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Oilfield operations: HOS exceptions
  • Drivers of CMVs used exclusively in the transportation of oilfield equipment can restart their accumulated on-duty time by taking 24 consecutive hours off.
  • For specially trained drivers of CMVs that are specially constructed to service oil wells, time spent waiting at a natural gas or oil well site can be recorded as off-duty time and excluded from the calculation of the 14-hour limit.
  • A specially trained driver who operates a CMV that is specially constructed to service natural gas or oil wells can accumulate a 10-hour break through use of on-site sleeping accommodations.

Due to the specialized nature of oilfield operations, drivers of commercial motor vehicles (CMVs) in the oilfield industry can take advantage of three exceptions to the federal hours-of-service rules in Part 395:

  1. 24-hour restart,
  2. Waiting time, and
  3. Equivalent of 10 hours off.

24-hour restart

Drivers of CMVs that are used exclusively to transport oilfield equipment can reset their accumulated on-duty time by taking a break of just 24 hours rather than 34 hours. (395.1(d)(1)). This exception is available to drivers engaged in a broad range of activities which directly support the operation of oil and gas well sites, including:

  • Stringing and picking up of pipe used in pipelines;
  • Servicing the field operations of the natural gas and oil industry;
  • Transporting equipment and supplies (including water) to the site and waste or product away from the site;
  • Moving equipment to, from, or between oil and gas well sites;
  • Transporting excess materials from the well site, if such operations are limited to transportation between the service depot or motor carrier facility and the field site; and
  • Oilfield mechanics operating CMVs used to service the vehicles/equipment associated with field operations.

“Oilfield equipment” is not specifically defined and may encompass a spectrum of equipment ranging from an entire vehicle to hand-held devices.

The driver must be in full compliance with 60- or 70-hour limit before driving other CMVs not used to service the field operations of the natural gas or oil industry.

Waiting time

For specially trained drivers of CMVs that are specially constructed to service oil wells, time spent waiting (and performing no other work) at a natural gas or oil well site can be:

  • Recorded as off-duty time, and
  • Excluded from calculation of the 14-hour limit. (395.1(d)(2)).

The waiting time must be accurately logged as “off duty” along with additional remarks to show which specific off-duty periods were spent waiting, or through use of a five-line log that has a fifth line to record waiting time. All other off-duty time must be recorded on Line 1.

Examples of equipment that may qualify a driver for the “waiting time” exception are vehicles commonly known as heavy-coil vehicles, missile trailers, nitrogen pumps, wire-line trucks, sand storage trailers, cement pumps, “frac” pumps, blenders, hydration pumps, and separators.

Drivers of CMVs used to transport supplies, equipment, and materials such as sand and water to and from the well sites do not qualify for the “waiting time” exception even if there have been some modifications to the vehicle and some training was required to run pumps, for example.

Caution:

  • Off-duty time spent at a yard for oilfield equipment is not eligible for this exception and must be counted toward the calculation of the 14-hour rule.
  • Oilfield drivers who use the “waiting time” exception cannot take advantage of the 150 air-mile exception in 395.1(e)(1) or the 16-hour exception in 395.1(o).

Equivalent of 10 hours off

A specially trained driver who operates a CMV that is specially constructed to service natural gas or oil wells can accumulate the “equivalent” of 10 consecutive hours off duty in two ways:

  1. By taking a combination of at least 10 consecutive hours of off-duty time, sleeper-berth time, or time in other sleeping accommodations at a natural gas or oil well location; or
  2. By taking two periods of rest in a sleeper berth or other sleeping accommodation at a natural gas or oil well location, providing:
    • Neither rest period is shorter than two hours;
    • The driving time in the period immediately before and after each rest period, when added together, does not exceed 11 hours; and
    • The driver does not drive after the 14th hour after coming on duty following 10 hours off duty.

Under option 2, the 14th hour is calculated by:

  1. Excluding any sleeper-berth or other sleeping period of at least two hours which, when added to a subsequent sleeper-berth or other sleeping period, totals at least 10 hours; and
  2. Including all on-duty time, all off-duty time not spent in the sleeper berth or other sleeping accommodations, all such periods of less than two hours, and any period not described in “A” above.

The driver may not return to driving subject to the normal limits under 395.3 without taking:

  • At least 10 consecutive hours off duty,
  • At least 10 consecutive hours in the sleeper berth or other sleeping accommodations, or
  • A combination of at least 10 consecutive hours off duty, sleeper-berth time, or time in other sleeping accommodations. (395.1(g)(2)).