Hotshot drivers typically haul commercial loads using heavy-duty pickup trucks and trailers. Compliance with federal regulations regarding logbooks and Electronic Logging Devices (ELDs) can be confusing because requirements depend on the vehicle’s weight rating and the length of the haul. The application of Hours of Service (HOS) rules is not universal for all hotshot operations and requires a precise understanding of the Federal Motor Carrier Safety Administration (FMCSA) standards.
What Triggers Logbook Requirements
The foundational trigger for federal Hours of Service (HOS) rules and logbook requirements is the Commercial Motor Vehicle (CMV) definition established by the FMCSA. A vehicle combination is classified as a CMV if its Gross Vehicle Weight Rating (GVWR) or Gross Combination Weight Rating (GCWR) exceeds 10,000 pounds. The GVWR is the maximum weight the manufacturer specifies for the truck itself, including the vehicle, passengers, fuel, and cargo.
For hotshot operations, the GCWR is the more frequent trigger, representing the maximum weight of the truck, trailer, and load combined. Since heavy-duty pickup trucks and their trailers often push the combination well over the threshold, most hotshot drivers are subject to HOS rules. Drivers must maintain Records of Duty Status (RODS) if the operation meets the 10,001-pound threshold and involves interstate commerce. Failing to accurately determine the GCWR can lead to unintended non-compliance.
The Standard Mandate for Electronic Logging Devices
If a hotshot operation meets the 10,001-pound CMV weight threshold, the default requirement is compliance with the full Hours of Service (HOS) rules, which necessitates the use of an Electronic Logging Device (ELD). The ELD mandate was established to replace traditional paper logbooks, automating the recording of a driver’s duty status by synchronizing with the vehicle’s engine control module (ECM). The ELD is designed to accurately track driving time, on-duty time, and required rest breaks, thereby enforcing the federal HOS limits.
The HOS regulations govern how long a driver can operate a CMV, generally limiting driving to 11 hours within a 14-hour duty window, followed by a mandatory 10-hour off-duty period. While a logbook (RODS) is the record of compliance, the ELD is the required tool for creating that record for most CMV drivers. Paper logs are largely phased out, making the ELD the standard unless a specific exemption applies. Therefore, any hotshot driver operating a qualifying CMV for a long-haul route must install and use a compliant ELD.
Key Exemptions for Hotshot Drivers
Even when a hotshot vehicle combination meets the CMV weight threshold, several exceptions allow a driver to operate without an ELD or use paper logs instead. Understanding these exemptions is important for maintaining compliance while maximizing operational flexibility. These exceptions are narrowly defined, and drivers must meet all qualifying conditions for the entire duration of the trip.
The Short-Haul 150 Air-Mile Exemption
The most common exemption utilized by hotshot drivers is the short-haul exception, which allows a driver to use time records instead of a formal ELD or logbook. To qualify, the driver must operate within a 150 air-mile radius of their normal work reporting location. An air-mile is a nautical mile, which is approximately 1.15 statute miles, meaning the radius is about 172.6 statute miles from the base.
In addition to the distance restriction, the driver must return to their work reporting location within 14 hours and take a minimum of 10 consecutive hours off duty between shifts. If a driver exceeds the 150 air-mile radius or the 14-hour duty limit even once, the exemption is void for that day. The driver must immediately begin recording duty status using an ELD or paper logs. The motor carrier must still maintain accurate time records for six months.
The 8-Day Rule (Paper Logs)
This exemption allows drivers to temporarily avoid using an ELD even when Records of Duty Status (RODS) are required. This rule applies to drivers who use paper logs for no more than 8 days within any rolling 30-day period. This provision is intended to cover drivers who primarily operate locally under the short-haul exemption but occasionally take a longer trip that requires RODS.
If a driver uses a paper log on the ninth day within the 30-day window, they must install and use an ELD for the remainder of that period. This exemption provides flexibility but requires diligent tracking by the motor carrier to ensure the 8-day threshold is not surpassed.
Non-Commercial Motor Vehicle Exemptions
Other exemptions apply depending on the specific cargo or vehicle age. Vehicles with an engine model year of 1999 or older are exempt from the ELD mandate because their engines lack the electronic control modules (ECMs) necessary for integration. Specific exemptions also exist for agricultural operations hauling certain goods within a 150-air-mile radius during planting and harvesting seasons. Drivers involved in driveaway-towaway operations, where the vehicle being driven is the commodity, are also exempt.
Penalties for Hours of Service Violations
Failure to maintain required logs or violating HOS rules results in significant consequences for both the driver and the motor carrier. During a roadside inspection, a driver found to be in violation may be immediately placed Out-of-Service (OOS). This prevents them from driving until they accumulate the necessary off-duty hours, causing substantial delays and disrupting the time-sensitive nature of hotshot freight.
Fines for HOS violations are substantial, with civil penalties against carriers ranging from approximately $1,000 to over $16,000 per violation. Repeated violations negatively impact the carrier’s Compliance, Safety, Accountability (CSA) score, which can lead to increased insurance costs, more frequent roadside inspections, and difficulty securing contracts from shippers who monitor safety ratings.
Maintaining Records Even When Exempt
Hotshot drivers operating under a specific exemption, such as the 150 air-mile short-haul rule, must still maintain accurate records, even though a formal ELD or logbook is not mandated. The goal of this record-keeping is to provide proof of compliance with the duty limits in case of a safety audit or roadside inspection. These time records must clearly document the driver’s start time, end time, and the total number of hours on duty for the day.
The motor carrier is obligated to retain these time cards or equivalent documents for a minimum of six months. This verifies the driver returned to the work reporting location within the 14-hour limit and took the required 10 hours off. This practice ensures that the driver can easily demonstrate they met all the conditions of the exemption.