A route can stay close to the terminal and still fail the federal short-haul exception. Calling a driver local does not establish which records the carrier is allowed to use.

For dispatchers and small fleets, the useful question is whether the actual workday meets the conditions, and whether the office can show it afterward.

This guide covers property-carrying CDL operations using 49 CFR 395.1(e)(1). It explains existing federal requirements checked October 21, 2026, rather than announcing a new rule. Intrastate operations and specialized exceptions need their own review.

Check the radius, the return and the release

The standard exception uses a 150 air-mile radius around the normal work-reporting location. That is about 172.6 statute miles measured as a radius, not the total miles on the odometer or a 150-road-mile trip allowance.

For the ordinary property-carrier operation covered here, the driver must return to that reporting location and be released from work within 14 consecutive hours. Returning the truck while the driver continues working does not finish that test. Property-carrying drivers also need the required 10 consecutive hours off between shifts. The regulation contains a driver-salesperson qualification; do not assume this general dispatch example resolves that specialized situation.

FMCSA's HOS summary describes the radius and return conditions. Dispatch should check both before assigning an extra stop, rather than assuming a familiar route always qualifies.

A timecard still needs the right information

The carrier must keep accurate time records for six months. Those records need the daily reporting time, release time and total on-duty hours. For drivers used for the first time or intermittently, section 395.8(j)(2) also requires a signed statement giving total on-duty time during the preceding seven days and when the driver was last relieved from duty before starting work for the carrier.

A payroll entry showing only eight paid hours may not establish when duty began and ended. Conversely, a properly designed timekeeping system can serve the office better than a folder labeled local drivers that nobody checks. The required information matters more than the software brand.

No log does not mean no hours limit

The exception removes the section 395.8 record-of-duty-status and section 395.11 supporting-document requirements when all its conditions are met. It does not give a driver 14 hours of driving.

Under section 395.3, the ordinary property-carrier driving limit remains 11 hours following 10 consecutive hours off. The applicable weekly limit also remains: no driving after 60 on-duty hours in seven days, or 70 in eight days, depending on the carrier's operating schedule. Qualifying short-haul drivers are excepted from that section's 30-minute driving-break requirement.

Non-CDL short-haul operations have a separate provision in section 395.1(e)(2), including different duty-window conditions. Do not mix its provisions into an (e)(1) policy.

Plan for the day that stops qualifying

FMCSA's Safety Planner says drivers must meet every qualification to use a short-haul exception. If a condition is missed, the standard rules apply unless another applicable exception covers the operation.

That means the carrier needs a plan for records of duty status when a day no longer qualifies. Whether an ELD is required involves separate ELD rules and exceptions; a missed short-haul condition alone is not a complete ELD determination.

Our recommended office check is simple: review reporting location, planned radius, duty start, expected release and available driving time before dispatch. Afterward, reconcile the actual return and release with the time record. These are recommended controls, not additional forms mandated by this guide.

Keep this review separate from the annual driver-file review; one does not replace the other. For help organizing a carrier's compliance process, review DOT Consulting Solutions' services, call (910) 915-8804, or email info@dotconsultingsolutions.com.

Photo: Lance Cheung / USDA, UPS feeder driver and tractor in Arlington, Texas, August 14, 2020. Public-domain federal photograph; resized and converted to WebP. Archival industry context, not a finding about the driver's hours or a DOTCS client.

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