Logs and Non-CDL drivers, What are the options?

Logs and Non-CDL Drivers

If you’re reading this, I’ll assume your goal is to be safe and compliant.  One of the hardest areas for most of our industry clients is the implementation of hours of service tracking (LOGS), for non-CDL drivers who operate vans or limos.


Please do not use the 100 Air-Mile Exception without reading our FAQ Page.


As we’ve covered earlier, any driver operating a van or limo and going to the airport (arrival or departure) must follow most of the same rules as a CDL operating in interstate commerce.  From a practical standpoint, there are three separate implementation strategies to gain compliance.


  • Option 1:  Only use CDL drivers in vans and limos
    • Pros
      • No additional training or pushback
      • No additional cost
      • Fewer logs to audit
    • Cons
      • Shortage of CDLs
      • Reduces dispatch flexibility
  • Option 2:  Create a pool of van/limo eligible non-CDL drivers
    • Pros
      • More dispatching choices
      • Fewer individuals to train
      • Flexibility with hours of service overages in sedans and SUVs
    • Cons
      • More liability than following HOS regulations for all
      • Can create challenges with last minute van/limo runs
      • Moderate dispatch flexibility
      • Additional cost for Med Cards
  • Option 3:  Train and qualify all drivers for all vehicle types that their license allows
    • Pros
      • Most flexibility in vans and limos
      • Safest, least liability
      • Lessens risk of non-compliance
      • Larger sample of correct logs/dq files to offset errors
    • Cons
      • Pushback from drivers
      • Additional training
      • Additional log verification/HOS tracking
      • Additional cost for Med Cards


There is no one size fits all solution, but hopefully this information will help streamline the discussion in your organization.  Next week we will cover best practices for implementation.


Click here for more information on rules concerning HOS 

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