Does any of this make it as clear as mud?
Question 19: Regulatory guidance issued by the Office of Motor Carriers states that a driver's record-of-duty-status (RODS) may be used as the 100 air-mile radius time record ". . . provided the form contains the mandatory information." Is this "mandatory information" that required of a normal RODS under §395.8(d) or that of the 100 air-mile radius exemption under §395.1(e)(5)?
Guidance: The "mandatory information" referred to is the time records specified by §395.1(e)(5) which must show: (1) The time the driver reports for duty each day; (2) the total number of hours the driver is on duty each day; (3) the time the driver is released from duty each day; and (4) the total time for the preceding 7 days in accordance with §395.8(j)(2) for drivers used for the first time or intermittently.
Using the RODS to comply with §395.1(e)(5) is not prohibited as long as the RODS contains driver identification, the date, the time the driver began work, the time the driver ended work, and the total hours on duty.
PS: Ed, the wooden shoes have dry rot.
Question 20: When a driver fails to meet the provisions of the 100 air-mile radius exemption (§395.1(e)), is the driver required to have copies of his/her records of duty status for the previous seven days? Must the driver prepare daily records of duty status for the next seven days?
Guidance: The driver must only have in his/her possession a record of duty status for the day he/she does not qualify for the exemption. The record of duty status must cover the entire day, even if the driver has to record retroactively changes in status that occurred between the time that the driver reported for duty and the time in which he/she no longer qualified for the 100 air-mile radius exemption. This is the only way to ensure that a driver does not claim the right to drive 10 hours after leaving his/her exempt status, in addition to the hours already driven under the 100 air-mile exemption.
Interpretation for 395.8
What I used to do is just log it. Group your drops together and show some drive time in between. Say I started in Portland and took 20 minuets to get to the first drop. Show 15 drive time then on duty not driving. Next stop is six blocks away, the next 10 blocks, the next 3 blocks. I would show all on duty not driving. My next stop is 15 minuets drive time show that as drive time even if still in Portland. My next stop is 23 minuets to Tualatin and I have 4 drops with in a 8 block radius. Show the drive time to Tualatin, (your choice either 15 or 30, I always rounded up if over 22 1/2 minuets) and the 4 drops took me 45 minuets show the drops as on duty not driving. Get my pattern? Try to keep it accurate as you can so when you end up with an hour drive to the terminal you show an hour not 15 minuets. Try to keep accurate mileage so you have a realistic number to put in the spot of mileage.
As far as you office time log it. Make sure you don't go over your hours. After you have done the logging for the local stuff for awhile you will find that you can do it fairly fast.