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If I am mistaken then apparently the FMCSA Guidance is also mistaken.
link here
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Question 1: How should a change of duty status for a short period of time be shown on the driver's record of duty status?
Guidance: Short periods of time (less than 15 minutes) may be identified by drawing a line from the appropriate on-duty (not driving) or driving line to the remarks section and entering the amount of time, such as "6 minutes," and the geographic location of the duty status change.
This specifically mentions ". . . appropriate on-duty (not driving) or driving line . . ." and any changes from those lines should be flagged. This does not apply to a change from the sleeper berth or off duty lines. I am not going to flag every time I step out of the sleeper to visit the restroom. If I happen to ask someone on the way to the restroom what time they think I will get unloaded that also will not warrant a flag for the entire thirty seconds it took.
What the interpretation says is:
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Guidance: Short periods of time (less than 15 minutes) may be identified by drawing a line from the appropriate on-duty (not driving) or driving line to the remarks section and entering the amount of time, such as "6 minutes," and the geographic location of the duty status change.
Flagging the change is not an option, listing the amout of time the task required is an option.
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Also if Uturn is correct that
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less than 15 minutes may be flagged
Then the opposite must also be true, that they MAY NOT need to be flagged. Because by definition the word "MAY" gives us an option. . . to do or not to do.
Busted.
My bad, Uturn2001 used the word
MAY, the regulations do not:
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(c) For each change of duty status (e.g., the place of reporting for work, starting to drive, on duty not driving and where released from work), the name of the city, town or village, with State abbreviation, shall be recorded.
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Day began at 5 am, 15 pretrip, drove 1.5 miles to shipper, waited until 10 to dock,sat until 12 pm. Company is saying if under 20 miles were driven its not required to log it as on duty, and trying to say he didn't need to do his pretrip until 10 when he docked to the shipper, and that would be when he went on duty.
How you do your log is your choice, however:
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(f) The driver's activities shall be recorded in accordance with the following provisions:
(f)(1) Entries to be current. Drivers shall keep their record of duty status current to the time shown for the last change of duty status.
Question 26: May a driver record sleeper berth time as off-duty time on line one of the record of duty status?
Guidance: No. The driver's record of duty status must accurately reflect the driver's activities.
The information provided is regarding not logging short trips of Line 3. I doubt anyone would mind a driver not flagging the change from SB to off-duty if the driver was going to use the restroom. However, drivers that log sleeper berth while off-duty have been cited for false logs when toll receipts indicated the vehicle was in motion while a solo driver was logging SB time.
A driver may use a CMV for personal conveyance while off-duty. However, a driver cannot use a vehicle as a personal conveyance from the sleeper berth.
Be safe.