Bobtail to the Next Pickup Is Not Personal Conveyance

PC is personal use, off duty, not for the carrier

FMCSA's personal-conveyance guidance describes the use of a commercial motor vehicle while the driver is off duty, for personal reasons, and not to advance a load or the motor carrier's business. That is a purpose test. The truck can be a commercial motor vehicle. The driver can be an employee. Neither fact creates personal conveyance. The miles have to be the driver's personal errand, after the driver is relieved of work.

Off duty means relieved of work and of responsibility for performing work. A dispatch instruction, a pickup appointment, and a message that says be there at 06:00 are work. Movement that answers those instructions is on duty. The guidance's examples of personal use are things like travel from lodging to a restaurant and back, or travel home from a terminal where the driver was relieved, when the move is not advancing the load. They are not the next load.

The full definition, the examples FMCSA prints, and the way to annotate a move that really is personal are on personal conveyance and personal conveyance on the ELD. This page has one job: the bobtail or empty move toward freight, which is not on that list.

Positioning for a load is business, even bobtail

Bobtail to a shipper is on-duty driving. Bobtail to the yard so the trailer can be hooked is on-duty driving. Empty, with the trailer already on, to the next pickup is on-duty driving. Moving closer tonight so the morning appointment is possible is on-duty driving. The carrier's business is advanced the moment the truck is where the load needs it to be. Taking the trailer off does not wash that purpose out.

Drivers describe this as I'm not under a load yet. The regulation does not wait for the bill of lading to be signed. Positioning is part of the job. It counts as driving time against the 11-hour limit, it sits inside the 14-hour window, and it counts as on-duty time against the 60 or the 70. Logging it off duty removes it from all three. That is why the misclassification is attractive, and why it is a false record of duty status.

A driver who has been relieved, who is not answering a dispatch, and who takes the truck to a personal stop can be in a different case. The moment the purpose becomes the pickup, the yard, or a head start on tomorrow's freight, the case changes back. If you have to ask whether dispatch would be upset if you did not make the move, you are not on a personal errand.

There is no federal mile cap that makes it legal

FMCSA's guidance does not publish a mileage allowance that converts a business deadhead into personal conveyance. A rumor of a fixed mile figure, whatever number is circulating this month, is not a sentence that legalizes bobtail to the shipper. Short deadheads are still deadheads. Long ones are too. The test is purpose, and it applies to the first mile.

Do not shop for a distance at which the guidance supposedly stops caring. It does not. An officer who sees a PC line that begins when the trailer was dropped and ends in the shipper's lot does not need a mileage debate. The destination is the business. Write the shipper's city on the driving line.

This page will not describe a route, a distance, or a wording that hides that destination. If the move is to the freight, log driving. If you are looking for a way to make the graph show off duty while the truck approaches the customer, stop. That graph is the violation.

What a carrier PC policy can add

A carrier may forbid personal conveyance. A carrier may limit true personal use to a shorter distance, a certain time of day, or bobtail only, or may require a call before the truck moves. Those are stricter rules. They are allowed. A carrier may not adopt a policy that calls deadhead to a pickup personal conveyance, may not hand out a mile budget for repositioning, and may not tell the driver the ELD has a PC button for getting closer to the morning load.

Put the policy in writing and match it to the guidance. If the policy is silent, the guidance still applies. Silence is not permission to invent a looser rule on the road. Safety departments that want a simple line can use this one: if the carrier benefits from the new location, it is not PC.

Training should use the company's own last three PC events. If they end at shippers, the policy is already being violated and the logs are already false. Fix the events. Do not add a paragraph that blesses them.

How the ELD annotation should read

When a move is truly personal, the annotation says where the driver went and that the driver was relieved of work. The steps for that annotation are on the ELD page linked above. When the move is bobtail to a pickup, there should be no PC annotation at all. The status is driving. The location remarks show the path from the current city to the shipper. The shipping paper, once it exists, belongs to that driving.

Do not annotate a deadhead with personal errand, commute, or heading home if the pin stops at the customer. Those words do not change the GPS. Roadside reviews compare the line to the movement. A note that contradicts the destination makes the record worse, not better.

If a real personal trip happens after the driver is released at a terminal, keep it separate from the deadhead that got the driver to the terminal. One continuous PC line that includes both the approach to the yard and a later grocery stop hides the business miles inside the personal ones. Split them. Driving for the carrier, then off duty, then PC if the later move qualifies.

Three examples: one yes, two no

Yes, when it is personal. The driver is released at the terminal, the carrier has no further dispatch, and the driver takes the unloaded truck to a restaurant and back to the lodging, with no freight purpose. That is the kind of off-duty personal use the guidance describes. Annotate it as personal. It is not a template for tomorrow's pickup.

No. The driver drops an empty trailer at a yard and bobtails 40 miles to the next shipper to make a morning appointment. The trailer is empty and the distance is short. Neither fact matters. The purpose is the pickup. The status is driving. Logging PC here is a false log. There is no revised wording that fixes it.

No. The driver finishes a delivery, keeps the truck, and moves 15 miles toward the next pickup city so the start is easier. The driver calls it getting closer and still off duty. Getting closer for the load advances the carrier's business. It is on-duty driving. The 15 miles count on the 11, inside the 14, and on the 60 or 70. Calling them PC does not pause or extend those clocks. It only conceals the time, which is the violation this page refuses to instruct.

After the real deadhead is on the driving line, the weekly recap and the 11-hour count both move. That is the point of correcting it. Leave the false PC in place and every later dispatch is planned on hours the driver already used. Fix today's status before you accept tomorrow's load.

Frequently Asked Questions