On Duty, Not Driving

Absolutely!
Any time your carcass is IN the sleeper berth, you can put sleeper line 2 on your logs. You do not have to be "sleeping", just IN the sleeper area, no matter what you are doing.

 

The only guys I know who are anxious to leave themselves in an on-duty status at the dock are the one's who are paid by the hour when driving or on-duty on their logs.

 

"I wasn't working officer I was just driving!"

True enough I suppose.

 

DOT Inspector:
Why were you off-duty while at the shipper?

Me:
Because after I docked, they locked my ODOT bumber with a hook, removed my red air line and attached a gland hand lock, told me I was not needed on the dock and that they would bring paperwork out to me upon completion.

DOT Inspector:
Sounds good.

 

I just unloaded in Columbus and logged the whole hour and fifteen minutes on line 4, then left and didn't sleep in their parking lot. (I'm down the street at the gas station...just gnawed on a deli sandwich and one of those giant pickles)

 

Always has been a huge grey area, and much confusion added by conflicting company policies. And company policies add confusion to much more than this. Take personal conveyance for example.
The enforcement individuals opinions are on the money. I have been questioned about the amount of on duty time I log, usually about 1 hour total per day. But I don't haul freight, just power only drop and hook. Once that is explained the officer is satisfied. Usually reasonable folks imho.

 

FMCSA allows carriers to let their drivers log On Duty when arriving, but after the 15 min to go to Off Duty/Sleeper and normally they will have a letter in the truck stating that. They are basically relieving you of duties for the load. This way you do not burn up your 70/80 just sitting at a dock.

If you are required to be on the dock during loading/unloading then you have to log On Duty.

https://www.fmcsa.dot.gov/sites/fmcsa.dot.gov/files/docs/Drivers Guide to HOS 2015_508.pdf

 

Letter? No such thing found.

You must be physically IN the sleeper area to log sleeper berth line 2.

Letter or not, your carrier may relieve you of duty and you can be off-duty line 1. But: In order for time to be considered off-duty, you must be relieved of all duty and responsibility for performing work. You must be free to pursue activities of your own choosing and be able to leave the place where your vehicle is parked.

If you are not allowed to leave the vehicle, not off-duty.

 

I worked for a company that did publish a letter to all drivers relieving them of responsibility and to log line 1 or 2 which being loaded/unloaded and not on the dock. I did not mean FMCSA published a letter.

 

The FMCSA has said in a clarification that leaving the premises is not a prerequisite for logging off-duty. You can be sitting in the driver's seat, reading a book, not allowed to leave and still log off-duty.