The short-haul exception can replace the driver's daily RODS/ELD record with qualifying time records only when every condition of the applicable exception is met. “Local” work or returning home most nights is not enough by itself.
What this means for your fleet
Track the operating radius, reporting location, start and release time, and exception eligibility for each day. Define what happens on a day that exceeds a limit and how the fleet counts non-qualifying days.
Federal short-haul conditions to test for the day
The short-haul exception in 49 CFR 395.1(e)(1) includes operating within a 150 air-mile radius, returning to the normal work-reporting location and being released from work within 14 consecutive hours, and keeping the required time records. Check every condition of that provision, including rest requirements and any applicable driver-salesperson exception. Other short-haul provisions have different conditions. If a day does not qualify, determine the required RODS method and whether a separate ELD exception applies.
What to check
| Check | How to verify |
|---|---|
| 1. Identify the exact short-haul provision | Cite the exact current short-haul provision and retain driver/carrier type, normal reporting location, operation, reviewer, and dated scope decision. |
| 2. Record reporting location and time | Keep each day's reporting location, start/release times, total on-duty time, driver, vehicle, source time records, and exceptions. |
| 3. Monitor radius and duty window | Record route points and air-mile calculation, duty window, return result, limit breach alert, reviewer, and day-level pass/fail result. |
| 4. Switch recordkeeping when a day does not qualify | Practice a scenario in which a short-haul condition is not met. Record how the fleet detects it, selects the required RODS or ELD method, reviews the day, and adjusts dispatch instructions. |
| 5. Retain the required time records | Keep each driver’s start time, end time, and total hours by date for at least the required six-month period. Assign a record owner, test retrieval, and review any additional retention duties or holds before deletion. |
Common failure modes
- Calling every city route short haul.
- Failing to detect a limit breach.
- Assuming an ELD exception removes HOS obligations.
Limits and exceptions
Use this guide to plan your checks; it does not determine whether a legal exception applies, certify a record, or guarantee compliance, safety, savings, or audit results. Preserve original ELD records and edit history. Use the current rules to determine applicability and the manual for your installed device for operating instructions.
Sources and review date
Reviewed August 10, 2026. Check the latest rules and product information before changing your procedures or signing a contract.
- 49 CFR Part 395: hours of service and ELD requirements — Office of the Federal Register and U.S. Government Publishing Office.
- Official ELD exceptions and exemptions FAQ — Federal Motor Carrier Safety Administration.
- Factor ELD products, plans, and support — Factor ELD.
Discuss your ELD workflow
Ask Factor ELD to demonstrate the workflow on your installed system. Have the driver, vehicle, trip details, and original ELD record ready. A qualified compliance reviewer should determine how the current rules apply to the trip.