FMCSA just posted new guidance clarifying a slight modification to how they interpret the HOS agricultural exemption, and how it will work with the upcoming ELD mandate.
This new guidance was issued in response to a slight change in how the agency is interpreting the exemption. Traditionally we have interpreted the 150 air mileage exemption as counting towards work done within the radius throughout the day, however now the interpretation is being applied to any work being done within the radius (loading/detention time/etc.) whether they are operating within the radius throughout the day or just at the beginning of their trip. For example, if a carrier hauling cattle from Montana to Colorado starts their day at a hotel location near the loading point then all time spent waiting to load, loading and driving within the first 150 air miles (172 actual miles) is covered under the exemption and not until the carrier is outside that radius does the hours of service clock begin. The document also goes on to explain how this interpretation will work with the new electronic logging mandate.
Agricultural & Food Transporters Conference
American Trucking Associations, Inc.