NWRA Sought Clarification for “Curotto Can” Operations in Florida

NWRA Sought Clarification for “Curotto Can” Operations in Florida

Arlington, VA – The National Waste & Recycling Association (NWRA) issued the following statement after receiving clarification on the operation of dumping containers on hydraulic arms that extend in front of the vehicle sometimes referred to as a “Curotto Can.”

In May 2019, the Florida legislature passed and the Governor signed HB 725 that eliminated the statutory provision exempting waste and recycling vehicles. Working with the Federal Motor Carrier Safety Administration (FMCSA), NWRA on behalf of its Florida members received the following clarification:

FMCSA understands that the standard headlamps and turn signals may be obstructed during the “work performing” operation of loading trash cans into the dumping container. During the work performing portion of the trash collection operation, the CMV may be slowly moving from residence to residence but is not in a transit operation, where the waste recycling CMV is traveling on roads and highways at posted highway speeds. Assuming that the dump container is carried on top of the waste recycling CMV during normal transit operations and not blocking the headlamps or turn signals, FMCSA does not believe that there is any FMCSA CMV regulatory violation with regard to obstructing required headlamps or turn signals. FMCSA consulted with several CMV Roadside Inspectors and determined that were the vehicle to be inspected at roadside, it would be inspected as if it was in “transit” operations with the dump container stowed on top of the CMV, and not in the configuration as if it was loading trash cans into the dump container.


The National Waste & Recycling Association (NWRA) represents the private sector waste and recycling services industry. Association members conduct business in all 50 states and include companies that manage waste, recycling and medical waste, equipment manufacturers and distributors, and a variety of other service providers. For more information about NWRA, please visit www.wasterecycling.org.

Brandon Wright
National Waste and Recycling Association