395.1 (e) Short Haul Exemptions, Lunch?

Question 20: May a driver who is taking advantage of the 100-air-mile radius exemption in§395.1(e) be intermittently off-duty during the period away from the work-reporting location?
Guidance: Yes, a driver may be intermittently off-duty during the period away from the work-reporting location provided the driver meets all requirements for being off-duty. If the driver’s period away from the work-reporting location includes periods of off-duty time, the time record must show both total on-duty time and total off-duty time during his/her tour of duty. In any event, the driver must return to the work-reporting location and be released from work within 12 consecutive hours.

So the question is: A driver comes to work at 6 am takes lunch at 12 for 30 minutes and works until 4 pm. The time record must show Time In and Time Out and Total Time.
Example: 6am-4pm=10 hours or does it equal 9.5? or 6am-12:00-12:30 -4pm=9.5 hours

JJ Keller forms only have 3 columns (In, Out, Total) so this doesn't make sense to me. The drivers sure would like to work 60 paid hours and not 57.5 paid hours due to the 60/6 day rule. We don't work Sundays.

I've been told because we're using the short haul exemption we aren't allowed to count the off duty time for lunch. (I do realize that they aren't required to take lunch but sometimes they do and the boss would prefer not to pay them for it.) Here's what I've been told:
For the drivers clocking out - the total time is not a correct time. In order to claim the short haul exception the time record must indicate start, stop and total.
Example: 6:00a - 4:00p = 10 hours; or 6:00a - 12:00p 12:30p - 4:00p = 10
There cannot be a deduction for lunch. You may not deduct the break time from the total.

HELP! What do you think? Isn't lunch off duty? But what if they are with the truck at McDonald's so they aren't leaving from our home office for lunch? Where's the loop hole? Thanks!

 

Thanks Kemosabi49. But the "I Think " part has me a little concerned. Anyone else have any factual advice?