The restart exception most haulers can use
Under 395.1(d)(1), a driver of a commercial motor vehicle used exclusively in transporting oilfield equipment or servicing field operations may end any period of 8 consecutive days with an off-duty period of 24 or more successive hours. FMCSA's 2012 guidance, retained in 2013, confirms the restart covers a broad range of vehicles in direct support of well sites, including trucks moving equipment, supplies, and water to the site and waste or product away from it.
The waiting time exception is about the equipment, not the load
The second exception, 395.1(d)(2), applies only to operators of vehicles specially constructed for well-site use that require extensive training beyond driving, such as heavy-coil vehicles, missile trailers, nitrogen pumps, wireline trucks, sand storage trailers, cement pumps, frac pumps, blenders, hydration pumps, and separators. For those drivers, time spent waiting at the well site is not counted as on-duty, as long as no work is performed. FMCSA is explicit that drivers of modified trucks hauling sand or water do not qualify, even with some extra training in running pumps.
Where fleets get caught
The mistake is applying the waiting-time exception to a driver who then loads, runs a pump, or does any work activity, because any work puts that driver on duty. Overstating the exception shows up as 395 violations in a DOT audit and as an unsafe driver behind the wheel. The fix is training dispatchers on the difference between the two exceptions and keeping duty status honest load by load.
The HOS exceptions interact with the rest of the compliance stack an oilfield carrier carries: ELD records, driver qualification files, and ELDT training records for new hires. If duty status is decided by memory instead of the log, an operations audit will show which drivers are legally available for the next load.