Updated October 12, 2026. A driver does not have to hold a CDL for federal hours-of-service (HOS) rules to apply. For a van or limousine trip, start with the trip, the vehicle, and the operation—not the license label. This guide is a decision path for passenger carriers, not a blanket rule that every airport ride needs a log.
First: is this a covered passenger-carrier trip?
Crossing a state line for compensation can be interstate transportation. A ride that stays inside one state can also be part of a prearranged interstate trip involving an airport, train station, or port. But a passenger who arranges a new ride only after arriving is not automatically continuing an interstate trip. Vehicle size, seating capacity, compensation, and exceptions also matter. Use FMCSA’s multi-modal trip guidance and its passenger-carrier fact sheet for the actual test; do not classify all airport work the same way.
Then: which HOS record method fits?
For a driver of a covered passenger-carrying commercial motor vehicle, federal rules limit driving to 10 hours after 8 consecutive hours off duty and prohibit driving after 15 hours on duty following that rest period. Other limits also apply. Check FMCSA’s passenger-carrier HOS guide before building the schedule.
The short-haul exception is a recordkeeping method, not a free pass from driving limits. A qualifying driver generally must stay within a 150-air-mile radius of the normal work-reporting location and return and be released within 14 hours; the carrier keeps the required time records. If the exception does not apply, determine whether a record of duty status (RODS) and an electronic logging device (ELD) are required. FMCSA’s HOS summary and ELD guidance explain the distinctions. Our short-haul decision guide walks through the record choice.
Make the policy workable for dispatch
- Classify the actual trip and vehicle before assigning a driver; do not use “CDL” or “airport” as a shortcut.
- Tell dispatch which drivers and routes need HOS records, and what changes when a short-haul condition is missed.
- Keep the chosen time records or RODS, train drivers and reviewers, and check the records for gaps. A company can choose a more conservative policy than the federal minimum, but should not label that policy a universal legal requirement.
If you are comparing tools for that record workflow, review LBC Fleet’s DOT compliance software as an option to evaluate. Ask for a live demonstration of the current ELD provider, passenger-HOS settings, short-haul handling, and record export for your operation. The product page alone does not prove that every module or exception works in your configuration, and the carrier remains responsible for determining which rules apply.
