Summary of Rules
Drivers may split their 10 hour required Shift reset period in 2 periods, providing one is at least a 7 hour SB and the other is at least a 2 hour OFF/SB. These 2 periods must add up to 10 hours. Neither time will count against the Shift time when the second period is completed.
One period must be be at least 2 hours and can be spent in the sleeper berth, off-duty, or personal conveyance (or a combination of the three).
The other period must be at least 7 hours and can only be taken in the Sleeper Berth.
The two breaks can be taken in any order and by completing both the periods, the 14-hour driving window is re-started from the end of the first split period, but not until after the second period is completed.
After completing both periods, neither period will count towards the driving window (Shift).
The 2+ hours of Off Duty will not pause the Shift clock unless it is paired with an appropriate 7+ hour SB period at a later time. Drivers should be aware of violations that may be present before the second split sleeper period is achieved.
- If a driver takes an 7+hour SB period first, then the 2+ hour Off Duty period, the Off Duty period will not be counted towards the shift in real time. There is no limit to how long each period can be. If a driver's "short" 2+ hour period is 9 hours, then that 9 hours will not be counted towards the shift.
- Since the 14-hour driving window does not restart after the end of the second period, the split sleeper berth is not a full 10-hour reset; it simply moves the start time of the 14-hour driving window.
- A driver is able to continuously run with split sleeper. When the Shift re-calculation point happens at the end of the first split sleeper period, the second split period can be paired with a third period, moving the Shift calculation period again.
- If a driver has 3 hours of Off Duty, then 7 hours of SB at a later point, the Shift moves forward to the end of the 3 hour period. A new Shift starts because of split sleeper.
- Then a driver has a later 3 hour Off Duty period. This 3 hour Off Duty period would pair with the earlier 7 hours of SB, and split sleeper would recalculate the Shift again, this time at the end of the 7 hours of SB.
Q: My driver is taking 2+ hours of Off Duty, but this is not pausing their Shift clock. Why is that?
A: The Samsara system is operating under the new HOS rules, which state that only when the two qualifying periods add up to 10 hours, do neither period count towards the driving window. Samsara has pessimistic clocks, meaning that we do not assume that a driver will take a split sleeper period at a later time, as many drivers take a 2+ hour break without attempting split sleeper. If Samsara were to pause the Shift clock before the later split sleeper period was met, then the system would possibly hide active violations. Samsara is taking a conservative approach here to enable drives to avoid driving in violation before they take a later 7+ SB period. When this later period is taken, we will recalculate the Shift and remove any violations that are no longer relevant. Drivers should make sure to annotate the first Off Duty period to indicate the intention to use split sleeper.
Q: Why do periods of 10+ hours count as eligible split sleeper periods? That wasn't the case in the old rules. Can you explain this?
A: The regulation prior to 9/29/2020 explicitly called out that split sleeper periods could be no longer than 10 hours. They have since removed this language from the regulation, as the desire is to make 10+ hour periods (both Sleeper Berth and Off Duty) eligible segments.
Pre 9/29/2020 Regulation:
(D) Must exclude from the calculation of the 14-hour period in § 395.3(a)(2) any sleeper-berth period of at least 8 but less than 10 consecutive hours.
(ii) Specific requirements. The following rules apply in determining compliance with paragraph (g)(1)(i) of this section:
(A) The term “equivalent of at least 10 consecutive hours off duty” means a period of
(1) At least 8 but less than 10 consecutive hours in a sleeper berth, and
(2) A separate period of at least 2 but less than 10 consecutive hours either in the sleeper berth or off duty, or any combination thereof.
Post 9/29/2020 Regulation:
(ii) Sleeper berth. A driver may accumulate the equivalent of at least 10 consecutive hours off-duty by taking not more than two periods of either sleeper berth time or a combination of off-duty time and sleeper berth time if:
(A) Neither rest period is shorter than 2 consecutive hours;
(B) One rest period is at least 7 consecutive hours in the sleeper berth;
(C) The total of the two periods is at least 10 hours;
Q: It seems that some of my drivers are not experiencing a Shift violation when they should. I suspect something might be going on with Split Sleeper. What could be going on?
A: If a driver takes their 10 hour Shift reset in Sleeper Berth, then that period is eligible as the 7+ hour Sleeper Berth period for split sleeper. Any 2+ off duty time during their "Shift" will not count towards the Shift clock. There is no duration limit to this 2+ hour period.
For example, if this second Off Duty is 9 hours, then none of those 9 hours will count towards the Shift. If 10 hours of Off Duty are accrued, then a Shift reset will happen.
How it works in Samsara
Samsara drivers need only to log their hours per the split sleeper rules. Samsara will calculate the split sleeper and recalculate the hours automatically when split sleeper conditions have been met.
Split Sleeper Berth Exception
Note: These rules have recently changed. To best understand the rule changes, it is helpful to see two example next to one another.
Old Rules: Dashboard Example
Old Rules: Driver App (Point 2)
14 Shift Limit - 7:30 Drive - 2:00 OFF = ~4:30 Shift remaining
11 Drive Limit - 7:30 Drive = ~3:30 Drive remaining
9/29 Rules: Dashboard
14 Shift Limit - 6:15 Drive - 0:13 ON = ~7:30 Shift remaining (Note: 3 OFF does not impact Shift Remaining)
11 Drive Limit - 6:15 Drive = ~4:45 Drive remaining