial guarantee to the public, not coverage for you.
- Federal financial responsibility rules reach for-hire motor carriers transporting property in interstate or foreign commerce, plus carriers of hazardous materials, substances or wastes including in intrastate commerce. The hazmat limb is the one people assume applies to septage.
- EPA defines domestic septage as material from a works receiving only domestic sewage. It is not listed as a hazardous substance in the transport rules, and it is not a hazardous waste because it is regulated under a different part entirely rather than through the waste manifest system.
- Weight thresholds. A USDOT number for interstate operation at 10,001 pounds, with many states applying it intrastate too, and a commercial driver licence at 26,001 pounds. A loaded vacuum truck generally clears both.
Answered by Septic Cleaning Insurance Group
We only write this trade, and we read the policy before we sell it. More on the operations we insure and the coverage behind them.
Straight answers, no insurance-speak
It guarantees payment of a public judgment regardless of policy conditions, then gives the insurer a right to be reimbursed by you. It protects the public, not the carrier’s insured.
Yes, through the ordinary route: operating as a for-hire motor carrier of property in interstate commerce. That is a question about your authority and your operation, not about what is in your tank.
Weight-based ones. A USDOT number at 10,001 pounds for interstate operation, with many states applying it intrastate as well, and a commercial driver licence at 26,001 pounds. A loaded vacuum truck clears both.
Possibly not. These answers describe standard forms and common rules; your policy may carry endorsements that change the result either way. Send the declarations and endorsement schedule and we will tell you what your form does.
Get Your Do I Need an MCS-90 to Haul Septage? Septic Insurance Quote
A few quick questions about your operation. Takes about 2 minutes. Prefer to talk first? Call (855) 461-2010.
Want this answered against your actual policy?
Send the declarations and endorsements. We will tell you what your form does, not what a standard form does.
No pressure. If we’re not the right fit for your business, we’ll tell you straight.