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.

Safety Fitness Determination

Closeup shot of male hand in watches holding car steering wheel

A proposed federal rule that would give the Federal Motor Carrier Safety Administration another means to score and target unsafe carriers has cleared the White House’s Office of Management and Budget.

The so-called Safety Fitness Determination Rule cleared the OMB late last week and is now in the hands of the DOT, ready for publication as a Notice of Proposed Rulemaking when it chooses.

Since this is the proposed version of the rule, there will be a public comment period, likely either 60 or 90 days, following its publication. FMCSA will then begin work on a final version of the rule and send it down the regulatory pipeline for publication, a process that could take several years to complete.

The DOT has been working on the rule since 2007. Few details are known about what it entails. According to the agency’s regulatory summary, it would give FMCSA a new system to “determine when a motor carrier is not fit to operate.” The safety determination, however, would be in part based on the BASIC categories in the agency’s Compliance, Safety, Accountability program, and it’s unclear whether recent Congressional action to remove CSA rankings from public view will impact the SFD rule.

Language in the highway bill expressly prohibited use of SMS BASIC “alerts and the relative percentile for each BASIC developed under the CSA program” to be used for carrier Safety Fitness Determinations until FMCSA acts on the required revamp of the CSA program. The highway bill directed the agency to, within 18 months, commission a study by the National Academies to recommend improvements to the CSA SMS, with implemented changes then following before returning the SMS to public view.

The NPRM will likely be published before year’s end.

If you have questions about this, please do not hesitate to contact CNS.  It is important that you understand what this could mean for you and your business.

Medical Card / MVR Requirements

Requirements starting January 30, 2015

Beginning January 30, 2015, a driver required to have a commercial driver’s license, who has submitted a current medical examiner’s certificate to the State documenting he/she meets the physical qualification requirements, will no longer need to carry the medical examiner’s certificate (or a copy of the certificate) for more than 15 days after the date it was issued as valid proof of medical certification.

Beginning, July 8, 2015, a driver required to have a commercial learner’s permit, who has submitted a current medical examiner’s certificate to the State documenting he/she meets the physical qualification requirements, will no longer need to carry the medical examiner’s certificate (or a copy of the certificate) for more than 15 days after the date it was issued as valid proof of medical certification.

A CDL or CLP holder who obtained a medical variance from FMCSA must continue to have the original or copy of the medical variance documentation in his/her possession at all times when on-duty.

Driver Qualification Files

If the CDL issuing state motor vehicle record contains medical certification status information for the CDL holder, the motor carrier employer must obtain the motor vehicle records from the current licensing State and place it in the driver qualification file. The motor carrier has 15 days to obtain the MVR from the date stamped on the medical examination certificate.  The medical examiner’s certificate or a copy must be placed in the DQ file for the 15 day period (or until the CDL issuing state MVR is put there).  Without either the MVR or the medical examiner’s certificate (for the 15 day period), the motor carrier may not let the driver operate a CMV.

After January 30, 2015, a non-excepted, interstate CDL or CLP holder who does not have medical certification status information on the CDL issuing state motor vehicle record will be designated “not-certified” to operate a CMV in interstate commerce. A motor carrier may use a copy of the driver’s current medical examiner’s certificate that was submitted to the state for up to 15 days from the date it was issued as proof of medical certification.

Under a proposed rule issued May 10, 2013, the 15 day grace period will eventually be removed.  (78 Fed. Reg. 27349.)  If the proposed rule is adopted without change, carriers would be required to obtain the CDL issuing state MVR before letting the driver drive, and would not be able to rely on putting the medical examiner’s certificate in the DQ file.  The rule would require medical examiners to submit the results of their medical examinations on the same day as the examination, and for states to update their CDL issuing state MVR information within a day.  Because there would be no delay in the information being put in the CDL issuing state, here would be no need for a delay in carriers obtaining the information.

If you are under CNS Driver File Management program there is no need to worry! We have got you covered. We will pull your CDL or CLP holders record 15 day after the medical card expires. We will also keep informing you on when the CDL or CLP holder’s medical card expires.

Not enrolled in CNS Driver File Management program yet? Contact us today and learn how easy it is to enroll. Plus, we will get you 100% compliant with your driver files. Call 1-888-260-9448 today.