hours of service for fuel delivery drivers: the 150 air-mile short-haul exemption
Most local fuel delivery qualifies for the FMCSA 150 air-mile short-haul exemption, which means your bobtail drivers usually do not need an electronic logging device or paper Records of Duty Status. If a driver starts and ends the day at the terminal, stays within 150 air-miles of it, and is released within 14 hours, a timecard is enough. The drivers who tend to need an ELD are transport haulers running long pulls from a rack that keep them out past that window.
How the short-haul exemption works
The rule lives at 49 CFR 395.1(e)(1). A driver is off the hook for keeping RODS on any day they meet four conditions: they operate within 150 air-miles of the normal work reporting location, they return to that location and are released from duty within 14 consecutive hours, they had at least 10 consecutive hours off before the shift, and they do not drive more than 11 hours. Meet all four and the day needs no log and no ELD. Miss any one of them and that day turns into a full RODS day.
For a jobber, the "normal work reporting location" is almost always the terminal or bulk plant the driver reports to each morning. A driver who loads there, runs local drops, and comes back before hour 14 fits the exemption cleanly. That covers a large share of everyday bobtail delivery.
The four numbers that keep a driver off an ELD
These are the thresholds to watch on any given shift. Cross one and the exemption is gone for that day.
- 150 air-miles. The driver stays within 150 air-miles of the reporting terminal. This limit went up from 100 air-miles in the 2020 FMCSA short-haul rule.
- 14 hours. The driver is released from duty within 14 consecutive hours of coming on duty. This limit also rose, from 12 hours, in the same 2020 change.
- 11 hours driving. No more than 11 hours behind the wheel, the same driving cap that applies to every property-carrying CMV driver.
- 10 hours off. At least 10 consecutive hours off duty before the shift starts.
One bonus of qualifying: short-haul drivers are also excused from the 30-minute break requirement that otherwise kicks in after 8 hours of driving. Long-haul fuel drivers running RODS still owe that break.
Air-miles are not road-miles
An air-mile is a nautical mile, which is about 1.15 statute miles. So 150 air-miles is roughly 172 road-miles in a straight line from the terminal. The measurement is a straight line, not odometer distance, so a driver who winds through 190 miles of two-lane roads can still be well inside the 150 air-mile circle. If you dispatch near the edge, map the straight-line radius from your terminal rather than guessing off the truck's mileage.
The day a driver falls out of the exemption
Say a driver normally runs local, then takes one long transport pull that keeps them out 15 hours or pushes past the 150 air-mile line. They lose the exemption for that single day and must complete a RODS for it. That does not automatically force an ELD. Under the ELD rule, a driver who has to keep RODS on 8 or fewer days in any rolling 30-day period may use paper logs for those days instead of an electronic device.
Cross that 8-day line and the driver needs an ELD in the truck. This is the number that decides the whole ELD-versus-timecard question for a mixed fleet. If a driver blows the short-haul limits nine or more days a month, plan on an ELD for that truck. If it is an occasional long pull, paper logs on those days keep you compliant. Drivers doing mobile and onsite fueling routes that circle back to base each day usually stay comfortably inside the exemption.
The 60- and 70-hour limit still counts
The short-haul exemption gets a driver out of daily logs, but it does not touch the weekly on-duty cap. A driver may not be on duty more than 60 hours in any 7 consecutive days, or 70 hours in any 8 consecutive days if the company runs vehicles every day of the week. That clock includes loading, fueling the truck, waiting, and paperwork, not just driving. A driver can optionally reset the weekly count with 34 or more consecutive hours off duty. For a jobber this matters most during a cold snap or a price run when everyone is pulling long days back-to-back, because the weekly ceiling arrives before anyone notices.
What you keep instead of logs
When a driver runs under the short-haul exemption, the record you keep is a time record for each day showing the time the driver reported for duty, the time released, and the total hours on duty. Keep those records for 6 months. That is your proof at a roadside inspection or a compliance review that the driver qualified, so a scribbled start-and-stop is not enough if it cannot survive an audit.
Sloppy timekeeping is where this bites. A driver who cannot show they were released inside 14 hours can be cited as if they should have been logging all along, and unpaid or mistimed on-duty hours are a quiet way that labor cost and exposure creep up, the same kind of slow drain covered in where fuel margin leaks. If you already run dispatch or delivery software, keeping the on-duty clock in the same system that tracks the loads is cleaner than a separate binder. FastDragon logs driver hours against each ticket for exactly this reason. If you are still building out the operation, the driver-hours question is one to settle early while you are setting up as a jobber.
Questions people ask
Is there a short-haul option for drivers who do not hold a CDL?
Yes. A separate provision at 49 CFR 395.1(e)(2) covers non-CDL short-haul drivers within a 150 air-mile radius, with its own conditions on the 14-hour window and the number of longer days allowed per period. It is common for small delivery trucks that stay local. The CDL and non-CDL versions are not identical, so check which one each driver actually falls under.
Do these federal HOS limits apply if we only run inside one state?
Purely intrastate carriers follow their state's hours-of-service rules, and most states adopt the federal limits or something close to them. Some, including Texas, California, and Florida, have their own intrastate variations on daily and weekly hours. If none of your routes cross a state line, confirm your state's version rather than assuming the federal numbers apply exactly.
Can a driver take the bobtail home at night without it counting as driving time?
Sometimes, under the personal conveyance provision, but only when the movement is truly for the driver's own purpose and the truck is unladen in the way FMCSA allows. Moving a loaded fuel truck toward the next job does not qualify. Personal conveyance rules are easy to misapply, so set a written policy before you let drivers commute in a company truck.
Is there a separate exemption for hauling fuel to farms?
There is an agricultural commodity exemption that suspends HOS limits within a 150 air-mile radius of the source during planting and harvest seasons as defined by each state. Fuel delivered for farm operations can fall under it in some situations. The definitions are specific and state-set, so verify it applies before relying on it for a farm-delivery route.