If you’re reading this, I’ll assume your goal is to be safe and compliant. One of the hardest areas for many passenger-carrier fleets is implementing hours-of-service tracking for non-CDL drivers who operate vans or limousines.
Do not rely on the 150 air-mile short-haul exception without confirming every requirement. Review FMCSA’s current passenger-carrier hours-of-service guidance before applying it.
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
- Pros
- 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
- Pros
- 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
- Pros
There is no one size fits all solution, but hopefully this information will help streamline the discussion in your organization.
