Short-Haul Hours of Service Rules Explained for Fleets

For many local and regional fleets, the short-haul exemption is one of the most useful Hours of Service (HOS) tools in the FMCSA rules. But it is also widely misunderstood. The exemption does not let drivers ignore HOS limits; it mainly changes how hours are recorded and removes a few requirements when specific conditions are met. For small fleets, understanding that distinction is the key to avoiding preventable violations.

What the short-haul exemption actually does

Under 49 CFR 395.1(e)(1), qualifying property-carrying CDL drivers can use the short-haul exception if they meet the required operating conditions. When they qualify, they are generally exempt from:

• Preparing a standard record of duty status (RODS) under 49 CFR 395.8
• Using an ELD, unless they exceed the exception often enough to trigger the ELD rule
• Taking the standard 30-minute break requirement that otherwise applies under 49 CFR 395.3(a)

What the exemption does not do is waive the basic HOS safety limits. Short-haul drivers still have to comply with:

• The 11-hour driving limit
• The 14-hour duty window
• The 10 consecutive hours off duty requirement
• The 60/70-hour limit in 49 CFR 395.3(b)

Short-haul exemption at a glance

The key rules for property-carrying short-haul drivers

1. The 150 air-mile radius matters

To use the exemption, the driver must operate within a 150 air-mile radius of the normal work reporting location under 49 CFR 395.1(e)(1). An air mile is a straight-line measurement, not route miles on a road map.

That means:

• 150 air miles = about 172.6 statute miles
• Dispatch should not assume a 150-mile route radius is compliant
• GPS route miles and air-mile radius are not the same thing

This is one of the most common fleet errors. A driver can be “local” in practical terms and still go beyond the allowed air-mile radius.

2. The driver must return to the same reporting location

The driver must return to the normal work reporting location and be released from duty there. If a driver starts at one terminal and ends at a different location, the short-haul exception may not apply.

For small fleets with yard moves, drop lots, and customer-site parking, this point deserves extra attention. The rule is built around a normal reporting location, not just “some company location.”

3. The 14-hour window still applies

The short-haul exception requires the driver to be released from duty within 14 consecutive hours after coming on duty. This mirrors the core property-carrying HOS framework in 49 CFR 395.3(a).

Important nuance:

• If a short-haul driver works past 14 hours, they do not get extra flexibility
• Instead, they generally lose the exception for that day and must complete a log
• If they also drove after the 14th hour, that may be an actual HOS violation, not just a recordkeeping issue

4. The 11-hour driving limit still applies

A short-haul driver may not drive more than 11 hours after 10 consecutive hours off duty under 49 CFR 395.3(a).

This is where fleets sometimes get tripped up. A driver can qualify for the short-haul exception from a logging standpoint and still violate the 11-hour rule operationally. The exemption is not permission to drive longer.

5. The 60/70-hour rule still applies

Short-haul drivers are still subject to the cumulative limits in 49 CFR 395.3(b):

• 60 hours in 7 days, if the carrier does not operate every day of the week
• 70 hours in 8 days, if the carrier operates every day of the week

Because short-haul drivers often do not maintain standard logs, carriers must still have a reliable way to total on-duty time across the week. This is where timekeeping discipline becomes essential.

What records the carrier must keep

Even when a driver is exempt from RODS, the motor carrier still has recordkeeping obligations under 49 CFR 395.1(e)(1). The carrier should maintain accurate time records showing, at minimum:

• The time the driver reports for duty
• The time the driver is released from duty
• The total hours worked each day
• The total time for the previous 7 days for drivers used for the first time or intermittently

These records generally must be retained for 6 months. In practice, that means a short-haul fleet still needs dependable daily time tracking. If a DOT auditor asks how you know a driver stayed under the 60/70-hour rule, “we don’t use logs” is not a valid answer.

When a driver loses the short-haul exemption

A driver typically loses the exemption for any day when they:

• Travel beyond the 150 air-mile radius
• Do not return to the normal work reporting location
• Are not released within 14 consecutive hours

When that happens, the driver generally must complete a RODS for that day. If this happens often enough, the ELD rule becomes important. Under 49 CFR 395.8(a)(1)(iii)(A), a driver who must keep RODS for more than 8 days in any 30-day period is generally required to use an ELD, unless another exemption applies.

A practical way to think about it:

• Miss the short-haul conditions once in a while: log that day
• Miss them regularly: you may need an ELD
• Exceed 11 driving hours or 60/70 hours: that is a potential HOS violation, whether logged or not

Common short-haul mistakes small fleets make

Confusing route miles with air miles

This is the classic mistake. Drivers may stay within 150 road miles but exceed 150 air miles, or the reverse. Dispatchers should understand the difference and use mapping tools that can verify the radius correctly.

Assuming “no log” means “no tracking”

Short-haul fleets still need to track:

• Start time
• End time
• Total on-duty time
• Rolling weekly totals

If you cannot prove compliance, FMCSA may treat that as a recordkeeping problem even if the operation itself was lawful.

Mixing up the short-haul exemption and the 16-hour exception

The 16-hour exception in 49 CFR 395.1(o) is a separate rule. It is not the same as the short-haul exemption, and it has its own eligibility requirements. Fleets should not assume that because a driver is short-haul, they can automatically extend every day to 16 hours.

Forgetting about state intrastate rules

This article focuses on the federal HOS framework. Some states have different or modified intrastate short-haul rules. If your fleet operates only intrastate, confirm whether state rules differ from the federal standard.

Best practices for staying compliant

For small fleets, the safest approach is to build simple processes around the exception:

• Document the normal work reporting location for each driver
• Track on-duty start and end times every day
• Monitor the 150 air-mile radius before dispatch
• Review weekly cumulative hours
• Flag days when a driver loses the exception
• Train dispatch and payroll staff, not just drivers, on short-haul conditions

The biggest compliance wins usually come from operations and office staff understanding the rule the same way the driver does.

Frequently Asked Questions

Do short-haul drivers need an ELD?

Not usually, if they fully qualify for the short-haul exception under 49 CFR 395.1(e)(1). But if they must keep RODS on more than 8 days in any 30-day period, they generally become subject to the ELD requirement under 49 CFR 395.8(a)(1)(iii)(A).

Does the 30-minute break apply to short-haul drivers?

If the driver is operating under the short-haul exception, the standard 30-minute break requirement does not apply. However, if the driver loses the exception for that day, the fleet should evaluate whether the normal HOS requirements apply.

What happens if a driver goes beyond the 150 air-mile radius one day?

That driver generally cannot use the short-haul exception for that day and should prepare a RODS. One occasional day outside the radius does not automatically mean the fleet needs ELDs, but repeated occurrences may.

Can a short-haul driver work more than 14 hours if they stay local?

No. The short-haul exception requires the driver to return to the reporting location and be released within 14 consecutive hours. Staying local does not remove that limit.

Simplify Your Compliance with HaulComply

Short-haul operations are simpler than long-haul, but they still require consistent time tracking, weekly hour monitoring, and exception management. HaulComply helps small fleets stay organized with practical DOT compliance tools built for everyday operations. Start with a 7-day free trial to see how much easier short-haul HOS tracking can be.