Do limo drivers need to be logging hours of service?

log book

Hours of Service (HOS), or keeping a log book, is a simple concept with a set of complex regulations. The goal is to ensure only safe, well-rested drivers are on the road. From a business standpoint, one must maximize driver utilization while maintaining complete compliance and reducing liability.

Who needs to comply with HOS regulations?

The FMCSA states that HOS regulations apply to any driver who:

• Is engaged in interstate commerce (picking up at the airport, or performing affiliate work from an out of state company)
• Using a vehicle designed or used to carry 9 passengers (including the driver)
• For compensation (directly or indirectly)

http://www.fmcsa.dot.gov/regulations/hours-of-service

This means, CDL and non-CDL drivers operating stretch limousines, vans, and mini buses must maintain HOS records when they are engaging in interstate commerce.

What are the HOS regulations?

There are three primary rules that passenger carriers must comply with.

The first is the 15 hour on-duty limit. No driver shall drive after having been on-duty for 15 hours following 8 consecutive hours off duty.

Examples of on-duty time:

• Pre-trip and post-trip inspections
• Substance abuse testing
• Time resting in a parked vehicle
• Repairing or waiting with a disabled vehicle
• Working for another employer
• Driving company vehicles

The second is the 10-hour driving limit. This rule limits the direct number of hours that a driver can spend behind the wheel operating a commercial motor vehicle. No driver may drive for more than 10 hours following 8 consecutive hours off.

• Driving time means all time spent at the driving controls of a commercial motor vehicle in operation.
• Time spent driving sedans and SUVs will likely qualify as on-duty but not driving dependent upon your fleet.

The third rule is the 60/70 hour limit. If you operate commercial motor vehicles seven days a week you can forget about the 60 in the 60/70 hour rule. The 70 represents a maximum of 70 hours that drivers can work in any consecutive 8 day period. This is a floating 8 day cycle with the 8th day dropping off as new days are added.

How do I maintain compliance?

There are two primary ways to collect and maintain HOS records, keeping a traditional log book or the 100 air-mile exemption.

100 AIR-MILE EXEMPTION

The 100 air-mile exemption requires that the driver:

• Starts and ends their day at the same location
• Does not exceed 100 air-miles from the office
• Does not exceed 12 consecutive hours on-duty
• Does not exceed 10 hours of drive time

If a driver qualifies and you wish to use the 100 air-mile exemption the employer must maintain records for six months showing:

• The time the driver started
• The time the driver ended
• Total hours worked

TRADITIONAL LOG BOOK

Keeping a traditional log book provides both pros and cons to consider:

PROS:
• Allows 15 hours non-consecutive on-duty time
• Allows an expanded range
• Allows for different start and stop sites
• Maximizes driver utilization

CONS:
• Time intensive paperwork
• Chance of form and manner violations

With a shortage of CDL drivers and the heavy downtime in the limo & bus industry, most companies will find keeping a traditional log book as the right choice. Doing so will allow better utilization of drivers while maintaining complete legal compliance.

Why should I care about HOS regulations?

The FMCSA holds the carrier responsible for violations as well as the driver.

Possible consequences of non-compliance include:

• The driver being placed out-of-service mid-run
• Lower CSA Scores
• Fines from $1,000-11,000 per infraction
• A downgraded safety rating
• Criminal charges against owners and management

Compliance can be simple, check out dotbuscompliance.com for more info.

For information on electronic log book option go to limologs.com

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