Updated October 2026. A late airport pickup or an extra client stop can turn a workable schedule into an hours-of-service problem. For a chauffeured carrier, the first question is not “Do we own an ELD?” It is “Which rules apply to this vehicle, trip, and driver?”
First, check whether federal passenger HOS rules apply
Federal passenger-carrier rules depend on interstate-commerce status and the vehicle and compensation tests. A nine-seat vehicle is not automatically subject to every federal safety rule. Direct versus indirect compensation matters for some smaller passenger vehicles, and a trip that stays in one state can still be interstate in some circumstances. Use FMCSA’s small-passenger-vehicle guide to check your operation, then check state rules for trips outside federal jurisdiction. If you are not sure, resolve applicability before setting the driver’s schedule.
If the passenger HOS rules apply, watch three driving limits
- Driving time: Do not permit more than 10 hours of driving after eight consecutive hours off duty.
- On-duty time: Do not permit driving after the driver has been on duty for 15 hours following eight consecutive hours off duty. This is a limit on driving, not a blanket statement that all work must stop at hour 15. Qualifying off-duty time does not count as on-duty time.
- Rolling total: Do not permit driving after 60 on-duty hours in seven consecutive days if the carrier does not operate commercial motor vehicles every day of the week, or after 70 on-duty hours in eight consecutive days if it does. Work for other carriers counts.
Those are the general federal passenger limits in 49 CFR § 395.5; specific exceptions can change the analysis. Dispatch should check the driver’s remaining driving and on-duty time before accepting or extending a trip—not after the vehicle leaves.
Short haul changes the record, not the driving limits
A driver who qualifies under 49 CFR § 395.1(e)(1) can use the short-haul exception from the daily record-of-duty-status requirements. The driver must stay within 150 air miles of the normal work-reporting location, return there and be released within 14 consecutive hours, and—as a passenger driver—have at least eight consecutive hours off duty between duty tours. The carrier must keep accurate report time, release time, and total daily on-duty hours for six months. For a first-time or intermittent driver, the rule also calls for the preceding seven days’ total. If a trip breaks a condition, do not keep treating that day as a qualifying short-haul day.
See our current short-haul checklist for a closer look. A qualifying short-haul driver is not required to use an ELD for those timecard days; drivers who must keep records of duty status generally fall under the ELD rule unless another exception applies. FMCSA explains the ELD exceptions here.
A simple dispatch check before the next trip
- Confirm the vehicle, passenger capacity, compensation, and trip jurisdiction.
- Check the driver’s last eight consecutive hours off duty, driving time, on-duty time, and rolling seven- or eight-day total.
- If using short haul, check the reporting location, air-mile radius, planned release time, and time-record coverage.
- Agree on who dispatch calls if a trip runs late or the driver cannot finish within the applicable limits.
If your team needs help organizing the carrier’s driver records, short-haul timekeeping process, or audit preparation, see LBC Fleet’s compliance services and driver-support options. The carrier still needs to determine which rules apply to each operation and keep its own records accurate.
