150 Air-Mile Short-Haul Exemption: Eligibility and Records

A local delivery fleet runs for years without logbooks because every route starts and ends at the same yard. Then sales lands a customer a little further out, dispatch adds the stop on a busy Tuesday, and nobody notices that the route now crosses the radius line. At the next compliance review the carrier has drivers with no record of duty status for days on which they needed one.

The 150 air-mile short-haul exception in 49 CFR 395.1(e)(1) is generous, but it is conditional on every single day. A fleet that measures radius properly, tracks the 14-hour release time, keeps the four required time records for six months and counts exception days per driver can use it safely, and can see in advance when a route change will force a log or an ELD.

• What the guide covers: who qualifies, how air miles are measured, the 14-hour and off-duty conditions, the time records, the non-CDL variant and the days that break the exception.
• Worked material: radius checks from one depot to real cities, a distance formula, a timestamped incident, a cost comparison in US dollars with a rupee view, and an audit checklist.

Who can use the 150 air-mile exception and what it removes

The exception removes the duty to keep a record of duty status and supporting documents; it does not remove the driving limits. Under 395.1(e)(1), a qualifying driver is exempt from 395.8, which covers logs and ELDs, and 395.11, which covers supporting documents. The 11-hour driving limit and the 60-hour or 70-hour weekly limits in 395.3 still apply.

Four conditions must all hold on the day in question. The driver operates within a 150 air-mile radius of the normal work reporting location. The driver returns to that location and is released within 14 consecutive hours. A property-carrying driver has at least 10 consecutive hours off duty between each 14 hours on duty, or 8 hours for a passenger-carrying driver. And the carrier keeps specified time records for six months.

• Driving limits kept: 11 hours of driving within the 14-hour period and the 60-hour/7-day or 70-hour/8-day totals continue to bind short-haul drivers.
• Break rule lifted: 395.3(a)(3)(ii) expressly excludes drivers who qualify for either short-haul exception from the 30-minute break after 8 hours of driving.
• Paperwork lifted: no log, no ELD and no retained bills of lading or dispatch records under 395.11 for qualifying days.
• History: FMCSA's June 2020 final rule, effective 29 September 2020, widened the radius from 100 to 150 air miles and the return window from 12 to 14 hours.

Under 49 CFR 395.1(e)(1), a short-haul driver avoids record of duty status and ELD duties only on days that meet all four conditions: work within a 150 air-mile radius, release within 14 consecutive hours, 10 hours off duty for property carriers, and six months of carrier-kept time records. The 11-hour driving limit still applies.

Measuring 150 air miles from the reporting location, not road miles

The radius is a straight-line distance in nautical miles, not the odometer reading. The regulation itself states 150 air miles as 172.6 statute miles, about 277.8 kilometres. A route can run well over 172 road miles and still qualify if every stop lies inside the circle, and a single stop just outside the circle ends the exception for that day regardless of total mileage.

The centre of the circle is the normal work reporting location, meaning the yard or terminal where the driver reports and is released, not the company's head office. Fleets with several yards need a circle per yard, and drivers who sometimes report to a different yard need the circle of the yard they actually reported to that day. The formula below is what a TMS or a spreadsheet should use.

Great-circle distance in nautical (air) miles, haversine form

  d = 2 * R * asin( sqrt( sin^2((lat2 - lat1) / 2)
                          + cos(lat1) * cos(lat2) * sin^2((lon2 - lon1) / 2) ) )

  lat1, lon1  reporting location, in radians
  lat2, lon2  stop location, in radians
  R           mean Earth radius = 3,440.07 nautical miles (6,371.01 km / 1.852)
  d           distance in air miles; 1 air mile = 1.15078 statute miles

Rule:   stop qualifies if d <= 150.0
Buffer: flag for dispatcher review if d > 145.0 (geocoding error margin)

Applied to a depot in Columbus, Ohio, using city-centre coordinates, the circle produces results that surprise dispatchers. Indianapolis and Detroit fall inside; Louisville falls outside, even though drivers often think of it as the nearer city. Actual stop addresses should always be geocoded, because a customer on the far side of a metro area can sit several miles from the city centre point.

The 14-hour release clock and the off-duty gap between shifts

The 14 hours run from the time the driver reports for duty to the time the driver is released at the reporting location, and nothing pauses them. Lunch, waiting at a customer and an off-duty hour in the middle of the day all count toward the 14. A driver who reports at 05:30 must be back and released by 19:30, not merely parked at the last customer. The separate driving window in 395.3(a)(2), which still applies, is covered in our FMCSA 14-hour rule guide.

Two details catch fleets. First, the 10-hour off-duty minimum for property carriers sits between each 14-hour duty period, so an early report after a late release can break the exception on the following day. Second, the regulation carves driver-salespersons, a defined term in 395.2, out of the return-within-14-hours condition, so a sales route driver's eligibility should be checked against that definition rather than assumed.

• Clock start: the reporting time on the time record, normally the yard clock-in, not the ignition-on time.
• Clock end: the release time at the same reporting location; arriving at the gate and then fuelling for 20 minutes moves the release time.
• Off-duty gap: release at 20:15 means the earliest compliant report the next day is 06:15 for a property-carrying driver.
• Adverse conditions: 395.1(b)(1) allows up to two extra hours of driving or duty time in genuinely unforeseen adverse conditions, but a driver who then fails the 14-hour return needs a record of duty status for that day.

Time records the carrier must keep for six months

The exception replaces the log with a time record that the carrier, not the driver, must keep. Paragraph (e)(1)(iv) requires accurate and true records, kept for six months, of the time the driver reports each day, total on-duty hours each day and the release time, plus the total time for the preceding 7 days for drivers used for the first time or intermittently.

That last item points to 395.8(j)(2), under which a carrier using a driver for the first time or intermittently must obtain a signed statement of the driver's total on-duty time in the previous 7 days and the time the driver was last relieved from duty. Agency drivers and staff borrowed from another depot are where this item is usually missing.

Short-haul time records under 49 CFR 395.1(e)(1)(iv) must show the daily report time, daily on-duty hours, daily release time and, for first-time or intermittent drivers, a 7-day prior total under 395.8(j)(2). Carriers keep them for six months, and payroll clock data usually satisfies three of the four items.

Days that break the exception and the eight-in-30 logging limit

When any condition fails, the driver needs a record of duty status for that day, and the number of such days decides whether paper logs remain an option. Under 395.8(a)(1)(ii)(A)(1), a carrier may let a driver record duty status manually instead of using an ELD if the driver needs a record on no more than 8 days in any 30-day period.

The 30 days roll; they are not a calendar month. A driver who leaves the radius every Tuesday and Friday logs about eight such days in most 30-day windows, but some windows contain nine, and from the ninth day the paper option is gone for that driver. FMCSA's 2020 rule preamble describes exactly this choice: up to 8 days in any 30 on paper, or more with an ELD.

• Radius exceeded: one stop beyond 150 air miles turns the whole day into a logged day, including the hours before the stop.
• Release after 14 hours: a late return converts the day, and the 30-minute break rule also applies to it.
• Short off-duty gap: fewer than 10 consecutive off-duty hours before the shift breaks the exception from the start of the day.
• Counting rule: count logged days per driver over a rolling 30-day window, and alert on day 7 so dispatch can plan around day 9.

Non-CDL drivers under paragraph (e)(2): the 14th and 16th hour rule

Drivers of property-carrying vehicles that do not require a commercial driver's licence have their own short-haul rule with a longer duty day on two days a week. Paragraph (e)(2) applies within the same 150 air-mile radius, requires a return to the reporting location at the end of each duty tour, and lets the driver drive up to the 16th hour after coming on duty on 2 days of any 7 consecutive days.

On the other days the limit is the 14th hour. A driver using (e)(2) is exempt from 395.3(a)(2), 395.8 and 395.11, but the paragraph also makes that driver ineligible for 395.1(e)(1), (g) and (o) on those terms. The same four-part time record applies. Mixed fleets of box trucks and tractor units therefore need a vehicle-class field in the time record, so the right rule is tested for each driver-day.

A Louisville stop that turned a local route into a logged day

The trace below uses illustrative route, driver and order numbers from a Columbus depot. The point is the sequence: the exception was lost at 09:55 when the stop was added, but nobody knew until the following week.

1. Tue 05:40: driver D-117 clocks in at the Columbus yard for route R-2214, six stops, furthest stop Cincinnati at 87 air miles. No log is started, which is correct for a short-haul day.
2. Tue 09:55: customer service adds order SO-88410 for a Louisville customer to R-2214 in the TMS. The route planner recalculates arrival times but has no radius check, so nothing is flagged.
3. Tue 13:20: D-117 delivers in Louisville, 164.5 air miles from the yard. From the regulation's point of view the whole day now needs a record of duty status and the 30-minute break rule applies.
4. Tue 20:02: D-117 clocks out at the yard, 14 hours 22 minutes after reporting, so the day would have failed the 14-hour condition anyway. No record of duty status exists for the day.
5. Next Mon 08:30: the weekly compliance query flags the release time. The controlled version of this day has the TMS reject the stop at 09:55 unless the dispatcher confirms the driver will start a paper record from 05:40, and counts the day toward D-117's rolling 30.

Dispatch, yard and payroll effects priced in dollars and rupees

Adding one out-of-radius customer has a monthly cost even when nobody is fined, and the cheapest compliant answer is not always the one dispatch reaches for first. India has no air-mile exemption or ELD rule to compare; its four labour codes, including the Occupational Safety, Health and Working Conditions Code 2020 that consolidated the Motor Transport Workers Act 1961, took effect on 21 November 2025. The rupee column therefore shows the same US decision as an India-headquartered parent would consolidate it, at an illustrative ₹88 per dollar.

On these illustrative numbers, rotating the run to keep each driver under nine logged days costs about $77 more each month than equipping one truck with an ELD, and it spreads the paper-log error risk across three people. Option C only wins when the customer's volume justifies a separate service or the local fleet has no spare driver hours inside the 11-hour driving limit.

• Yard effect: late releases on logged days push the next morning's earliest report time, so the first wave of outbound trailers may need a different driver.
• Payroll effect: time-and-attendance data becomes evidence, so manual clock edits need a reason code and an approver.

A Columbus depot adding a Louisville customer twice weekly can create up to 9 logged days per rolling 30-day window, which removes the 395.8(a)(1)(ii)(A)(1) paper-log option for a dedicated driver. On illustrative rates, one ELD-equipped driver costs about $198 a month against $275.40 for rotating three drivers on paper logs.

Which eligibility checks a system can enforce and which need a supervisor

Radius, release time and off-duty gaps are measurable facts and should be checked automatically on every route and every driver-day. Judgements about adverse conditions, driver-salesperson status and whether to accept an out-of-radius order belong with a named supervisor, with software only gathering the evidence.

Fleets that already run ELDs on some trucks can use the same review habits described in our guides to reviewing unassigned ELD driving time and handling ELD malfunctions. For dispatch-side clock locks across a long-haul fleet, our playbook on HOS dispatch interlocks and gate SOPs covers ELD-logged drivers; this article covers the drivers who are not logged at all.

Audit-ready checklist before claiming the short-haul exception

A carrier should be able to show, for any driver-day in the last six months, either a qualifying time record or a record of duty status. The checklist below turns that into tests a compliance manager can run on a sample of days before an investigator does.

If you are planning TMS radius checks, time-and-attendance links or a mixed ELD and short-haul fleet setup, the NextEdge request for proposal page explains what to send us. Other fleet compliance guides sit on the logistics and supply chain hub.