HOS rules and working in yard.

The "business" is involved in interstate commerce, and any trailer placarded and transported (doesn't say how far, doesn't say on a street, just says transported....which also means "moved"....would qualify a yard goat to be a CMV used by "the business"..
I guess the FMCSA rules don't apply to your version or interpretation:

• http://www.fmcsa.dot.gov/regulations/hours-of-service

As to what is coming with EOBR's, here is an excerpt from the same group...an explanation:

 

I guess the FMCSA rules don't apply to your version or interpretation:

• http://www.fmcsa.dot.gov/regulations/hours-of-service

As to what is coming with EOBR's, here is an excerpt from the same group...an explanation of rules:

 

You do realize that you can only log 11 hrs on driving right?

 

If a trailer isnt moved from a physical address then its pretty difficult to claim its involved in interstate commerce during said move.

 

What is the difference between interstate commerce and intrastate commerce?

If you perform trade, traffic, or transportation exclusively in your business’s domicile state, this is considered intrastate commerce. If your trade, traffic, or transportation is between a place in a state and a place outside of such state (including a place outside of the United States); between two places in a state through another state or a place outside of the United States; or between two places in a state as part of trade, traffic, or transportation originating or terminating outside the state or the United States, this is considered interstate commerce. Source: 49 CFR 390.5.

Last Updated : June 4, 2014

http://www.fmcsa.dot.gov/faq/what-difference-between-interstate-commerce-and-intrastate-commerce​

Note the reference to "...trade, traffic, or transportation..." If what is on the trailer when it is moved in the yard is part of interstate commerce, then the trailer and any movements thereof are engaged in interstate commerce regardless of the origin or destination of that particular move.

 

DOT HOS regulations only apply to operating a CMV on a public roadway. If you never leave private property, HOS does not apply.

 

Really? Please show me (using the regs and a link or a quote) where it states anything about "on a public roadway". Better read the quote directly from the FMCSA regs...(one more time...)
Most drivers must follow the HOS Regulations if they drive a commercial motor vehicle, or CMV.

In general, a CMV is a vehicle that is used as part of a business and is involved in interstate commerce and fits any of these descriptions:

• Weighs 10,001 pounds or more
• Has a gross vehicle weight rating or gross combination weight rating of 10,001 pounds or more
• Is designed or used to transport 16 or more passengers (including the driver) not for compensation
• Is designed or used to transport 9 or more passengers (including the driver) for compensation
• Is transporting hazardous materials in a quantity requiring placards

 

So you are saying that any time a driver is on private property the HOS no longer apply? Like when picking up a reefer load at a cooler? Loading a coil at a mill? Dropping off cars at a dealership? Can you see the fallacy of your statement?

 

Part 390
FEDERAL MOTOR CARRIER SAFETY REGULATIONS; GENERAL

§ 390.5: Definitions.

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.​

Highway means any road, street, or way, whether on public or private property, open to public travel. “Open to public travel” means that the road section is available, except during scheduled periods, extreme weather or emergency conditions, passable by four-wheel standard passenger cars, and open to the general public for use without restrictive gates, prohibitive signs, or regulation other than restrictions based on size, weight, or class of registration. Toll plazas of public toll roads are not considered restrictive gates.

http://www.fmcsa.dot.gov/regulations/title49/section/390.5

 

As far as i knew you dont even need a cdl to drive a semi on privite proporty, always been part of the warehouse duties at mid sized ltl's that ive been around. But thats just my opinion. And that plus a dollar will buy you a coffee.