What is the Short Haul Exemption?
The FMCSA hours of service (HOS) short-haul exemption allows certain commercial drivers to be exempt from some of the HOS rules that apply to long-haul truckers.
The most important relief being that these drivers don’t have to log their hours of service with an Electronic Logging Device (ELD ).
These FMCSA ELD exemptions only applies to truck or bus drivers who:
- Operate within a 150 air mile radius of their work reporting location and
- Return to that location at the end of each duty day.
(This hours of service regulations exemption is also often called that 150 air mile radius exemption as well because of this. Some others may refer to these as the DOT hours of service for local drivers as well).
Under the short-haul exemption, drivers are allowed to remain on duty for up to 14 hours, but the driving time is limited to 11 hours.
In addition, drivers are not required to take a mandatory 30-minute break after 8 hours of driving, as is required for most truck drivers.
Additionally, drivers who use the short haul exception are not required to keep records of duty status (RODS) or use ELDs.
Check out our video on the short haul exemption here:
To use these e log exceptions, a short haul trucking driver simply have to have a time card or a time sheet which is usually kept at their normal work reporting location.
However, it’s important to note that the short-haul exception has specific requirements that must be met, including requirements for maintaining records of duty status and the use of their time card system.
Drivers and carriers must ensure that they are in compliance with these requirements in order to take advantage of the exception.
Who qualifies for the Short Haul Exemption?
In the final rule of the ELD mandate, the Federal Motor Carrier Safety Administration outlined which drivers would not have to use electronic logging devices. These FMCSA exceptions granted relief from the requirements of both §395.8 and §395.11 if a driver qualifies.
To qualify for the hours of service (HOS) short-haul exemption, a commercial driver must meet the following criteria:
- The driver must operate within a 150 air-mile radius of their work reporting location and must return to that location at the end of each duty day.
- The driver must not exceed a 14-hour workday, with a maximum of 11 hours of driving time.
- The driver must be off duty for at least 10 hours before starting a new duty day.
- The driver must keep accurate records of duty status (RODS) to document compliance with the short-haul exemption.
As long as a driver meets each of those conditions, they can use the 150 air mile exemption.
How does the Short Haul Exemption work?
The short-haul exemption is intended to provide greater flexibility to drivers who operate within a limited geographic area and who are able to return to their home terminal each day.
This FMCSA HOS exemption is often used by short haul trucking drivers who make multiple short trips within a single day and need to take advantage of the additional time to complete their deliveries.
The short haul exception works great for intermodal container haulers who operate around port locations, local delivery drivers, roll-off dumpster companies, dump truck operations and ready mix haulers.
This isn’t a complete list, of course. Any short haul drivers who operate within a 150 air-mile radius of their work reporting location and who return to that location before the end of each 14 hour driving window can use the exception.
Using the exception is simple. Just record when a driver reports to their “normal work reporting location at the beginning of their duty period. Once they finish their duty day, simply record the time that they returned on the same “time card”.
We help monitor and manage your entire Hours of Service program as part of our comprehensive DOT compliance services!
Logging the Short Haul Exemption:
As we mentioned, you must keep a time card or other document for each day that you plan to use the the 150 air mile exemption.
These hours of service records must include:
- The time the driver reports for duty
- The time the driver goes off duty
- The total number of hours the driver is on duty each day
- The driver’s total driving time for the last seven days
Pro Tip: Be sure to keep these time cards for at least 6 months. You also have to be prepared to produce them for inspection with a 2 business day notice as well.
Grab a short haul exemption timesheet here!
No special documentation is required to use the exception, but you can gladly grab our short haul exemption truck card to share with each drivers who are using the exception.
Download our short haul exception “cab card”
Again, this isn’t required. But, it can help a driver explain their position if they’re stopped for a roadside inspection.
If your driver is stopped for a roadside inspection while using this hours of service exemption and the officer refuses to recgonize the use of the exception for some reason, be sure to keep your DVER from the inspection and you can submit a DataQ to try and have it removed.
You would also want to keep any HOS supporting documents that can be used as evidence for the request (like bills of lading, GPS information or fuel receipts).
Don’t forget that you’re still subject to the 60 70 hour driving limits and have the 34 hour reset provision at your disposal.
Some officers may feel that a driver who is also running an ELD has to run the logging device and abide by the 395.8 and 395.11 regulations. This is untrue, of course.
But, do remember that officers could use ELD information or a document (like a BOL for the shipment with a delivery location outside of 150 air miles) to invalidate the use of the FMCSA short haul exemption. You’ve been warned!
How does 150 air miles work?
150 air miles is equal to 172.6 “statute” or over the road miles.
The 150 air mile radius can be thought of as being “as the crow flies” from your normal work reporting location.
So, your normal work reporting location would be Point A and your destination for your trips have to be within 150 air miles (or nautical miles) from your reporting location.
A pretty good way to easily find this is to:
- Pull up Google Maps
- Enter Your Starting and Ending Destinations
- Click on the option for “Walking” instead of driving
This gives you a pretty good approximation for air miles.
You can also just:
- Pull up Google Maps
- Right click on the map
- Select “Measure Distance” at the bottom of the pop out menu
- You can then drag the little white dot out 150 miles from your starting point
You can also check out this link to see how to determine this on PC Miler.
What are some limitations on using the Short Haul Exemption?
It’s important to note that the short haul exemption has some restrictions and limitations, and it’s up to the driver to know and understand these rules in order to be compliant with the regulations.
For example, the short-haul exemption does not apply to drivers who are transporting some types of hazardous materials, and the rules may also vary based on state regulations.
Additionally, the exemption is not available to drivers who regularly operate commercial motor vehicles outside of the 150-air-mile radius. If you go outside of the 150 air miles during any duty day, you would have to complete a paper log/ RODS for that day only.
Pro Tip: If you exceed the 150 air mile radius or 14 hour period more than 8 times in a 30 day period, you have to switch to an ELD.
Recent Changes to Other HOS Exemptions
In September 2020, the FMCSA changed the short haul exemption to allow Commercial motor vehicle drivers to extend their maximum on-duty period from 12 hours to 14 hours. Additionally, they extended the range of the exception from a 100 air mile radius to a 150 air mile radius.
They also made these changes to other key hours of service exemptions:
Adverse Driving Conditions
CMV Drivers are now allowed to extend their 11-hour driving clock and 14-hour driving window by up to 2 hours when adverse driving conditions are encountered. Again, you can use this with the 150 air mile radius exemption.
Split Sleeper Berth Flexibility
Truck drivers may now split their required 10-hour off-duty period, as long as one off-duty period (whether in or out of the sleeper berth) is at least 2 hours long and the other involves at least 7 consecutive hours spent in the sleeper berth. This is commonly known as an 8/2 split or a 7/3 split. All sleeper berth pairings must still add up to at least 10 hours. Also, when used together, neither of the split time periods count against the driver’smaximum 14- hour driving window.
30 Minute Break Requirement
Drivers must now take a 30-minute break when they have driven for a period of 8 cumulative hours without at least a 30-minute interruption. Previously, you would have had to take your 30 minute brake within 8 hours of coming on duty.
Pro Tip: If you’re going to have to create a paper log for a day, you’re going to have to abide by the 30 minute break requirement for that day as well. So, plan on doing that as soon as you know you’ll not be able to use the short haul exemption.
Short Haul Exemption FAQs
What happens if you’re using the short haul exemption and you end up exceeding the exception imits (150 air mile radius or 14 hour duty window)?
You must log your hours using a paper log for that duty day. If you do this more than 8 times (days) in any 30 day period, you would then have to use an electronic logging device.
Can a driver use both the adverse driving conditions exemption with the short haul exemption?
Absolutely! You can use both if you qualify for both exceptions to the HOS regulations. But, if the driver doesn’t make it back to their terminal location before the end of their 14 hour duty day, they would have to complete a paper log/ RODS (Record of Duty Status).
Can a driver who claims the short haul exception use personal conveyance?
Yep! There is no connection between personal conveyance and the short haul exemption. You can use both exceptions at once in combination or by themselves.
Can you run an ELD in your truck if you’re taking advantage of the short haul exception?
Sure and it’s probably a great idea to do so for a number of other possible reasons. Most importantly, ELDs can be helpful in tracking speeding and other unsafe driving behaviors. Increasingly, truck camera systems/event recorders are being tied into ELDs as well. Many fleets also use ELDs for DVIR reporting and other vehicle maintenance activities.
Short Haul Exemption: Wrapping Up
As you can see, the short haul exemption can be a pretty poweful tool in your Hours of Service toolbelt. Hopefully, you can see some value to using the exception if you’re truck or buses are regularly operating within 150 air miles of your terminal location.
Keep in mind, that there are some HOS rules that must still be followed and you’ll need to keep accurate time cards for each driver operating under the exemption.
Be especially careful if some drivers may go outside of the radius or not return to the same location in the 14 hour duty period.
If that happens, they’ll have to at least prepare a paper log for that duty day.
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