HOS Short-Haul Exemption: 150 Air-Mile Radius Rules Explained
The short-haul exemption is one of the most valuable provisions in the Hours of Service regulations for local and regional drivers. It eliminates the need for Records of Duty Status and ELD requirements entirely, replacing them with a simple time card. But the rules have specific boundaries, and exceeding them even once has consequences. This guide breaks down every aspect of the CDL and non-CDL short-haul exemptions so you know exactly where you stand.
150 Air Miles
CDL Radius Limit
14 Hours
CDL Window
16 Hours
Non-CDL Window
8 in 30
Days Before ELD Required
O Trucking Editorial Team
Trucking Industry Experts
Fact-Checked by O Trucking Compliance Team
5+ years helping local and regional carriers understand short-haul exemption rules
This article was written by the O Trucking editorial team with 9+ years of combined trucking industry experience. Learn more about us.
O TruckingHOS Short-Haul Exemption
What Is the Short-Haul Exemption?
The short-haul exemption under 49 CFR 395.1(e) is a provision that allows drivers who operate within a defined radius of their work reporting location to use a simplified timekeeping method instead of maintaining full Records of Duty Status. Instead of logging every duty status change on an ELD or paper log, qualifying short-haul drivers simply record their start time, end time, and total hours on a time card.
The exemption exists because the complexity of full RODS tracking is unnecessary for drivers who start and end each day at the same location and operate within a limited geographic area. Local delivery drivers, construction haulers, and regional LTL drivers are the most common beneficiaries of this exemption.
There are two versions of the short-haul exemption: one for CDL drivers and one for non-CDL drivers. The 2020 HOS Final Rule expanded the CDL short-haul window from 12 hours to 14 hours, making the exemption significantly more practical for a larger number of drivers.
The 2020 Rule Made Short-Haul More Practical
CDL Short-Haul Exemption (150 Air-Mile Radius)
The CDL short-haul exemption under 49 CFR 395.1(e)(1) applies to drivers who hold a Commercial Driver's License and operate commercial motor vehicles. To qualify, you must meet all four conditions every day:
Operate within 150 air miles of your work reporting location
Every point on your route must be within 150 air miles (approximately 172.6 statute miles) of the location where you report for duty. If any stop on your route takes you beyond this radius, you lose the exemption for that day.
Return to your work reporting location within 14 hours
From the time you come on duty to the time you return to your reporting location and are released, no more than 14 consecutive hours may pass. This is not 14 hours of driving; it is 14 hours from start to finish including all on-duty, driving, and waiting time.
Start and end at the same work reporting location
You must report to and return to the same normal work reporting location each day. This is typically a terminal, yard, or office designated by the carrier. You cannot start at one location and end at another.
Do not drive after the 14th hour
You cannot operate a CMV after 14 hours have elapsed from the time you came on duty. The standard 11-hour driving limit within those 14 hours still applies, as does the 30-minute break requirement after 8 hours of driving.
Non-CDL Short-Haul Exemption (16-Hour Window)
Non-CDL drivers operating CMVs with a gross vehicle weight rating (GVWR) between 10,001 and 26,000 pounds have a separate short-haul exemption under 49 CFR 395.1(e)(2). The key difference is a longer on-duty window:
| Requirement | CDL Short-Haul | Non-CDL Short-Haul |
|---|---|---|
| Air-mile radius | 150 air miles | 150 air miles |
| On-duty window | 14 hours | 16 hours |
| Max driving time | 11 hours | 11 hours |
| Return to reporting location | Required | Required |
| ELD required | No (if qualifying) | No (if qualifying) |
| Record keeping | Time card | Time card |
The 16-hour window for non-CDL drivers was established by the 2020 HOS Final Rule. Previously, non-CDL short-haul drivers had the same 14-hour window as CDL drivers. The expanded window acknowledges that non-CDL short-haul operations, such as box truck deliveries and local hauling, often involve longer days with significant non-driving time.
Time Card Exception vs Full RODS
The most practical benefit of the short-haul exemption is the time card exception. Instead of maintaining a complete Record of Duty Status that tracks every status change throughout the day, qualifying short-haul drivers only need to record:
Time Card Requirements
- Date of each day worked
- Total on-duty hours for the day
- Time the driver reports for duty
- Time the driver is released from duty
- Total hours worked for the preceding 7 days (for drivers used for the first time or intermittently)
The time card does not require a graph grid, does not need to track individual duty status changes, and does not need to record locations. This dramatically reduces the administrative burden for both drivers and carriers. The carrier must retain these time cards for a minimum of 6 months.
Keep Time Cards Accurate
ELD Exemption for Short-Haul Drivers
One of the most significant benefits of qualifying for the short-haul exemption is that you are also exempt from the ELD mandate. Short-haul drivers who consistently meet the exemption criteria do not need to purchase, install, or maintain an Electronic Logging Device. This saves owner-operators and small carriers the cost of the device ($200-$800), monthly subscription fees ($15-$40/month), and the time spent managing ELD compliance.
However, the ELD exemption is not unconditional. If you exceed the short-haul parameters more than 8 days in any 30-day rolling period, you lose the ELD exemption and must install an ELD. This is where the 8-in-30 day rule becomes critical for drivers who occasionally operate outside the short-haul boundaries.
ELD Exemption Is Not the Same as HOS Exemption
When You Lose the Short-Haul Exemption
You lose the short-haul exemption for any day when you exceed any one of the qualifying conditions. The triggers are:
Exceeding the 150 air-mile radius
If any point on your route falls outside the 150 air-mile radius from your reporting location, you do not qualify for the exemption that day. You must complete full RODS for the entire 24-hour period, not just the portion outside the radius.
Exceeding the time window (14 or 16 hours)
If more than 14 hours (CDL) or 16 hours (non-CDL) pass between when you come on duty and when you return to and are released at your reporting location, you lose the exemption for that day. Even 14 hours and 1 minute triggers the requirement for full RODS.
Not returning to your work reporting location
If you end your day at a location other than where you reported for duty, you do not qualify for the short-haul exemption. This commonly happens when a driver is asked to park the truck at a job site overnight instead of returning to the terminal.
On any day you lose the exemption, you must prepare a full Record of Duty Status for that entire 24-hour period. This means you need paper log forms or a backup ELD ready for those occasions, even if you normally operate under the time card exception. Carriers should ensure short-haul drivers carry blank RODS forms for this purpose, as covered in our ELD exemptions guide.
The 8-in-30 Day Rule Explained
The 8-in-30 day rule is the mechanism that determines when a short-haul driver permanently loses their ELD exemption. Here is how it works:
How the 8-in-30 Rule Works
The count: FMCSA tracks how many days within any rolling 30-day period you exceed the short-haul parameters. Each day you go beyond 150 air miles, exceed the time window, or fail to return to your reporting location counts as one day toward the limit.
The threshold: If you exceed the short-haul parameters more than 8 days in any 30-day rolling period, you lose the ELD exemption and must install an ELD.
The reset: To regain the ELD exemption after losing it, you must complete 30 consecutive days without exceeding the short-haul parameters. Only after that 30-day clean period is the exemption restored.
Practical impact: If you occasionally take a longer run or get stuck at a delivery beyond 14 hours, that is fine as long as it does not happen more than 8 times in 30 days. But if your operation regularly pushes the boundaries, you may need an ELD as a permanent part of your compliance program.
Track Your Exceptions
How to Calculate Air Miles vs Road Miles
The 150 air-mile radius is measured as a straight line distance from your work reporting location, not as road miles driven. This distinction matters because road miles are always greater than air miles due to the curves and routing of actual roads. Understanding the conversion prevents you from accidentally exceeding the radius.
Air Mile Conversion
1 air mile = 1.15 statute miles (approximately)
150 air miles = approximately 172.6 statute miles (straight line)
Actual road miles for 150 air miles: Typically 175-215 road miles depending on routing, road curvature, and terrain. In flat areas with straight highways, road miles are closer to the air mile equivalent. In mountainous or winding terrain, road miles can be significantly more.
To check whether a specific destination is within 150 air miles of your reporting location, use any online great-circle distance calculator. Enter your reporting location and the destination, and the tool will return the straight-line distance. If it shows less than 150 nautical miles or 172.6 statute miles, you are within the radius. Many GPS and fleet management systems can also display air-mile distances.
100 Air-Mile vs 150 Air-Mile Radius
How Our Team Researched This Guide
This guide is based on the regulatory text of 49 CFR 395.1(e), the FMCSA 2020 HOS Final Rule summary and preamble, and FMCSA driver information resources. Our compliance team has helped dozens of local carriers determine whether their operations qualify for the short-haul exemption and has assisted with proper time card documentation and 8-in-30 tracking. The practical guidance in this article reflects patterns we see in real carrier operations.
How O Trucking LLC Helps Short-Haul Carriers
Whether you qualify for the short-haul exemption or need to transition to full ELD compliance, our team can help you navigate the rules efficiently.
Exemption Qualification Assessment
We review your typical routes, delivery patterns, and daily schedules to determine whether your operation consistently qualifies for the short-haul exemption. For carriers on the borderline, we help identify which routes push you outside the 150 air-mile radius and recommend adjustments that might keep you within the exemption boundaries.
8-in-30 Tracking
For carriers who occasionally exceed the short-haul parameters, we track your exception days against the 30-day rolling window. You will know well in advance if you are approaching the 8-day threshold, giving you time to adjust operations before losing the ELD exemption. This proactive tracking prevents surprise compliance requirements.
Load Planning Within the Radius
Our dispatch team understands the short-haul boundaries and plans loads that keep qualifying drivers within the 150 air-mile radius and 14-hour window. When a load would push a driver outside the exemption parameters, we flag it so the driver can make an informed decision about whether to take it and prepare the appropriate RODS documentation.
Frequently Asked Questions
What is the 150 air-mile radius?
The 150 air-mile radius is the geographic boundary for the CDL short-haul exemption. An air mile equals approximately 1.15 statute miles, so 150 air miles translates to roughly 172.6 statute miles measured as a straight line from your work reporting location. As long as every point on your route stays within this radius and you meet the other conditions (return within 14 hours, same start/end location), you qualify for the simplified time card recordkeeping instead of full RODS.
Do short-haul drivers need an ELD?
No, as long as they consistently qualify for the short-haul exemption. Qualifying drivers use time cards instead of ELDs or RODS. However, if you exceed the short-haul parameters more than 8 days in any rolling 30-day period, you lose the ELD exemption and must install an ELD. For more on ELD exemptions, see our ELD exemptions guide.
What happens if I exceed the 150 air-mile radius?
On any day you exceed the 150 air-mile radius, you must prepare a full Record of Duty Status for the entire 24-hour period. You need paper RODS or an ELD for that day. Additionally, each day you exceed the limits counts toward the 8-in-30 threshold. If you exceed the limits more than 8 times in 30 days, you must install an ELD and cannot use the short-haul exemption until 30 consecutive qualifying days pass.
What is the 8-in-30 day rule?
The 8-in-30 day rule determines when a short-haul driver loses their ELD exemption. If you exceed the short-haul exemption parameters (go beyond 150 air miles, exceed the time window, or fail to return to your reporting location) more than 8 days in any rolling 30-day period, you must install and use an ELD. To regain the exemption, you must complete 30 consecutive days without any exceptions. This rule affects the ELD requirement specifically, not the general HOS rules which always apply.
Local Operations? We Keep You Compliant
Whether you qualify for the short-haul exemption or need ELD support, our compliance team helps you understand the rules and stay within the boundaries that matter for your operation.