Separate the invoice from the driver record
A carrier may describe a period as detention for billing purposes. That label does not decide whether the driver is on duty, off duty or in the sleeper berth. Start with the facts about what the driver was required to do.
The definition of on-duty time in 49 CFR 395.2 addresses waiting, loading, unloading, readiness to operate and relief from work. Review the relevant conditions and exceptions rather than marking every stationary interval off duty.
Document a waiting interval
| Situation to examine | Fact to establish |
|---|---|
| Driver helps load or watches loading | What work or attendance is required? |
| Driver waits for a door assignment | Is the driver required to remain ready to work, or actually relieved? |
| Driver is relieved and rests | When did relief start, and what responsibilities remain? |
| Truck must move during the delay | Who moves it, when, and under which applicable recording procedure? |
| Loading resumes | When does the driver return to work? |
This worksheet gathers the evidence for a status decision; it does not assign a universal status to each row. A single visit may contain several different activities. Preserve the actual sequence instead of assigning one convenient label to the entire delay.
Do not confuse a driving interruption with off-duty time
For drivers subject to the federal property-carrier 30-minute interruption requirement, qualifying non-driving time can include on-duty not driving. That does not turn working time into off-duty time or automatically stop the duty window. See 395.3 and review the applicable rule configuration.
If the delay disrupts the next appointment, notify dispatch using the carrier’s process. Retain the arrival, changes in activity and departure information for the log review; keep detention-billing evidence in its proper business record. 30-Minute Break Rules and ELD Records. HOS with ELD: A Daily Planning Guide.
Detention questions
Does paid detention always mean on-duty time?
The billing label alone does not decide the status. Review actual duties and whether the driver was relieved from work under the applicable definition.
Can a receiver’s delay automatically extend the driving limit?
Do not assume an extension. The carrier must assess any claimed exception against its actual conditions; waiting for a customer is not a general permission to exceed a limit.