100 Mile Radius Exemption / Passenger Carrying Driver

Found this

(B) A passenger-carrying commercial motor vehicle driver has at least 8 consecutive hours off duty separating each 12 hours on duty;

The way I interpret this is since our shifts are 8 hours we can’t work no more than 4 hours and the 8 hours of continuous rest begins when you punch out; start at 5:30am punch out 2:00pm. Punch in at 4:30pm. Can’t work more than 4 hours from 4:30pm and that’s when the 8 hours of continuous east starts when I punch out.

 

Found this page 4 of the document is referring to the 15-Hour On-Duty Limit which is first limit and the 10-Hour Driving Limit which is the second limit. This is confusing to me because the 2 limits seem contracting to each other.

(a) No motor carrier shall permit or require any driver used by it to drive a passenger-carrying commercial motor vehicle, nor shall any such driver drive a passenger-carrying commercial motor vehicle:

1. More than 10 hours following 8 consecutive hours off duty; or
2. For any period after having been on duty 15 hours following 8 consecutive hours off duty

https://www.fmcsa.dot.gov/sites/fmc...te-Passenger-Carrying-Driver-Guide-To-HOS.pdf

Thanks!

 

To be honest no I’m not. I’m just tying to understand what and what I can’t legally work and also to inform my co workers

 

Ok I hope I got the right info from a Grey Hound manager.

First my manager is wrong. He used to be in management at SEPTA which is the public mass transit system in Phildelphia and suburbs. Through a PennDOT waiver to state law, public transit bus drivers have looser regulations than other commercial motorists. Bus operators in Pennsylvania cannot be on duty for more than 16 hours per day, cannot work more 30 hours in two days back-to-back, and must have have an eight-hour rest period between shifts.

Manager thinks this applies to our operations but it doesn’t because we are private and not mass transit.

The bottom line for passenger carrying is you can’t work more than 15 hours which is on duty time and can’t drive more than 10 hours which is driving / behind the wheel time at the 15 hours. After 15 hours on duty / 10 hours of driving you must have 8 hour continuous rest.

He asked if we log out and log in between the runs on the routes because he realizes on transit type bus route there are breaks, rest room etc before the next run starts. I said we don’t. Then our 8 hour bus routes are considered 8 hours of driving / behind the wheel unless you log out and log in between the runs, but we don’t.

In our case we are eligible to work 2 hours.

I’m also going to call the FMCSA in Harrisburg to confirm this.

It’s not that I want to work more than what’s legal, I want to know what I can work to stay legal.

 

you meant 10 hours in a stretch...

also there’s a difference between work(on duty not driving) and driving.

 

Gotcha. In our case what’s regulated is 10 hours of driving.

 

Talked to an FMCSA enforcement officer out of the PA State Police HQ. Somewhat of a different response from the Grey Hound guy.