Marc's Safety Corner

Ask our panel of experts, Marc and Guy, any questions you may have around fleet safety, compliance, DOT audits, roadside inspections or CSA scores. 

Dear Marc,

In my ELD app, there is a short-haul 100 air miles provision, but I always thought it was supposed to be 150 air miles. What is the difference?

 

Dear Reader,

There are a few scenarios concerning the short-haul provision. See below for which one applies to you.

100 Air-Mile Radius rule

A driver is not required to fill out a log with a graph grid if he/she comes under the 100 air-mile radius exception. Incidentally,  in the short-haul exceptions you will see the term “air miles.” This is a different measurement of a mile than what is used for statute miles on a roadmap. An air mile is longer than a statute mile. There are 6,076 feet in an air mile and 5,280 feet in a statute mile. One-hundred air miles is equal to 115.08 statute miles. Therefore, a 100 air-mile radius from your work reporting location can be figured as 115.08 statute, or “roadmap,” miles from your work reporting location and not 100 miles.  Many truckers are not aware of this fact.

Moving on, the 100 air-mile radius exception applies for any day in which a driver:

  • Drives within a 100 air-mile radius of his/her normal work reporting location,
  • Returns to their work reporting location, and are released within 12 consecutive hours, and
  • Follows all other basic hours-of-service rules, including the 10-hour off-duty and 11-hour driving requirements.

In order to take advantage of this exemption, the motor carrier must keep time records of the times a driver reports for and is released from work each day, and the total hours on duty each day.

A driver does not have to have these records in your truck or to surrender to a safety official at roadside.

Another key point is that many truckers are not aware that this exemption is optional. Many fleets and their drivers have elected to use a logbook even though they are within the 100 air-mile radius.  They main reason for this, is that a driver is no longer required to be released from work within 12 hours in that day.

Again, the motor carrier that employs the driver and utilizes this exemption must maintain and retain for a period of 6 months accurate and true time records showing the following:

  • The time the driver reports for duty each day;
  • The total number of hours the driver is on duty each day;
  • The time the driver is released from duty each day; and
  • The total time for the preceding 7 days for drivers used for the first time or intermittently.

This regulation is found in Section 395.1(e)(1).

 

Non-CDL Short-Haul

A driver is not required to fill out a log with a graph grid if he/she comes under the non-CDL short-haul exception. Following what I described above, a 150 air-mile radius from a driver’s work reporting location is 172.6 statute miles.

The non-CDL short-haul exception applies on days when a driver:

  • Drive a truck that does not require a CDL,
  • Work within a 150 air-mile radius of your normal work reporting location and return there each day.
  • Follow the 10-hour off duty and 11-hour driving requirements,
  • Do not drive after the 14th hour after coming on duty on 5 days of any period of 7 consecutive days, and
  • Do not drive after the 16th hour after coming on duty on 2 days of any period of 7 consecutive days.

Once again, the motor carrier that employs such drivers must keep time records of the times he/she reports for and are released from work each day, and the total hours on duty each day.

This regulation is found in Section 395.1(e)(2).        

 

150 Mile Agricultural Exemption

Refer to Demystifying The Short-Haul ELD Rules In The U.S. for more information on the 150 Mile Agricultural Exemption.

 

The above information is for informational purposes only, and should in no way be relied upon as legal advice.

  Mar 26, 2019     Marc Moncion

Moncion-Marc

Marc Moncion

Lead Expert - Fleet Complete

Marc is the Head of Safety, Compliance & Regulatory Affairs at Fleet Complete. He is an author and industry subject matter expert who has worked in numerous senior transportation management roles for over 25 years, including an Inspector for the MTO. Marc sits on several Federal/State/provincial regulatory bodies and frequently provides commentary on emerging technology, best practices and regulatory affairs. In addition, Marc is a commercial driver's licence (CCD) holder and can drive all types of commercial vehicles in North America.

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