The Federal Motor Carrier Safety Administration (FMCSA) requires all commercial motor vehicle (CMV) drivers to maintain logs, called Record of Duty Status (RODS), to show when the driver is on the clock, driving, not driving, sleeping in a truck's sleeper berth, and when the driver is off the clock. The goal is to prevent tired truck drivers from getting behind the wheel. But do these rules apply to every commercial truck driver?
No. Under certain conditions, some commercial drivers are exempt from the requirement to track their time behind the wheel (hours of service).
These exemptions mostly stem from the fact that FMCSA, has no authority to regulate trucks that do not engage in interstate commerce. Every single US state has the full rights and authority to govern all transportation of commerce that occurs within its borders (so long as they don't intrude on the federal government's regulation of interstate commerce).
If a driver stays within a 150 air-mile radius (distance measured in a straight line) of their work location, the driver ends their shift at the same location, and the driver does not exceed the 14-hour shift limit, they are exempt from completing a log. This is most often used by drivers who complete daily deliveries or only travel short distances.
But wait a minute, what about states that are larger than 150 air miles? The federal government has essentially decided that once a truck travels farther than 150 miles as the crow flies, then it impacts interstate commerce and is therefore subject to federal regulation.
Here's a quick example: Let's imagine a UPS driver named Bob clocks in and out at the same warehouse every day. He arrives to work, clocks in, loads the 18-wheeler up for the day, drives to several retail stores where he drops boxes off at each location, and then finally returns back to the warehouse with an empty truck. Bob's shift was a total of 11 hours and he stayed within the required 150-mile radius. He is one of the commercial truck drivers exempt from filling out his RODS.
8-Day Record of Duty Status Exemption
Truck drivers who maintain a Record of Duty Status (RODS) for less than 8 days during a 30-day period are exempt.
Basically, if a driver normally stays within the 150-air-mile radius and doesn't work shifts longer than 14 hours, when they make an occasional trip that would normally require them to complete their RODS, they don't have to. Additionally, if a truck driver only works 7 days during a whole month, even if these 7 days are for long routes, then they are also exempt from completing their RODS.
Let's go back to our UPS driver, Bob. He normally runs the same route dropping off loads at retail stores, but every once in a while a store that is outside of his warehouse's 150-air-mile radius that he is dispatched to. Bob still does not have to complete RODS. He still clocks in and out at the same warehouse, the shift is only a total of 13 hours, and he only makes that trip once or twice a week.
If a trucker never works longer than 14 hours each day then the driver is automatically following the HOS Rule, so a report is unnecessary. If a trucker only drives farther than 150 miles as the crow files, less than 8 days every month, then it stands to reason that they are not overextended or exhausted for those few trips.
In short, FMCSA essentially recognized that some drivers are simply not part of the issue.
The drivers that are not at risk of being fatigued and/or the drivers that are automatically adhering to the HOS Rule do not have to complete a log book showing that they follow the rules designed to keep fatigued drivers off the road.