I clarified this direct with DOT back in 2009
The memory is the second thing that goes.
They're exempt from logbooks
Correct.
They are also exempt from the 30 minute rest period before 8 hours of on duty time.
And, as long as they are relieved of duty within 12 hours. Anyone working over 12 hours without taking a lunch until the end of day has violated HOS.
If all their time is counted as on duty driving wouldn't they be prohibited from working more than 11 hours a day?
Yes.
Package drivers don’t follow the 11 hour rule for exactly what 104feeder said
Incorrect.
They are still subject to only 11 hours of driving.
it has to do with the short amount of time between stops that package drivers are physically driving.
Correct.
But they still must follow 11 hours of driving time.
Even working 14 hours, no package driver will drive for more than 11 hours, but, the 11 hour rule still applies.
Just that over the course of a 14 hour day (basically your worst nightmare/peak) you will undoubtedly spend at least half that time in parked, sorting, delivering, etc. which means in nearly every case you are not at risk of driving past 11 hours in a day.
Correct.
Even if you are not spending half your time not driving.
Just a quarter of the time not driving, say a 200 mile 60 stop country route, you will never exceed 11 hours drive time.
I understand that package drivers don't follow the 11 hour rule
Incorrect.
I believe I clarified other than break and meal time.
You did, and you are correct, on this point.
But, all other time for a package driver is considered on duty, not on duty-driving as you posted.
otherwise please cite your basis
Electronic Code of Federal Regulations
PART 395—HOURS OF SERVICE OF DRIVERS
§395.1 Scope of rules in this part
(e) Short-haul operations—(1) 100 air-mile radius driver. A driver is exempt from the requirements of §§395.8 and 395.11 if:
(i) The driver operates within a 100 air-mile radius of the normal work reporting location;
(ii)(A) The driver, except a driver-salesperson or a driver of a ready-mixed concrete delivery vehicle, returns to the work reporting location and is released from work within 12 consecutive hours;
(B) The driver of a ready-mixed concrete delivery vehicle returns to the work reporting location and is released from work within 14 consecutive hours;
(iii)(A) A property-carrying commercial motor vehicle driver, except the driver of a ready-mixed concrete delivery vehicle, has at least 10 consecutive hours off duty separating each 12 hours on duty;
(B) A driver of a ready-mixed concrete delivery vehicle has at least 10 consecutive hours off duty separating each 14 hours on duty;
(C) A passenger-carrying commercial motor vehicle driver has at least 8 consecutive hours off duty separating each 12 hours on duty;
(iv)(A) A property-carrying commercial motor vehicle driver, except the driver of a ready-mixed concrete delivery vehicle, does not exceed the maximum driving time specified in §395.3(a)(3) following 10 consecutive hours off duty;
And here is §395.3(a)(3)
(3) Driving time and rest breaks. (i) Driving time. A driver may drive a total of 11 hours during the 14-hour period specified in paragraph (a)(2) of this section.