150 Short Haul exemption - Normal work location or Home base
Regarding the 150 mile short haul exemption, how is the normal work location determined? The business has always operated on the basis that when teams go out they utilize the hotel as their basis of daily normal work location and as long as they stay with in 150 miles of the hotel and job site they are within the exemption. It is my understanding that its based on the business start/stop location since they come home on weekends and eventually return to the business home site.
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That's how I've always understood it, as well. The normal work location to return to is the one that would be where they started their day, and where they get back in their personal vehicle, done for the day, or in your case, the hotel where they're staying if the truck is parked there also. That allows jobsites to be the ‘return to’ when crews are working away from the company base location. It can also be where the truck is parked for start/return for work each day, if away from home business location, but you'll either want to transport the driver there or have his personal vehicle parked there while he's in the truck. I would also want to be very careful about using PC with those trucks that are working away from the regular business home site….not saying it can't be done, but i'd want it documented carefully, with driver receipts for personal purchases, etc.
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Interpretation Question #15 under 3951.
May an operation that changes its normal wor-reporting location on an intermittent basis utilize the 100-air mile (should be 150 air mile) radiius exemption?
Yes. However, when a motor carrier changes the normal reporting location to a new reporting location, that trip (from the old location to the new location) must be recorded on the RODS becuase the driver has not returned to his/her normal work reporting location.
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