Short-haul records need a daily eligibility check

A dispatcher adds one more delivery to a local driver's afternoon. The truck may still be close to the terminal, but a delayed return or a distant stop can change the record required for the entire duty day. The useful question is not whether the company calls the route local. It is whether this driver actually qualifies for the short-haul exception today, and what happens if the plan changes. This resource examines existing federal rules for ordinary CDL drivers hauling property in operations covered by Part 395; passenger service, non-CDL provisions, driver-salesperson rules, and other specialized exceptions need separate treatment. It reports no new rule.

Start with the conditions in 49 CFR 395.1(e)(1). The driver must operate within a 150 air-mile radius of the normal work reporting location, return there and be released within 14 consecutive hours, and have at least 10 consecutive hours off duty separating the duty periods. The employer must keep accurate time records for six months. Those records show the daily reporting time, total on-duty hours, and release time, plus preceding-seven-day totals for first-time or intermittent drivers as specified in the rule. A route label alone proves none of those conditions.

The distance test is a radius, not a daily odometer allowance. FMCSA identifies 150 air miles as 172.6 statute miles. Editorial inference: a route review should compare each operating location with the normal reporting location, rather than treating the sum of road miles as the eligibility test. Multiple stops and a winding road can create a long trip inside the circle; one distant stop can cross it. Likewise, returning to the yard is not the same as release from work. A time record must capture the actual end of duty, including remaining work, rather than simply the truck's arrival at the gate.

A time card changes recordkeeping, not every operating limit. FMCSA's driver guide says qualifying property drivers remain limited to 11 hours of driving. Section 395.3 retains the applicable 60-hour-in-seven-days or 70-hour-in-eight-days limit and provides a 30-minute driving-break exception for drivers qualifying under 395.1(e)(1). Editorial inference: dispatch therefore needs driving and cumulative-duty availability alongside the planned return. A payroll total by itself cannot answer every question about whether the next assignment fits. Fourteen hours to complete the short-haul duty period does not mean fourteen hours of driving are available. When the driver cannot meet the exception's terms, FMCSA's guide says to complete a record of duty status for that day as soon as the exception no longer applies. The record is for the duty day, not merely the part of the route beyond the radius or the final late hour. Editorial inference: preserve the reporting time and the sequence of work and driving as the day unfolds, so the driver can create an accurate full-day record if a delay changes eligibility. Completing a log records what happened; it does not authorize driving beyond an applicable limit.

Industry sponsor From the road to the back office, keep every handoff visible. Take a closer look ↗

Then ask a separate equipment question. Section 395.8 allows manual duty-status records when the operation requires a log on no more than eight days in any 30-day period. FMCSA explains that this period rolls across month boundaries; it is not a fresh allowance every first of the month. Its short-haul fact sheet says eight or fewer log-required days permit paper logs or an ELD, while more than eight generally require an ELD for that log-required day. Another valid ELD exception can change the answer. Count days requiring logs, rather than deliveries, out-of-radius stops, or all days worked.

Consider a hypothetical driver with eight log-required days still inside the rolling window. An additional assignment that makes today's duty day ineligible for short-haul treatment can become the ninth log-required day. Editorial inference: safety and dispatch should check that count before accepting a foreseeable extra stop, so a driver is not sent out with an unsuitable recording plan. On another day that genuinely meets the short-haul conditions, the short-haul recordkeeping exception remains available. The rolling count does not turn every qualifying local day into an ELD day. Conversely, calling today local cannot erase a day that actually required a log.

Unforeseen changes also deserve a break check. FMCSA's published guidance addresses a driver who unexpectedly becomes unable to use a short-haul exception after eight or more hours have passed without the required break. It directs the driver to explain in the duty-status record why the break was not taken earlier and take it at the earliest safe opportunity. The current general property-carrier break rule is based on eight cumulative hours of driving without a qualifying 30-minute interruption. Do not treat the unforeseen-change guidance as a planned permission to omit breaks on assignments known to exceed short-haul conditions.

A practical handoff can be brief. Editorial inference: before departure, identify the normal reporting location, check the proposed stops against the radius, confirm the actual release can fit, and review both available hours and the rolling log-day count. During the shift, give the driver one contact for a changed stop or delay and preserve enough detail for accurate records. At closeout, compare actual release and operating locations with the plan, keep the complete time record or required log, and update the count. The value of that loop is that tomorrow's assignment begins with evidence from today, rather than an assumption that a familiar route will always qualify.