Personal conveyance (PC) does not start the driver’s Hours of Service (HOS) clock, including the 11-hour driving limit or the 14-hour duty limit, provided it is used correctly while the driver is off-duty. PC is an allowance for commercial motor vehicle (CMV) drivers to move their vehicle for personal reasons when they are relieved from work and all responsibility for performing work. This regulatory exception allows drivers to record time operating a CMV as off-duty, which helps manage available hours.
Understanding Personal Conveyance Status
Personal conveyance is defined by the Federal Motor Carrier Safety Administration (FMCSA) as the movement of a commercial motor vehicle for personal use while the driver is off duty. The fundamental requirement is that the driver must be completely relieved from all responsibility for performing work for the motor carrier. The driver cannot operate the CMV at the direction of the carrier or for the purpose of advancing a load or the carrier’s business.
PC allows drivers the flexibility to use their CMV for necessary personal activities, such as finding a place to rest or obtaining a meal, without counting that time against daily driving limits. Current FMCSA guidelines permit the use of a laden CMV for personal conveyance, provided the load is not being transported for the commercial benefit of the motor carrier at that time. Drivers use this status to account for movement while maintaining an off-duty status on their Record of Duty Status (RODS).
The Impact of Personal Conveyance on Hours of Service Limits
Time spent operating a CMV under personal conveyance is recorded as “Off Duty,” which is essential for managing a driver’s Hours of Service (HOS) limits. HOS rules impose three main constraints: an 11-hour driving limit, a 14-hour duty window, and 60/70-hour weekly limits. Logging PC as off-duty time prevents this movement from counting against the 11-hour maximum driving time.
PC time also does not count against the driver’s 14-hour duty window. Although the 14-hour clock continues to run once started, PC is not considered on-duty. This means a driver who has exhausted their 14-hour window can still use PC to find a safe parking spot. Since PC is off-duty time, it has no impact on a driver’s 60/70-hour cumulative limits or the required 34-hour restart period.
Permitted Uses of Personal Conveyance
The FMCSA provides specific examples where the use of personal conveyance is permissible and maintains the driver’s off-duty status.
Commuting and Errands
Common uses include commuting between the driver’s residence and the terminal, worksite, or authorized parking location. PC also covers traveling from temporary lodging, such as a motel or truck stop, to a nearby restaurant, entertainment facility, or for other personal errands.
Obtaining Rest
A driver may use PC to travel to a nearby, reasonable, and safe location to obtain required rest after loading or unloading. This is permissible even if the driver has exhausted available driving hours, as the movement is solely for obtaining necessary rest. If a law enforcement official requests the driver move the CMV during off-duty time, this movement can also be logged as PC. The movement must always be primarily for the benefit of the driver and not to advance the motor carrier’s operations.
When Personal Conveyance Becomes On-Duty Time
Improper use of personal conveyance immediately invalidates the off-duty status and triggers the on-duty or driving clock, leading to HOS violations. Any movement made to advance the load or enhance the motor carrier’s operational readiness is explicitly prohibited under the PC rule.
Common misuses include:
- Driving a CMV to a repair shop for maintenance or service, as this benefits the carrier.
- Repositioning the vehicle closer to the next assigned destination.
- Bobtailing (operating with an empty trailer) toward the next shipper or receiver to facilitate the next commercial trip.
- Bypassing available, safe resting locations to get closer to the next pickup or drop-off point.
- Driving the CMV to a motor carrier’s terminal after loading or unloading, rather than to a resting location.
In all these instances, the movement serves a business purpose, making it on-duty time.
Logging Requirements for Personal Conveyance
Drivers using a CMV for personal conveyance must accurately record this time on their Record of Duty Status (RODS). This is done by selecting the “Off Duty” status on an Electronic Logging Device (ELD) and activating the specific “Personal Conveyance” special driving category. The motor carrier must first enable this feature in the ELD system.
A proper annotation must be included with the log entry to explain the movement’s purpose and location, as required under 49 CFR 395.8. This annotation justifies the off-duty nature of the driving time during a roadside inspection. If the motor carrier does not authorize the specific ELD function, the driver may still log the time as Off Duty, but must manually annotate the log to indicate the use of personal conveyance.