On-Duty Time Policy

Policy Justification: The 2-Hour On-Duty Time Requirement Under the 17-Hour Clock Rule

Objective:
To ensure that essential non-driving responsibilities are accounted for within the 17-hour duty window through a structured, safety-aligned 2-hour on-duty expectation—without compromising the rolling, flexible nature of the rule.

1. Purpose of the On-Duty Allocation:
Truck drivers are responsible for far more than driving. The law and industry recognize a range of on-duty tasks including: • Pre-trip and post-trip inspections
• Vehicle fueling and maintenance
• Loading and unloading oversight
• Paperwork, dispatch communications, and route planning
These duties are essential for safety, compliance, and efficiency but do not contribute to productive drive time. The 17-Hour Clock Rule allocates 2 hours specifically for these responsibilities, ensuring: • Drivers are not penalized for completing required tasks
• Time is formally accounted for within the duty cycle
• The system reflects the daily balance between driving and supporting responsibilities
• Drivers don’t have to choose between doing their job right and protecting their clock — reinforcing trust in the system and protecting both pay and professionalism

2. Safety and Compliance Considerations:
The inclusion of the 2-hour on-duty requirement prevents the misclassification or compression of safety-critical tasks into off-duty or undocumented segments. This: • Reinforces a culture of compliance
• Protects drivers from pressure to cut corners on inspections or paperwork
• Ensures full transparency in ELD logs
• Maintains alignment with FMCSA inspection standards

3. Operational Flexibility:
The on-duty time is not a rigid block. It may be distributed throughout the 17-hour window in alignment with the driver’s workflow. For example: • 30 minutes for pre-trip inspection
• 45 minutes at a weigh station
• 20 minutes for fueling
• 25 minutes for post-trip logs and walkaround
While drivers may not always use the full two hours of on-duty time in practice, the system structurally accounts for it within the 17-hour duty period. As long as essential non-driving tasks are properly logged within any rolling 24-hour window, the driver remains in full compliance. This structure respects the unpredictability of the job while maintaining a clear and auditable framework.

4. Industry Alignment:
The 2-hour on-duty component is consistent with: • FMCSA’s existing definitions of on-duty tasks
• Current carrier safety programs and log auditing protocols
• The practical time distribution observed across local, regional, and OTR operations
By institutionalizing what is already functionally required, this rule promotes a more honest, flexible, and safety-forward system.

5. Compatibility With the 17-Hour Clock Rule:
• On-duty time is included within the 17-hour duty period.
• It is restored minute-by-minute when a driver is in the sleeper berth.
• It pauses when a driver is off-duty.
This rolling system ensures that drivers can meet their operational responsibilities without being punished for delays or shifts in daily structure.
• Given that many ELD systems automatically log on-duty time when a vehicle is stopped, the 17-Hour Clock Rule works in harmony with real-world log behavior. It encourages drivers to record legitimate tasks accurately and removes the incentive to avoid logging on-duty time out of fear of “eating the clock.”

6. Practical Impact:
• Encourages better time management by ensuring key safety tasks are consistently completed.
• Removes pressure to skip inspections or paperwork due to fear of “losing time.”
• Protects driver safety while maintaining flexibility and control.
• Encourages accurate logging by removing the fear of “eating the clock” when documenting short but legitimate duties.

Conclusion:
The 2-hour on-duty time requirement is not an arbitrary addition. It reflects the non-negotiable responsibilities of the modern truck driver and provides structure to a clock system that is otherwise designed for flexibility and autonomy.
Incorporating this policy strengthens the legal, operational, and safety framework of the 17-Hour Clock Rule and ensures the system maintains both driver freedom and industry accountability.

Executive Summary
An overview of the proposal and why it’s time to fix the clock.

Sleeper Berth Time & Clock Restoration
How rest restores time, and how the 6-hour sleeper requirement keeps drivers fresh.

Off-Duty Time & Clock Pausing
Why true off-duty time pauses the clock without penalty—and how it helps.

15-Hour Drive Time Limit (Rolling 24-Hour Period)
How the system prevents fatigue and abuse while giving drivers back their control.


Prefer to listen instead?
Watch or listen to the On-Duty Time Policy read aloud on our YouTube channel.

Listen to the On-Duty Time Policy on YouTube