FMCSA Clarifies Oilfield Hours of Service Exemptions

Jun 13, 2012 | Articles, Industry News

The FMCSA’s June 2012 “guidance” did not change their exemption or their interpretations of the Hours of Service regulations as they apply to oilfield work.  It is intended to clarify the regulatory exemptions for oil and gas work.

Let’s clarify the 2 components of this Oil and Gas HOS exemption:

Exemption 1 – “Waiting” Time at Well Site.  Also known as “Line 5” or off duty at well site time, this allows drivers to go off duty at a well site.  That “Off Duty” time in the middle of a tour of duty NOT count toward the total On Duty time for a driver’s day.  Off Duty time is treated much like the sleeper berth provision.  Logging “Off Duty at Well Site” (as we call it at LoadTrek) extends a driver’s work day.

Application:  You can only use this Exemption if you are driving a “specially constructed” vehicle specifically made for oil or gas well servicing work.  Examples are frac pumps, wireline trucks, coiled tubing units, workover rigs, etc.  Pneumatics, liquid tankers (crude, water, etc) do not qualify.

Exemption 2 – 24 Hour Restart.  This allows drivers to restart their cumulative workweek time after 24 consecutive hours Off Duty.  This is available to all drivers who are working to service oil and gas wells.  This includes the previously mentioned tankers, equipment haulers, as well as those specially constructed vehicles.

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Doug Marcello The LEAD: Ignoring your data, fearing discovery in litigation, can be fatal to your company. The data is there. Plaintiffs will get it. You must proactively cumulate and analyze it to promote safety and proactively prepare to defend any potential suit....

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