Logging Duty Status

If it were me... Non cdl work never happened.

 

It would seem they are not commercial motor vehicles, assuming they do not fit the following definition:

Commercial motor vehicle means any self-propelled or towed motor vehicle used on a highway in interstate commerce to transport passengers or property when the vehicle—

(1) Has a gross vehicle weight rating or gross combination weight rating, or gross vehicle weight or gross combination weight, of 4,536 kg (10,001 pounds) or more, whichever is greater; or

(2) Is designed or used to transport more than 8 passengers (including the driver) for compensation; or

(3) Is designed or used to transport more than 15 passengers, including the driver, and is not used to transport passengers for compensation; or

(4) Is used in transporting material found by the Secretary of Transportation to be hazardous under 49 U.S.C. 5103 and transported in a quantity requiring placarding under regulations prescribed by the Secretary under 49 CFR, subtitle B, chapter I, subchapter C.

- eCFR — Code of Federal Regulations​

Therefore, your non-CMV driving is considered on-duty, but not driving:

Driving time means all time spent at the driving controls of a commercial motor vehicle in operation.

On-duty time means all time from the time a driver begins to work or is required to be in readiness to work until the time the driver is relieved from work and all responsibility for performing work. On-duty time shall include:

(8) Performing any other work in the capacity, employ, or service of, a motor carrier;
​

- eCFR — Code of Federal Regulations​

 

I would think anytime running the van, and getting paid for it, you or your company must log you as on duty on your ELD.

 

If it is OTR Regional or big truck, It's ELD, logbook if necessary etc.

IF IT IS NOT CDL VEHICLE, NO ELD etc then it's your timeclock in the place you say good morning boss after clocking in that determines your work time.

 

i hate elds

 

Legally your delivering and or picking up items for the company. Your at a minimum on duty, but I believe legally you should be logging it as driving when drining, on duty while loading or unloading.
This is not necessarily how I would log it. But that was not the question.

 

If you are working, even a non CDL vehicle, it is On-Duty time, assuming you are running under logbook exempt (unless) status. Do yourself a favor and log it that way. If some crazy stuff happens and they audit you....it could go very bad if you try and hide it.