Short-haul exemption: 100 air-mile radius


Are you 100 air-mile exempt?

What is an air mile?

An “air mile” is a nautical mile measuring a straight distance between two points, excluding any twists or turns.

What is the short-haul exemption?

If you are a short-haul driver or fleet, in addition to time restrictions, there are two types of short-haul exemptions related to distance, the 100 air-mile exemption and the 150 air-mile exemption.

  • 100 air-mile exemption

The exemption applies to CDL drivers and to qualify they must remain operating within a 100 air-mile radius, return to the same work reporting location, go off duty within 12 hours and keep time cards with their start times, end times and total hours worked for the day.

  • 150 air-mile exemption

This exemption is slightly different in that it applies to non-CDL drivers and instead of the operating radius being 100 air-miles, it is 150 air-miles. Similarly, drivers are required to keep timecards, return to the same work reporting location, and they do not drive through a state that requires a CDL for the vehicle they drive.

Exceeding the short-haul limitation

A driver may violate the short-haul limitations by going over the radius limit or exceeding the time it takes to return to their reporting location.

If this happens, drivers are required to maintain a Record of Duty Status (RODS) and more importantly, if they maintain a RODS for more than 8 days in a 30-day period, they must have an ELD because the mandate exemption does not apply after that 8 days.

The 8-day rule is one of the biggest issues for any short-haul fleet because they are unable to determine if they will hit that 8-day limitation. It is important to note that it is nearly impossible to implement an ELD on short notice, therefore, many questionable short-haul fleets are beginning to install ELDs.

Verifying compliance?

If you have drivers that exempt, it is imperative that you check time records to verify compliance with time and distance restrictions.

If a driver is in violation, you must also verify that they followed proper procedure by taking a 30-minute break and submitting their daily log.

If your company is audited and you or your drivers are found to be misusing these exemptions, you will be cited for each violation every day it occurred which can lead to a rather large fine.

ELDs and short-haul exemptions

In most cases, a driver that qualifies for the 100 or 150 air mile radius is exempt from the upcoming ELD mandate, but there are exceptions.

The final regulation says if you are running short haul, you are not required to maintain Record of Duty Status (RODS) and, therefore, do not need to log your hours with an ELD, unless you break the rule more than eight (8) times in a 30-day rolling period.

If you do break the rule more than eight times, you will need an ELD to log your hours until you get back to the number of eight or fewer in a 30-day period.

Although not always required, ELDs can be an excellent resource for a short-haul fleet, as it allows constant awareness of a driver’s distance, eliminating any concerns of going beyond the radius limit.

Do you still need an ELD? We can help you out!


Stay DOT compliant

Knowing these rules and regulations will allow you to stay compliant and plan your operations more efficiently.

All CNS services are geared toward keeping your trucking company safe, compliant, and on the road.

If you have any questions, call 888.260.9448 or email at info@cnsprotects.com.

HOS short-haul exemptions and HOS compliance


What are short-haul exemptions?

The Federal Motor Carrier Safety Administration (FMCSA) developed several Hours-of-Service rules and regulations with a goal for these HOS rules to minimize driver fatigue and improve road safety for everyone.

However, the FMCSA has created certain exemptions giving drivers and carriers flexibility, depending on their situation. Different rules apply to passenger-carrying drivers, property-carrying drivers and drivers of hazardous materials.

Considering all of the potential HOS changes and so we are on the same page, we will discuss a few important Hours-of-Service rules, including the 14-hour rule, the 11-hour rule and the 30-minute break.

What are 3 important hours-of-service rules?

  • The 14-hour rule?

The 14-hour rule disallows a property-carrying driver from driving longer than 14 consecutive hours after starting duty. The driver cannot continue driving until they have taken ten (10) consecutive hours off-duty.

Passenger-carrying motor vehicles are limited to 15 cumulative hours. This differs from the 14 consecutive hours of property-carrying drivers.

For both property-carrying and passenger-carrying vehicles, off-duty time does not extend the 14-hour period.

  • The 11-hour rule?

The 11-hour rule states that property-carrying drivers are allowed a maximum of 11 hours of drive time after 10 consecutive hours off duty, if they stay within the 14-hour window.

On the other hand, passenger-carrying drivers can drive up to 10 hours after eight consecutive hours off duty.

  • The 30-minute break rule?

According to the 30-minute break rule, drivers can’t log driving time if eight hours have passed since the last off-duty period of 30 consecutive minutes. Drivers can perform non-driving tasks after eight hours without taking a break, but they cannot drive.

Are you a short-haul driver?

The FMCSA rules and regulations state that you are a short-haul driver, if:

  • Start and return to the same location within twelve (12) hours of duty time.
  • Maintain your time-clock function.
  • Do not drive for more than eleven (11) hours.
  • Have ten (10) consecutive hours in off duty between shifts.
  • Operate within a 100 air-mile radius from your starting location (CDL driver)
  • Operate within a 150 air-mile radius (non-CDL drivers)
  • Does not drive through a state that requires a CDL for the vehicle they drive

The 16-hour short-haul exemption – Do you qualify?

The FMCSA implemented a hours of service exemption allowing short-haul drivers to extend their 14-hour driving window by two hours each week.

This could apply to you if you are a short-haul driver and report back to the same work location each day, you might be able to take advantage of the 16-hour short haul exemption.

The exemption doesn’t extend the 11-hour daily driving limit but does provide you with up to 16 hours to complete your workday.

ELDs and short-haul exemptions

In most cases, a driver that qualifies for the 100 or 150 air mile radius is exempt from the upcoming ELD mandate, but there are exceptions.

The final regulation says if you are running short haul, you are not required to maintain Record of Duty Status (RODS) and, therefore, do not need to log your hours with an ELD, unless you break the rule more than eight (8) times in a 30-day rolling period.

If you do break the rule more than eight times, you will need an ELD to log your hours until you get back to the number of eight or fewer in a 30-day period.

Although not always required, ELDs can be an excellent resource for a short-haul fleet, as it allows constant awareness of a driver’s distance, eliminating any concerns of going beyond the radius limit.

Do you still need an ELD? We can help you out!


Stay DOT compliant

Knowing these rules and regulations will allow you to stay compliant and plan your operations more efficiently.

All CNS services are geared toward keeping your trucking company safe, compliant, and on the road.

If you have any questions, call 888.260.9448 or email at info@cnsprotects.com.

Ray Martinez leaving FMCSA at end of October


DOT recently announced that the current FMCSA Administrator, Ray Martinez, will be leaving his position; his last day will be October 28th.

Mr. Martinez has been heading up the Federal Motor Carrier Safety Administration (FMCSA) since March 2018 and has been a very active and involved leader, with initial intentions of settling differences between the agency and the trucking industry. Martinez regularly attended trade shows and conferences to talk to industry leaders and discuss updates on FMCSA work.

How will current FMCSA projects be affected?

Since he started in March 2018, Martinez began work on two major projects, the overhaul of the hours of service regulations and the pilot program for younger interstate drivers.

With this change occurring in the middle of these programs, the major question most trucking professionals have is, will this effect or prolong these programs from being completed? The answer tot his question is unclear, however, there is a good chance that these programs will see a delay.

The move is a result of an ongoing desire to be closer to family in Massachusetts, where he will manage a DOT construction project at the Volpe Center. After switching positions with the current deputy administrator—Alan Hanson (new DOT chief counsel)—Jim Mullen will temporarily replace Ray Martinez until President Trump nominates a permanent replacement.

If you have any questions, call 888.260.9448 or email at info@cnsprotects.com.

CVSA approves drag link welds on Dodge Ram recall


The Commercial Vehicle Safety Alliance (CVSA) recently approved a new inspection bulletin in relation to a recall on the drag link assembly for 2013-2018 Dodge Ram 2500s and Dodge Ram 3500s.

The National Highway Traffic Safety Administration (NHTSA) issued a safety recall report regarding the drag link assembly on 2013-2018 Dodge Ram 2500/3500s.

The CVSA has put the 2019-02 Inspection Bulletin in place to guide the inspection of the drag link assembly on those particular Ram 2500 and 3500 trucks that are subject to roadside inspections.

In accordance with the manufacturer’s approved recall remedy, these vehicles may have the outboard steering linkage jam nuts welded to the adjuster sleeve, which should not be cited as an out-of-service condition.

Drag link assembly
Drag link assembly weld locations for Dodge Ram recall

For the latest Inspection Bulletins, certified roadside inspectors should visit the CVSA’s Inspection Bulletins section to ensure inspections are conducted accurately and using the most up-to-date information.

Stay DOT compliant

It is important to stay up to date on vehicle maintenance, what is checked during an inspection and what can cause you to pass or fail an inspection.

We offer audit services and safety management programs that will ensure you stay in compliance at all times. All of our services are focused on keeping your trucking company safe and compliant so that you stay on the road.

If you have any questions, call (888) 260-9448 or email at info@cnsprotects.com.

CVSA international truck inspection results for 2019


On June 4-6, 2019—as part of the Commercial Vehicle Safety Alliance’s (CVSA) International Roadcheck—67,072 truck inspections were conducted, removing 12,019 vehicles and 2,784 drivers from roads across the US and Canada.

The International Roadcheck is conducted annually and is meant to remove unsafe commercial motor vehicles (CMV) and drivers from roads. During this 72-hour inspection, 17.9% of vehicles and 4.2% of drivers were placed out of service.

The basis for violations comes from the CVSA North American Standard Out-of-Service Criteria.

Inspection levels

There are eight different levels of inspection that the CVSA follows, however the truck inspections in this roadcheck were only subjected to the North American Standard (NAS) Level I, II, and III Inspections.

  • NAS Level I Inspection –includes a 37-step procedure examining the driver operating requirements and vehicle mechanical fitness.
  • NAS Level II Inspection—includes anything that can be inspected without getting under the CMV.
  • NAS Level III Inspection—includes a review of driver requirements, such as the license, cargo and vehicle documentation, record of duty status, seat belt usage, etc.

There were 60,058 Level I, II, and III Inspections conducted in the US and 7,014 in Canada. Respectively, the vehicle and driver out-of-service rate for the US was 17.7% and 4.4% and 19.9% and 2% for Canada.

Inspection focus

Inspections focused on violations related to steering and suspension systems, which resulted in identifying:

  • 408 steering violations or 2.5% of all out-of-service violations
  • 703 suspension violations or 4.3% of all out-of-service violations

Truck inspection results

The results for inspections are summarized below and include out-of-service vehicle, CMV driver, seatbelt, hazardous materials/dangerous goods and motorcoach violations.

There were 16,347 vehicles placed out-of-service with the top violation being for braking systems. The list below summarizes the remainder of recorded vehicle violations.

Out-of-service vehicle violations:

Vehicle violation category Number of violationsPercent of out-of-service violations
Braking systems 4578 28%
Tires and wheels 3156 19.3%
Brake adjustment 2801 17.1%
Cargo securement 1991 12.2%
Lighting devices 1875 11.5%
Suspensions 703 4.3%
Steering mechanisms 408 2.5%
Other 401 2.5%
Frames 170 1%
Coupling devices 124 .8%
Driveline/driveshaft 61 .4%
Fuel systems 44 .3%
Exhaust systems 35 .2%

There were 3,173 drivers placed out-of-service with the top violation being for hours of service. The list below summarizes the remainder of recorded driver violations.

Driver out-of-service violations:

Driver violation categoryNumber of violationsPercent of out-of-service violations
Hours of Service 1,179 37.2%
Wrong Class License 714 22.5%
False Logs 467 14.7%
Other 351 11.1%
Suspended License 232 7.3%
Drugs/Alcohol 99 3.1%
Expired License 94 3%
Violating License Restriction37 1.2%

There were 748 seat belt violations and out of 3,851 CMVs inspected, 527 violations for commercial motor vehicles transporting hazardous materials/dangerous goods with the most common violation being for loading. The list below summarizes the remainder of recorded violations for hazardous materials/dangerous goods.

Hazardous Materials/Dangerous GoodsNumber of violations Percent of out-of-service violations
Loading 7329.9%
Shipping papers 6125%
Placarding 46 18.9%
Markings 31 12.7%
Bulk packaging 15 6.1%
Package integrity 12 4.9%
Other 62.5%

During the International Roadcheck, 823 motorcoaches were inspected with 47 vehicles and 21 drivers being placed out of service. Inspections included a review of emergency exits, electrical cable sand systems in engine and battery compartments and seating.

Out-of-service orders and the number, type and severity of safety violations affect a motor carrier’s Compliance, Safety, Accountability (CSA) score and its Safety Fitness Determination (SFD) rating.

Stay DOT compliant

Knowing what your CSA score is and how it affects your company and all of the requirements to pass inspections, whether it be for brake safety or suspension and steering, will allow you to stay compliant and plan your operations more efficiently.

All CNS services are geared toward keeping your trucking company safe and compliant so that you stay on the road and pass all truck inspections.

If you have any questions, call (888) 260-9448 or email at info@cnsprotects.com.

Brake Safety: DOT inspection results


On May 15, 2019—in the unannounced brake safety DOT inspection—the Commercial Vehicle Safety Alliance’s (CVSA) law enforcement conducted commercial motor vehicle inspections focused on identifying brake safety violations.

The USDOT’s Federal Motor Carrier Safety Administration (FMCSA) reported that in 2017 over half a million commercial motor vehicle violations were related to brakes.

During this one-day DOT inspection, 55 jurisdictions participated (45 US states and 10 Canadian provinces), totaling 10,358 inspections. There were 1,667 vehicles—or 16.1% of all inspections—with critical brake-related violations that were placed out of service until the violations could be corrected. The remaining 84% of commercial motor vehicles inspected did not have any critical brake-related violations.

What was the inspection focus?

Inspectors focused on violations involving brake hoses and brake tubing, which resulted in identifying:

  • 996 units – Chafed rubber hose violations
  • 185 units – Chafed thermoplastic hose violations
  • 1,125 violations – Chafed rubber hoses
  • 124 violations – Kinked thermoplastic hoses

What are the most common brake-related violations?

According to the FMCSA, as of June 28, 2019, out of 1.8 million DOT inspections, the top five brake-related violations were:

  1. Clamp or roto type brake out of adjustment—86,296
  2. Commercial Motor Vehicles manufactured after Oct. 19, 1994, have an automatic brake adjustment system that fails to compensate for wear—45,594
  3. Brake hose or tubing chafing and/or kinking—37,737
  4. No or defective ABS malfunction indicator lamp for trailer manufactured after March 1, 1998—37,343
  5. Inoperative/defective brakes—32,125

The CVSA brake safety enforcement and awareness campaigns are meant to remove unsafe drivers from roads and remind drivers that braking systems need to be checked regularly.

Regular checks help to preserve the safety of both the drivers and others on the road. Although this campaign had a specific focus on brake violations, inspecting the brakes is a normal part of procedure during roadside inspections.

Any issues with the brake hoses and/or tubing can affect the whole brake system. In order to pass, brake hoses and tubing must be properly attached, undamaged, without leaks and have an appropriate amount of flexibility.

The CVSA will be holding a scheduled brake safety enforcement event this year, Brake Safety Week, which is scheduled for Sept. 15-21, at participating jurisdictions throughout North America.

Review the results from the 2018 Brake Safety Week.

Brake Safety Week is part of CVSA’s Operation Airbrake Program in partnership with FMCSA and the Canadian Council of Motor Transport Administrators.

FMCSA changes CDL requirements


On February 7, 2020, the Federal Motor Carrier Safety Administration (FMCSA) will place new CDL requirements on entry-level driver training (ELDT).

Individuals wanting to obtain a commercial driver’s license (CDL), upgrade their current license from a Class B to a Class A CDL or receive driver training for a passenger, school bus or hazmat endorsement. Requirements are also changing for instructors offering CDL training.

What class of CDL are you required to have?

Is it difficult to get a CDL license?

As of February 7, 2020, entry-level CDL trainees will have much stricter requirements for obtaining their CDL. For anyone planning to become a truck driver, you can attend a CDL school and get your CDL license before changes go into effect in 2020.

The new rules require an entry-level driver to complete a prescribed program of theory and behind-the-wheel instruction provided by a school or other entity listed on FMCSA’s Training Provider Registry (TPR) before taking the CDL test.

What are the new requirements to obtain a CDL license?

  • CDL school requirements: The minimum standards and requirements for CDL schools will be set at a federal level, as opposed to being set by each state.
  • Department of Transportation (DOT) management: CDL schools must record and report hours behind the wheel (no federal minimum) to DOT.
  • Schools must register and self-certify: Schools can self-certify instructors. Individual instructors may have to register with the DOT depending on the state.
  • CDL driving instructor requirements: Driving instructors are required to have a minimum of 2 years driving experience, a clean motor vehicle record and a medical certification for classroom, on the road and private range instruction
  • Increase in curriculum mandates:
    • DOT requires 31 theory course topics instead of the original four knowledge topics, which will be accompanied by 19 mandated behind-the-wheel (BTW) skills, that will be tested with vehicle inspection skills at the state department of motor vehicles.
    • The new Training Provider Registry (TPR) will require CDL schools to apply to join, starting February 7, 2022.

Learn more about all levels of truck driver training and CDL test preparation courses that we offer at our CNS Driver Training Center.


CVSA Brake Safety Week truck inspections, September 15-21


The Commercial Vehicle Safety Alliance (CVSA) has announced that their annual Brake Safety Week is scheduled for September 15-21, 2019. There was also an unannounced DOT inspection in May focusing on brake safety as well..

In that time enforcement officials will conduct roadside safety truck inspections on commercial motor vehicles and will focus on brake hoses and tubing.

During last year’s three-day International Roadcheck enforcement campaign, 45 percent of all out-of-service vehicle violations were related to out-of-adjustment brakes and brake-system violations. According to the Federal Motor Carrier Safety Administration’s (FMCSA), brake violations accounted for 6 of the top 20 most frequently cited vehicle violations in 2017.

What is covered in a roadside brake safety truck inspection?

Roadside truck inspections cover all areas of the air brake system; however, the CVSA will focus on brake hoses and tubing, ensuring that all are attached and secure, flexible, and free of leaks, corrosion, and any other type of damage.

Brake inspections consist of a visual check as well as an air brake test using a performance-based brake tester (PBBT) in the 14 jurisdictions where it is available. The performance-based air brake test measures the slow speed brake force and weight at each wheel and uses those measurements to determine the efficiency of the braking system.

According to the US federal regulations and the North American Standard Out-of-Service Criteria, if your brake system efficiency falls below the minimum of 43.5 percent, your vehicle will be put out-of-service.

How can I prepare for a truck inspection of my air brakes?

You should inspect your air brake system and all brake components regularly to keep your vehicle in safe operating condition. The list below covers some items you can visually check on a regular basis to ensure they are securely attached, leak-free, and free of damage, such as corrosion and holes.

  • Air brake chamber
  • Brake hoses and tubing
  • Cotter pins
  • Clevis pins
  • Slack adjuster
  • Air lines

The CVSA has answered some frequently asked questions about your air brake system and inspection and have also provided an air brake inspection checklist, which is a great way to be sure you are prepared for your roadside safety inspection.

What should I know about my air brake system?

If you know your brake system you are more likely to know if there is an issue. You should know what size and type of air brake chamber you have and learn how to properly identify it. Most air brake chambers will have a marking on them, letting you know what type and size it is. If you know the type of chamber you have, you will also be able to determine the maximum allowable push rod travel for that brake chamber and whether it is in or out of adjustment.

What are some types of air brake chambers?

Common air brake chambers for the front are clamp type 20 or clamp type 24 and clamp type 30 is the most common for the rest of the tractor trailer and can be a long or regular stroke.

Brake Safety Week is part of CVSA’s Operation Airbrake Program in partnership with FMCSA and the Canadian Council of Motor Transport Administrators.

Read about the 2018 Brake Safety Week results.

If you have any additional questions, call one of Compliance Navigation Specialist’s DOT Consultants .

Stay DOT compliant

Our Proactive Safety Management program will help you with vehicle maintenance, driver training, safety audits and the many other categories that can put you out of service.

Safety management and proper vehicle maintenance are very important for the truck drivers’ safety as well as others on the road. It will also allow you to stay compliant and plan your operations more efficiently.

All of our services are geared toward keeping your trucking company safe and compliant.

If you have any questions, call (888) 260-9448 or email at info@cnsprotects.com.


Governor Wolf amends bill for the transportation industry


Governor Tom Wolf increases fines for improper driver’s license

Pennsylvania Governor, Tom Wolf, signed in multiple bills on Friday, June 28, 2019. One of those bills, House Bill 384, is related to the transportation industry.

The bill was amended and may affect you if you are in Pennsylvania and work in the transportation industry or if you are an individual operating, hauling or towing oversized loads and/or vehicles.

The House Bill 384 was amended to increase the fine to $200 for driving a vehicle without the proper classed operator’s license.

Do I have the proper driver’s license?

There are many factors to consider when determining what type of driver’s license is required and this can vary by state. This bill only effects Pennsylvania residents, but it is important to be aware of the laws in your state.

If you are a Pennsylvania resident and are unsure if you have the proper license or believe you may need a CDL for the vehicle you are operating, refer to our previous post, Determining class of CDL required. Residents of all other states outside of Pennsylvania should research requirements in their state or contact us directly. Our licensing and permitting team can assist you with any further questions or concerns.

FMCSA Seeks Public Comment on Pilot Program to Allow Drivers Ages 18-20 to Operate Commercial Motor Vehicles in Interstate Commerce

WASHINGTON – The U.S. Department of Transportation’s (USDOT) Federal Motor Carrier Safety Administration (FMCSA) today announced that it is seeking public comment on a potential pilot program that would allow drivers ages 18-20 to operate commercial motor vehicles (CMVs) in interstate commerce.

“Commercial trucks and buses are essential to a thriving national economy, and the Department wants to ensure the public has an opportunity to comment on this important potential change,” said U.S. Transportation Secretary Elaine L. Chao.

Drivers ages 18-20 may currently only operate CMVs in intrastate commerce. In July 2018, USDOT announced the details of the Commercial Driver Pilot Program required under the Fixing America’s Surface Transportation (FAST) Act, which allows certain 18- to 20-year-olds with military training to operate CMVs in interstate commerce.

Today’s action requests comments on a second pilot program to allow non-military drivers ages 18-20 to operate CMVs in interstate commerce. FMCSA requests comments on the training, qualifications, driving limitations, and vehicle safety systems that FMCSA should consider in developing options or approaches for a second pilot program for younger drivers.

“We want input from the public on efforts that offer the potential to create more jobs in the commercial motor vehicle industry, while maintaining the highest level of safety. We encourage all CMV stakeholders to submit comments on a potential interstate pilot program for younger drivers,” said FMCSA Administrator Raymond P. Martinez.

The Federal Register Notice, including how to submit comments, is available here.