Short-Haul Exemption Guide

Who This Applies To

• Drivers who operate within a limited radius from their home base every day and want to confirm they qualify for the short-haul exemption from HOS logging requirements.
• Carriers whose local and regional drivers may qualify for the short-haul exemption and want to confirm the conditions before eliminating ELD requirements for those drivers.
• Drivers who previously qualified for the short-haul exemption and want to confirm continued eligibility after a route or schedule change.
• Compliance managers reviewing driver records for drivers claiming short-haul exempt status.

What To Verify

• The current conditions for the short-haul exemption under 49 CFR Part 395. The driver must return to the normal work reporting location within 14 hours, operate within a 150 air-mile radius of the reporting location, and not drive more than 11 hours. All three conditions must be met on every day the exemption is claimed.
• That a driver who uses the short-haul exemption is not required to maintain a daily log (RODS) or use an ELD on days the exemption applies. However, the carrier must maintain time records for short-haul exempt drivers showing time on duty and time off duty.
• That the short-haul exemption is a per-day exemption — not a per-driver designation. A driver who qualifies on most days but exceeds the 150 air-mile radius or 14-hour limit on a specific day must comply with full HOS logging requirements for that day.
• Whether the 30-minute rest break requirement applies to short-haul exempt drivers. Check the current eCFR Part 395 text for the interaction between the short-haul exemption and the 30-minute break rule.

Step-by-Step Overview

1. Confirm the driver's home base (normal work reporting location) and the operating radius for the routes being driven. A 150 air-mile radius is approximately 172 road miles but must be measured as the crow flies — not by road distance.
2. Confirm the driver can return to the reporting location within 14 hours of going on duty every day the exemption is claimed.
3. Confirm the driver does not exceed 11 hours of driving time on any day the exemption is claimed.
4. Maintain time records for short-haul exempt drivers even though full RODS are not required. These records must show on-duty and off-duty times and are subject to FMCSA inspection.
5. If any of the three conditions (radius, return time, or driving time) are exceeded on a given day, apply full HOS logging requirements for that day.

Common Mistakes

• Treating the short-haul exemption as a driver-level designation rather than a per-day qualification. A driver who qualifies most days but occasionally exceeds the radius or 14-hour limit must log on those days.
• Measuring the 150 air-mile radius by road distance. The radius is measured as the straight-line (air) distance from the reporting location — a driver who travels 160 road miles but stays within 150 air miles may still qualify, but a driver who exceeds 150 air miles does not.
• Not maintaining time records for short-haul exempt drivers. The exemption eliminates the daily log requirement, not all recordkeeping. The carrier must still maintain records of on-duty and off-duty times.
• Extending the exemption to a day where the driver returned to base 15 hours after going on duty. Returning after the 14-hour limit voids the exemption for that day — full logging is required.