Anyone else deal with this...

What do you mean "job site". Do they drive on public roads or private property?

 

What line of work exactly?

For compliance, they can reset by pulling ten hours "off duty at wellsite". Illegal (since they're actually working on duty, but good luck proving it Mr. DOT man!), but it will cover you from a compliance standpoint.

As far as the actual "it's not safe" part - that's a company culture issue that will only change if management is on your side, and are willing to change the culture. Even then, it will take forever to get most hands on board.

If your company has the resources and you really want to be legit, do like Halliburton, and have them shuttled to and from location at shift change.

 

You will not change the culture at that company.

Now, to answer your question, any travel time at the direction of a motor carrier must be logged as on-duty not driving unless they are afforded 10 consecutive hours off-duty before operating a commercial motor vehicle. If given the 10 off then all travel time must be recorded as off-duty.

In plain English, they must log on-duty when they report to the off-site location and are traveling to their trucks at the well pad. This time counts towards their 14 hour window. The trip from the pad back to the remote location where they get in their own cars and go home or otherwise are relieved of duty can be logged as off-duty if they are given 10 consecutive hours from when they get out of the company provided/directed transportation before they must report back to the work site (meeting location). If not then it is logged as on-duty, which will then put them in violation of the required rest period rule.

Look to 395.1 for the definition of teavel time, this is the controlling regulation for your scenario.

(j) Travel time—(1) When a property-carrying commercial motor vehicle driver at the direction of the motor carrier is traveling, but not driving or assuming any other responsibility to the carrier, such time must be counted as on-duty time unless the driver is afforded at least 10 consecutive hours off duty when arriving at destination, in which case he/she must be considered off duty for the entire period.

Also, FYI, here is the FMCSA guidance related to travel time. Ignore the references to 8 hours, this guidance was issued before the 10 hour rule. Yes, it's that old!

Question 14: How must a Commercial Motor Vehicle CMV driver driving a non-Commercial Motor Vehicle CMV at the direction of a motor carrier record this time?
Guidance: If Commercial Motor Vehicle CMV drivers operate motor vehicles with Gross Vehicle Weight Rating (GVWR)s of 10,000 pounds or less at the direction of a motor carrier, the Federal Highway Administration (FHWA) requires those drivers to maintain records of duty status and record such time operating as on-duty (not driving).
Question 24: If a driver is transported by automobile from the point of a breakdown to a terminal, and then dispatched on another run, how is the time spent in the automobile entered on the record of duty status? How is the time entered if the driver goes off-duty once he reaches the terminal?
Guidance: The time spent in the automobile would be on-duty (not driving) if dispatched on another run once he/she reaches the terminal, and off-duty if he/she is given 8 consecutive hours off-duty upon reaching the terminal.

 

Are you sure it is a non-CMV. Remember a commercial motor vehicle for hours of service purposes is not the same as a CMV for CDL or drug testing purposes. For hours of service it starts at 10,000 GVWR, which today encompasses many pickup trucks including the Ford F-350 single rear wheel and up.

Also see my other reply to this thread regarding proper logging of travel time, it appears this travel time is still on-duty not driving time.

395.1
(j) Travel time—(1) When a property-carrying commercial motor vehicle driver at the direction of the motor carrier is traveling, but not driving or assuming any other responsibility to the carrier, such time must be counted as on-duty time unless the driver is afforded at least 10 consecutive hours off duty when arriving at destination, in which case he/she must be considered off duty for the entire period.

 

Almost, they would be on-duty not driving on their log in the noncommercial pickup truck if it is at the directionof the company, which is fine. You can work past 14, just can't drive a CMV on public roadways. Their 10 hour break would have to start at the moment the got out of the pickup to head for the house or bunk or whatever not work related.

FMCSA does not tie compensation to on-duty time, it is both possible to be paid and be off-duty at the same time, or be logged on-duty but unpaid such as waiting time at a dock.