FMCSA Clarifications on Oil, Gas HOS Exemption Qualification

The FMCSA's "guidance" last week 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 treat 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.