We’re often asked by our clients about when it’s okay and when it’s not okay to use “Personal Conveyance”, or “PC” mode. So, we decided to create this primer to help clear up many of the common misconceptions out there.
What is Personal Conveyance?
Personal conveyance is simply the movement of a commercial motor vehicle (CMV) for personal use while off-duty.
All motor carriers are responsible for ensuring that drivers are not operating while ill or fatigued.
Trucking companies, at their discretion, may authorize their drivers to use a CMV while off-duty for personal conveyance. When this occurs, drivers are required to document such use as off-duty on their RODS (Paper Logs, AOBRD or ELD).
While “personal use” can mean many things to many people, the FMCSA recently came out with guidance that amends their previous thoughts on the proper use of Personal Conveyance status.
Generally, the FMCSA is very good about telling you what to do but not necessarily how to do it. However, this recent clarification is a welcome departure from the norm.
How Can Drivers Use PC?
Once a driver completes their On Duty Driving Time, they can switch their ELD system to Off Duty and then to Personal Conveyance Mode. Most ELD systems won’t allow a driver to move directly to PC from On-Duty Driving.
The FMCSA’s Personal Conveyance Website is a great resource for both drivers trucking companies. The site lists a great amount of information that can be very helpful.
When Can Drivers Use Personal Conveyance?
A driver may record time operating a CMV for personal conveyance as off-duty only when the driver is relieved from work and all responsibility for performing work by the motor carrier.
The following are examples of when operating a CMV is considered off-duty:
1. Time spent traveling from a driver’s en route lodging (such as a motel or truck stop) to restaurants and entertainment facilities.
2. Commuting between the driver’s terminal and his or her residence, between trailer-drop lots and the driver’s residence, and between work sites and his or her residence.
In these scenarios, the commuting distance combined with the release from work and start to work times must allow the driver enough time to obtain the required restorative rest as to ensure the driver is not fatigued.
3. Time spent traveling to a nearby, reasonable, safe location to obtain required rest after loading or unloading. The time driving under personal conveyance must allow the driver adequate time to obtain the required rest in accordance with minimum off-duty periods under 49 CFR 395.3(a)(1) (property-carrying vehicles) or 395.5(a) (passenger-carrying vehicles) before returning to on-duty driving, and the resting location must be the first such location reasonably available.
In other words, the 10 hour minimum off-duty time will begin once the driver arrives at their new “safe haven” resting space.
4. Moving a CMV at the request of a safety official during the driver’s off-duty time.
5. Time spent traveling in a motorcoach without passengers to en route lodging (such as motel or truck stop), or to restaurants and entertainment facilities and back to the lodging. In this scenario, the driver of the motorcoach can claim personal conveyance provided the driver is off-duty. Other off-duty drivers may be on board the vehicle, and are not considered passengers.
6. Time spent transporting personal property while off-duty.
7. Authorized use of a CMV to travel home after working at an offsite location.
You have to use a great deal of caution here to not “further commerce”. “Home”, as used here, means the normal work reporting location.
Let’s say that your driver has just completed a drop but is now out of available driving hours. The driver can’t simply move into PC status and begin heading back to their terminal.
That would be what the FMCSA would consider as “furthering commerce” and it’s a big No No. It’s essentially log falsification and could cost you upwards of $3,000 for each discovered occurrence during a compliance review.
To learn more about Personal Conveyance and the appropriate times to use this status, please review the FMCSA’s List of Appropriate Personal Conveyance Use.
