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An oilfield ELD that gets 395.1(d) right

Oilfield hours don't look like long-haul hours. Trucks sit on location for half a shift, crews rotate, and some drivers run under Canadian permits. Here is how the federal oilfield exceptions work, how waiting time goes on an ELD, and what TenTrucks does and doesn't do about it.

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Why oilfield hours are different

Picture a water truck idling on a pad in the Permian while the frac crew finishes a stage. The driver has been on location four hours and driven forty minutes all day. Twenty miles out, a pipe truck is stringing joints along a right-of-way, and there's no cell signal past the cattle guard.

Ordinary hours of service handle that day badly. The 14-hour window keeps running while the driver waits, and the 70-hour cycle needs 34 hours off to reset, which crews on rotation don't always get. Part 395 has two exceptions for this work, in 49 CFR 395.1(d). They help, but only for the drivers and vehicles they name, and one of them costs you the short-haul exception.

Neither one removes the logbook. If the truck is a commercial motor vehicle and no other exemption applies, the driver keeps records of duty status on an ELD like any other driver. The general limits are in hours of service.

The oilfield provisions side by side

Two paragraphs of 395.1(d), plus two rules often mixed up with them. The second column is where fleets get it wrong.

ProvisionWho qualifiesWhat it changesThe catch
24-hour restart, 395.1(d)(1)Drivers of CMVs used exclusively in transporting oilfield equipment, including stringing and picking up pipe for pipelines, and servicing the field operations of the natural gas and oil industryAny 8-consecutive-day period may end with an off-duty period of 24 or more successive hours, instead of 34The text says 8 days, not 7. Exclusively is the rule's word: a truck that also runs general freight doesn't fit it.
Waiting time, 395.1(d)(2)Specially trained drivers of CMVs specially constructed to service oil wellsWaiting time at a natural gas or oil well site isn't on-duty time. It's recorded as off duty, marked as waiting, and isn't counted in the 14-hour windowThese drivers can't use the 150 air-mile short-haul exception in 395.1(e)(1).
Sleeper berth, 395.1(g)(2)The same specially trained drivers of oil-well service vehiclesThe 10 hours off can be 10 consecutive hours of off duty, sleeper berth or other sleeping accommodations at the well site, or two rest periods of at least 2 hours each that add up to 10No 7-hour period is required, unlike the general split. It applies only to these drivers.
Pipeline welding trucks, 395.1(x)A pickup-style truck owned by a welder, with a welding rig used to build or maintain pipelines, at or under 15,000 lb GVWR or GCWR and weightPart 395 doesn't apply at allOwnership and weight conditions in 390.38 both have to hold.

The oilfield restart only shortens the reset. The 11-hour driving limit, the 14-hour window and the 10 hours off before driving don't change.

Waiting time: what counts and how it goes on the log

For the drivers it covers, 395.1(d)(2) says on-duty time does not include waiting time at a natural gas or oil well site. The waiting is recorded as off duty, either with remarks or annotations that mark the waiting periods or on a separate waiting-time line on the record of duty status. It isn't counted in the 14-hour window. The 60- and 70-hour limits count on-duty hours, so it doesn't add to them either.

An ELD has no waiting status to pick. FMCSA says the WT code in Table 6 of the ELD technical rule was carried over from the draft rule by mistake, and that drivers use annotations for special categories, including oilfield operations under 395.1(d). In practice, waiting is Off Duty with a note that it's waiting time.

Waiting means waiting

The provision is about waiting at the well site. If the driver is loading, unloading or working on the equipment, that isn't waiting, and it shouldn't go on the log as waiting.

Moving between wells is driving

The drive from one pad to the next is logged as driving, the same as any other driving. The waiting-time exception leaves the 11-hour driving limit where it is.

It follows the truck and the training

Delivering to a well site doesn't make a truck specially constructed to service oil wells. The rule names the vehicle and the driver's training, not the destination.

The short-haul trade

A driver working under 395.1(d)(2) gives up the 150 air-mile short-haul exception. For a local crew that ran on time records, that means logs every day.

In TenTrucks: settings on the log, not new clocks

Pick Oil & Gas at signup and hours of service starts on, with the wording set to Equipment, Driver, Asset, Operating and Sleeper. On each driver you set the things that matter here: the cargo type (Property, Passenger or Oil and Gas), the restart (24 or 34 hours on the US cycles) and the well-site setting, waiting time on line 5. Cargo type and well site are saved with the driver's log.

Now the plain part. TenTrucks has no waiting duty status. The statuses are Off Duty, On Duty, Sleeper, Driving, Personal Conveyance and Yard Move, and waiting goes on as Off Duty, which is what FMCSA expects. The well-site setting doesn't change any clock. The shift clock the driver sees is the standard 14-hour window, so for a driver who qualifies, the screen shows less time than the rule allows.

The restart works the same way: TenTrucks doesn't check whether a driver qualifies. The oilfield 24-hour restart ends an 8-day period, so it belongs with the USA 70 hour / 8 day cycle. If no preset fits, build a rule in the cycle rule builder and make well site, cargo type and restart choices the driver has to make in the app.

  • Oil and Gas cargo type on the log
  • Well-site setting saved with the log
  • 24- or 34-hour restart per driver on US cycles
  • Custom rules with required driver choices

Canadian oilfield work

TenTrucks has presets named Canada South Oil and Gas and Alberta, next to Canada South 70 hour / 7 day and 120 hour / 14 day. A driver who crosses the border can carry a primary and a secondary cycle and switch the active one in the app. The Canadian presets have no restart setting.

The federal rules, SOR/2005-313, define two cycles: 70 hours on duty in any 7 days, and 120 hours in any 14 days. Cycle 1 resets after 36 consecutive hours off and cycle 2 after 72. There is no federal cycle 3.

In Canada, oil well service work can run under a permit. Section 63 lets a provincial director issue one when the driver has completed safety training for the oil and gas field-services sector. Under the permit the normal cycles don't apply. The driver needs at least three off-duty periods of 24 hours or more in any 24 days, and 72 consecutive hours off before going back to the normal rules. Waiting or standby time at a well site isn't on-duty time when no work is done, it's recorded as off duty and marked as waiting or standby, and it isn't part of the mandatory 8 consecutive hours off. A vehicle operated under a permit is exempt from the Canadian ELD requirement.

Your permit's terms are what bind you. Go through the preset against the permit with us before you assign it.

  • Canada South Oil and Gas and Alberta presets
  • Primary and secondary cycle per driver
  • 14 days of logs in inspection mode on Canadian rules

Leases, pads and yards

Draw a circle around each pad, the saltwater disposal, the sand transload and your own yard. TenTrucks checks positions every 30 seconds, sends arrival and departure alerts, and the Geofence Dwell Time report shows how long each truck sat at each site.

That's how you answer an operator who disputes three hours of standby on a ticket. It doesn't replace the driver's log. Dwell is where the truck was. The log is what the driver was doing.

Put the circle on the pad, not on the lease road, so a truck driving past doesn't count as a visit. Geofence events can also go out by webhook to your own systems, and live positions and trip replay are on the fleet tracking map.

  • Circle geofences checked every 30 seconds
  • Arrival and departure alerts
  • Dwell time by truck and site
  • Location share links that expire when you choose

Engine hours, idling, fuel and fault codes

A truck that idles on location half the day barely moves its odometer, but the engine hours keep climbing. The TenTrucks ELD reads engine hours, odometer, speed, RPM and fault codes over J1939, OBD-II or J1708, so service runs on engine hours instead of a guess.

The Idle Time report shows which trucks idle and where. A low-fuel alert fires from the fuel level the truck reports. A fault code raises an alert and opens a work order, and so does every open defect from an inspection. The rest is in fleet maintenance.

Miles per state come from GPS and feed the IFTA report.

  • Service schedules by engine hours, miles or days
  • Idle Time report and idle alerts
  • Low-fuel and fault-code alerts
  • Fault codes and inspection defects open work orders

When there's no signal on the lease

Plenty of leases have no coverage. The phone talks to the ELD over Bluetooth, logs are saved on the phone first, and logging keeps going without a signal. When the phone finds a network again, it syncs.

At the roadside, the driver opens inspection mode for the officer: today and the previous 7 days, with an optional PIN so the officer can't leave that screen. The official transfer goes to FMCSA by web services or email, which needs a connection. FMCSA's guidance is that when data can't be transferred, the officer reviews the display or a printout, and that a device depending on roadside Wi-Fi may not be compliant.

The transfer and malfunction instructions are in the app and open offline. More on what the officer sees in roadside inspections.

  • Logging continues offline and syncs later
  • Inspection mode with today and the previous 7 days
  • Transfer by FMCSA web services or email
  • Transfer and malfunction instructions offline

What TenTrucks doesn't do in the oilfield

Know these before you buy.

No waiting status, no clock changes

Waiting is Off Duty. The well-site, adverse-conditions and 16-hour short-haul settings are stored on the log, and none of them stretches a clock.

No eligibility check

TenTrucks applies the cycle, restart and settings you choose. It doesn't know whether a truck is used exclusively in oilfield work or whether a driver is specially trained.

No satellite, cameras or asset tags

Data moves when the phone has a connection. There's no satellite option, no camera video and no standalone trackers for frac tanks, trailers or rig equipment.

Questions fleets ask us

About TenTrucks ELD for oil & gas fleets.

See TenTrucks set up for an oilfield fleet

Book a demo. We'll set up a driver for oil and gas work, draw your first pad and walk the log settings against the rules your drivers run under.

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