Who this is for: CDL drivers, owner-operators, fleet managers
Personal Conveyance and ELD — Off-Duty Use of a CMV
Personal conveyance (PC) allows a driver to use a commercial motor vehicle for personal purposes while genuinely off duty, with that movement recorded as off-duty time on the ELD. FMCSA guidance specifies that the driver must be completely relieved of all duty and responsibility. Driving a loaded trailer, moving at a carrier's direction, or using PC to extend a shift that has reached its limits are not appropriate PC uses.
Important Notice
Personal conveyance is governed by FMCSA guidance rather than a specific regulatory text. Guidance can change. Verify current FMCSA PC guidance at fmcsa.dot.gov before relying on PC in unusual situations.
What personal conveyance is and why it matters
Personal conveyance is the use of a commercial motor vehicle for personal reasons while the driver is completely relieved of all duty and responsibility for the carrier. Because the driver is off duty, the movement logs as off-duty time on the ELD — it does not count toward the 11-hour driving limit or the 14-hour on-duty window. The vehicle is moving, but the driver is not performing a safety-sensitive function in the regulatory sense. FMCSA addresses PC through guidance documents rather than a dedicated regulation; the underlying basis is the definition of on-duty time in 49 CFR 395.2, which excludes genuinely off-duty activity.
How PC affects the HOS record
PC time does not consume driving time or on-duty window time — it records as off-duty. It does count toward the 10-consecutive-hour off-duty reset (or 8-hour reset for passenger carrier drivers). This means a driver who uses PC to drive to a truck stop after being released for the day is logging that movement as part of their off-duty rest period. The ELD records the vehicle location throughout PC, so the movement is visible in the carrier's back-office system and in any inspection of the records. PC is not invisible movement; it is documented off-duty movement.
What FMCSA considers appropriate PC use
FMCSA guidance identifies several scenarios that qualify as legitimate PC: driving to a nearby restaurant, hotel, or rest area after being relieved of duty at a delivery or terminal location; driving home after being released by the carrier for the day; and driving a short distance to reach a parking location when the nearest available compliant parking is not immediately adjacent to the driver's current location. The common factor is that the movement serves the driver's personal interest and is not advancing the carrier's commercial operation.
What does not qualify as personal conveyance
FMCSA has been explicit on several scenarios. Driving a loaded trailer is not PC — the driver is transporting the carrier's cargo, which is a commercial function regardless of the driver's claimed duty status. Moving the truck because the carrier or dispatcher directs it — even if labeled as "personal conveyance" — is not PC. Using PC to travel from the end of one dispatch to the start of the next when that travel benefits the carrier's operation is not PC. And using PC immediately after exhausting daily driving or on-duty limits raises immediate questions about whether the driver is genuinely off duty or using the status to circumvent HOS.
The loaded trailer question
Whether an empty trailer affects PC eligibility is a more nuanced question than the loaded case. FMCSA's general position is that driving a loaded trailer under PC is inappropriate. For empty trailers, context matters: if the carrier directed the driver to reposition an empty trailer for the carrier's next operation, that movement serves the carrier's interest and should be logged as on-duty driving. If a driver is bobtailing or has an empty trailer attached and is genuinely traveling for personal reasons with no carrier direction, the empty trailer attachment alone does not automatically disqualify the move as PC. Many carriers resolve the ambiguity with a written policy that prohibits any PC with a trailer, loaded or empty.
Carrier PC policies
Carriers can be more restrictive than FMCSA guidance. Some prohibit any PC with a trailer attached. Some cap PC at a specific mileage per 24-hour period. Some require drivers to document PC use on trip reports. These policies are within carrier authority and do not conflict with federal rules. Drivers who violate a carrier's PC policy may face employment consequences even if the movement would technically qualify as appropriate PC under FMCSA guidance. Review the carrier's policy when starting a new position and ask if it is not provided.
Yard moves versus personal conveyance
Yard move (YM) is a separate ELD status for maneuvering a CMV within a terminal or facility. YM records as on-duty not driving — it does not count toward the driving limit, but it does count toward the 14-hour window and the weekly cycle. YM is for low-speed maneuvering on private property; PC is for movement on public roads when genuinely off duty. Using YM status while operating on a public road is a misuse of the status. An investigator reviewing records with YM logged during movement on a public highway will treat that time as on-duty driving.
At roadside with PC logged
PC is visible as a distinct duty status on the ELD display and in any data transfer. Inspectors are trained to review PC patterns — specifically, whether PC appears immediately after a driver has reached their daily driving limit or on-duty window. A driver who logs 11 hours of driving, then switches to PC and drives another 90 minutes to a truck stop, is in a difficult position to explain. Legitimate PC is typically short in distance and clearly separated from the work portion of the day by events the inspector can verify: arrival at a delivery point, a duty status change to off-duty, and then a short PC movement. Documenting the reason for PC use — in a note field on the ELD or in a trip log — protects the driver when questions arise.
Frequently Asked Questions
Can a solo owner-operator use PC when relocating an empty truck to a better parking spot?
Driving to a legal, safe parking location when the current location does not offer adequate parking is a scenario FMCSA has acknowledged as appropriate PC. The distance should be proportionate to the need. Driving across a state to reach a preferred location would not meet the standard; driving 5 miles from a rest stop that is full to the next available rest area is a different situation.
Does using PC reset the 10-hour off-duty requirement?
PC time counts as off-duty time toward the 10-consecutive-hour reset requirement. A driver who spends the first 30 minutes of their off-duty period driving to a truck stop under PC and then sleeps for 9.5 hours has taken a 10-hour off-duty period. The PC movement does not restart the clock or disqualify the off-duty period — it is part of it.
Can PC be used to commute to a pick-up location in the morning?
It depends on the circumstances. A driver who is fully off duty, has no pending dispatch instructions, and uses their personal truck to drive from home to a terminal before accepting any dispatch is in a different position than a driver who is already assigned a load and drives to the pick-up location before logging on duty. FMCSA guidance indicates that if the movement is made at the carrier's direction or to advance a dispatch the driver has already accepted, it is not PC.