How do you split truck dwell time between the carrier and the warehouse?
Reviewed October 2026 · sources: FMCSA Federal Register notice, 49 CFR 395.2, ATRI · not legal advice
Short answer: use the appointment time as the line. Time the truck spends waiting because it came early, and delay caused by arriving late, is the carrier's. From the appointment (or the actual check-in, if that is later) until the driver has signed paperwork in hand, the clock is the warehouse's. No federal rule sets this split, so write down which timestamp starts and stops each segment before you start grading carriers or your own dock.
The question comes up on warehouse forums in a familiar shape: a site logs dwell in five segments but only grades three of them, and nobody agrees which segments belong to the carrier and which to the building. Here is a split most sites can defend, and the timestamps it needs.
The five segments and who owns them
| Segment | Starts / ends | Usually owned by |
|---|---|---|
| 1. Early arrival wait | Gate check-in → appointment time | Carrier (the truck chose to arrive early) |
| 2. Late arrival | Missed appointment → the new slot you give | Carrier. The warehouse clock usually restarts at the new slot |
| 3. Wait for a door | Appointment (or check-in, if later) → door assigned | Warehouse |
| 4. Door to unload done | Trailer at the door → unload or load finished | Warehouse (live load or unload) |
| 5. Paperwork | Unload done → signed bill of lading or receipt in the driver's hand → gate-out | Warehouse. The segment most sites forget to own |
Drop trailers are different: once the driver drops and leaves, the time the trailer sits in your yard is not driver dwell. Trailer and container charges for that time follow the equipment agreement instead.
Why there is no official split
The federal regulator has said the data to draw this line does not exist. In a 2019 request for information, FMCSA wrote that the earlier studies "were not able to separate normal loading and unloading times (e.g., the time it would usually take to load and unload a CMV under typical schedules) from detention time (delays in the start of the loading and unloading process which disrupt the driver's available driving and/or on-duty time)" and called it "a critical data gap" (FMCSA, 84 FR 26933 (June 10, 2019)).
The same notice asked the industry: "How do contract arrangements between carriers and shippers address acceptable wait times? Do these arrangements include penalties for delays attributable to a carrier or shipper?" In other words, the split lives in your contracts, not in a regulation.
Where the two-hour free time comes from
Two hours is the reference point most people use. The FMCSA-sponsored study cited in the same notice found that drivers "experienced detention time during approximately 10 percent of their stops for an average duration of 1.4 hours beyond a commonly accepted two-hour loading and unloading period" (FMCSA, 84 FR 26933 (June 10, 2019)). ATRI's 2024 research uses the same idea, counting time "detained at customer facilities for more than two hours", and reports that "In 2023, drivers reported being detained in 39.3 percent of all stops" (ATRI, September 2024).
Two hours is a convention, not a rule. If your contract or rate confirmation gives a different free time, grade against that.
The driver's clock runs either way
Whoever owns a segment, the driver's hours-of-service clock does not stop. Federal rules count as on-duty time "All time at a plant, terminal, facility, or other property of a motor carrier or shipper, or on any public property, waiting to be dispatched, unless the driver has been relieved from duty by the motor carrier" and "All time loading or unloading a commercial motor vehicle, supervising, or assisting in the loading or unloading, attending a commercial motor vehicle being loaded or unloaded, remaining in readiness to operate the commercial motor vehicle, or in giving or receiving receipts for shipments loaded or unloaded" (49 CFR 395.2, on-duty time items 1 and 5). That is why segment 5 matters: a driver waiting 30 minutes for a signature is burning hours the carrier can't get back. More on this in does waiting at the dock count against driver hours.
Pick one timestamp per boundary
Most dwell disputes are not about who owns a segment. They are about whose clock is right: the gate log, the driver's ELD, the carrier's GPS geofence, or the dock supervisor's sheet. Settle it once:
- Arrival: the gate check-in time, not the GPS geofence, unless your contract says otherwise.
- Appointment: the time in your scheduling system or appointment list, as confirmed to the carrier.
- Door assigned and at door: the time the dock or yard team records the move, on the same clock as the gate.
- Unload done and paperwork signed: written on the bill of lading or receipt with a time, not only a date.
- Departure: the gate-out time.
Write these five definitions on one page, share it with the carriers you work with most, and grade only the segments you own. Carriers get the same page, so their detention invoices and your logs use the same boundaries. If an invoice still doesn't match, see how to verify a detention invoice.
Where Vantage fits
Vantage records the two ends of this split: a timestamp at every gate-in and gate-out, taken on an iPhone or in the web dashboard, with a photo whenever the camera is used. The boundaries in between (door, unload, paperwork) you still define and record by your own process. The Free plan is $0 with no card: up to 3 users, 1 yard, 100 gate transactions a month and 30 days of history; paid plans start at $149 a month (pricing). There is no Android app.
Frequently asked questions
How do you split truck dwell time between the carrier and the warehouse?
Most sites use the appointment time as the dividing line. Waiting before the appointment because the truck came early, and any delay caused by arriving late, is the carrier's time. From the appointment (or the actual check-in, if later) until the driver has signed paperwork, the time belongs to the warehouse. Agree in writing which timestamp starts and stops each segment before you grade anyone.
Is there a legal rule for who owns dwell time?
No federal rule assigns dwell time to one side. FMCSA said in 2019 that the studies it had could not separate normal loading and unloading time from detention time, and it asked how contracts between carriers and shippers address acceptable wait times and penalties (84 FR 26933). The split is set by your contracts, rate confirmations and site rules.
How long is free time before detention starts?
Two hours is the common reference point. The FMCSA-sponsored study cited in 84 FR 26933 measured detention as time beyond a commonly accepted two-hour loading and unloading period, and ATRI's 2024 research counts drivers detained at customer facilities for more than two hours. Your contract may say something different.
Does the driver's hours-of-service clock stop while the warehouse is at fault?
No. Under 49 CFR 395.2, time waiting at a shipper's facility to be dispatched, and time attending a vehicle being loaded or unloaded or giving or receiving receipts, is on-duty time for the driver no matter whose delay it is.
Related: what is a good truck turnaround time · records for a detention claim · do shippers have to pay detention
Get your own gate-in and gate-out times
Free plan, no card, never expires. Up to 3 users and 1 yard.