Are Electronic Logs for Hotshot Drivers Necessary?

Getting into hotshot trucking as an owner-operator can be a fast-paced and lucrative career move. Low startup costs, fewer regulations, and being your own boss appeals to many drivers. 

Most of the advice available to hotshot drivers is about breaking into the business. Yet, there’s a lack of information available to drivers about daily details such as Department of Transportation (DOT) regulations and compliance—including the use of electronic logging devices (ELDs).

There’s some confusion surrounding electronic logs for hotshot drivers. Do drivers need to keep logs? Which drivers need an ELD? How will ELDs help your business? In this guide, we’ll focus on hotshot drivers holding a commercial driver’s license (CDL). Although there are exemptions, these drivers typically need to keep electronic logs. Read on to learn more.

What is hotshot trucking?

Hotshot trucking involings hauling smaller, more time-sensitive freight within a specific timeframe. It is a niche but growing segment of the trucking industry. The market for hotshot drivers—or “hotshotters”—grew from shippers needing flexibility to move materials quickly, cost-effectively, and with less hassle from larger carriers and trucking companies. Hotshot drivers often move agricultural and construction materials, farm equipment, and machinery.

Running hotshot is attractive for entrepreneurial drivers looking for more time at home and to be less constrained by regulations. Many hotshot drivers are one-truck owner-operators or small fleet owners. They often carry incomplete or less than a truckload (LTL) of goods. Unlike traditional big rig trucking, hotshot driving differentiates itself by having lower startup costs and does not require a CDL. As long as a truck driver hauls loads under 10,000 pounds and has the proper documentation, he or she can operate without a CDL.

Hotshot driving also differentiates itself from traditional trucking by commercial vehicle class. Instead of driving a Class 7 or 8 vehicle—i.e., a traditional big rig—hotshotters drive medium-duty trucks in Classes 3-5, which include full-size pickups, box trucks, walk-in vans, and city delivery trucks. 

Hotshot vs. expedited freight

Even though the terms are sometimes used interchangeably, hotshot and expedited trucking are distinct types of freight hauling. Hotshot truckers use medium-duty trucks or one-ton trucks to carry and pull loads, and brokers communicate hotshot jobs via load boards. By contrast, businesses hire expedited freight carriers to deliver rush or emergency orders. These carriers use cargo vans, tractor-trailers, and straight trucks. These are usually single-purpose vehicles on standby. 

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Hours of Service (HOS) rules and electronic logs for hotshot drivers

It’s a common misconception that hotshot drivers don't need to follow Hours of Service (HOS) rules and keep electronic logs. There’s no one-size-fits-all rule within this niche. Drivers must figure out if Federal Motor Carrier Safety Administration (FMCSA) HOS rules apply to their operations.

In order to understand if regulations apply to you, we should start with a quick overview of the terminology:

• Hours of Service (HOS) are the federal rules that determine a driver’s working hours. HOS defines the amount of time drivers can spend within a different status (on-duty time, driving periods, and rest periods).  

• Record of Duty Status (RODS) is a driver’s log. The FMCSA requires every driver to prepare a record of duty status for each 24-hour period.

• Electronic Logging Devices (ELDs) are also known as e-logs. These are devices that drivers of commercial motor vehicles use to automatically log RODS to help drivers comply with HOS requirements. ELDs also capture data on the vehicle’s engine, movement and miles driven. In 2017, the FMCSA mandated that certain fleets replace paper logs with ELDs. 

In general, all carriers and drivers operating commercial motor vehicles (CMVs) need to follow HOS regulations. Hotshot drivers who meet at least one of the following criteria must maintain RODs:

• The driver conducts interstate commerce.

• Your vehicle has a gross vehicle weight rating (GVWR) or gross combination weight rating (GCWR) of 10,001 pounds or more. Or the gross vehicle weight (GVW) or gross combination weight (GCW) exceeds 10,001 pounds—whichever is greater. 

• The transportation load includes hazardous materials and required placards.

While there are exemptions to this criteria—discussed later—most hotshot drivers should expect to comply with HOS regulations and the ELD mandate.

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Do hotshot drivers need to comply with the ELD mandate?

The ELD mandate is part of the Moving Ahead for Progress in the 21st Century bill, more commonly referred to as MAP-21, which was enacted by Congress in 2012. MAP-21 included a provision requiring the FMCSA to develop a rule mandating that drivers of commercial motor vehicles use ELDs to comply with their hours of service requirements. The FMCSA’s ELD mandate went into effect in 2017. The goal of the mandate is to ensure drivers have safe work environments and create an easier system to track and manage RODS.

While the use of ELDs for hotshot drivers depends on the vehicle’s weight and how far they travel, most operators will need to use one. Why? Many leading medium-duty trucks themselves—without trailers—have a GVWR over 10,001 pounds. This means an ELD is necessary even while driving without a trailer attached or “bobtailing.”

Van and truck owners must also use an ELD when they are using their vehicle for personal purposes. However, they may record their off-duty status as personal conveyance. There is no limit to how much personal conveyance a driver can use, as long as they are using it appropriately.

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ELD exemptions

If the GVWR (or GCWR) of a hotshot driver’s vehicle is over 10,001 pounds, the driver may qualify for an exemption from the ELD mandate. While those exempted may not need to use an ELD, there may still be circumstances under which they will be required to prepare RODS.

Short-haul exemptions

There are exemptions for truckers who drive short distances. Drivers need to meet all the qualifications to use the short-haul exemption. If drivers miss even one qualification, then they must use ELD.

150 air-mile short-haul exemption (CDL holders)

This exemption applies if you’re a hotshot driver who completes a daily delivery or only travels a short distance during the workday. To meet this exemption, drivers must:

• Operate within a 150 air-mile radius of their daily starting location.

• Start and end the day at the same location.

• End the workday within 14 hours.

• Have at least 10 hours off-duty time between each 14-hour shift.

150 air-mile radius (non-CDL holders)

Similarly, suppose you drive a property-carrying commercial vehicle and do not have a CDL. In that case, you may still qualify for this exemption if you:

• Operate within a 150 air-mile radius of your work’s primary location.

• Return to that primary location at the end of each duty shift.

Additionally, you must not:

• Drive any vehicle that requires a CDL.

• Drive after 14 hours of coming on duty on 5 days of any period of 7 consecutive days.

• Drive after 16 hours of coming on duty on 2 days of any period of 7 consecutive days.

Even if you qualify for these short-haul exemptions, drivers must record time in, time out, and the total number of hours per day. Drivers may need to keep these records for six months.

When a truck driver no longer meets the short-haul exception by driving too far or working too many hours, they must complete a regular log or use an ELD.

Tow-away drivers

If you transport commercial vehicles as part of a tow-away business, you are exempt from the ELD mandate. Because your business does not own the CMVs it’s transporting, the FMCSA does not require you to install an ELD.

Pre-2000 vehicles

Any vehicle engine manufactured in 1999 or earlier is exempt from the ELD mandate. Vehicles with a 2000 model year or later are subject to the mandate. This applies to the engine model number and not the Vehicle Identification Number (VIN).

Drivers maintaining RODS for 8 days or less

Commercial drivers who maintain RODS for less than 8 days within a 30-day period are exempt from using ELDs. This applies to drivers who meet all short-haul exemption requirements but sometimes drive outside of the designated radius.

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Electronic logs for hotshot drivers help beyond compliance

While ELDs help drivers log hours and stay in compliance, today’s devices have many benefits. For example, suppose an ELD is part of a telematics hub or vehicle gateway. Its hardware would also contain other sensors and tools that give drivers access to information to improve operations.

A few functions a telematics solution can help with:

• Real-time tracking: GPS built into the hardware gives you precise location data, even in challenging geographical environments. 

• Routing and dispatching: Real-time tracking helps small fleet managers pivot to dispatcher mode by coordinating jobs, re-routing vehicles, and managing drivers efficiently.

• Engine diagnostics: Proactively check your engine for issues like failing batteries and engine fault codes.

• Fuel management and efficiency: Fuel data tells you how fuel is being used, allowing you to make adjustments to improve fuel economy.

• Driver safety: Engine data can reveal unsafe driving behaviors such as harsh turning and braking.

• International Fuel Tax Agreement (IFTA) tracking: Accurately track IFTA miles and streamline quarterly reporting.

While these functions may seem insignificant, making slight adjustments can keep costs down and save you money in the long run. For instance, engine diagnostics help you take care of problems before they surface, saving you money on costly emergency repairs. Fuel data shows if you’re driving inefficiently and unnecessarily burning fuel by doing things such as accelerating fast and braking hard. And if you make adjustments and improve unsafe driving habits, you might save money on insurance.

Electronic logging device solutions

If your hotshot company is subject to HOS regulations and requires an ELD, Samsara can support your business needs. The Samsara electronic logging device is an FMCSA-registered ELD that connects to the engine's OBD-II port and automatically collects vehicle data throughout the day. This, combined with the Samsara Driver App where you access your HOS logbook, provides you with an accurate and complete read of compliance. 

Through the Samsara Driver App, you can update your driving status, see the time until a rest break, and track the number of hours left in a driving period. Compliance is simplified; the app will automatically notify any driver approaching HOS violations.

Samsara ELD compliance is part of a unified system designed to increase the safety, efficiency, and sustainability of trucking operations. Our solutions provide owner-operators and small fleet managers with real-time GPS tracking for live-to-the-second location data, dash cams, trailer tracking to prevent theft, and more. 

To learn how Samsara can help you become more efficient, reach out for a free trial today or read more about the Samsara ELD solution.

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