Field supervision + payroll · 8 min
Truck-driver coverage questions
Truck-driver coverage is fact-dependent. A driver may spend time delivering from offsite, moving material within the site, working at a dedicated support site, or performing non-delivery construction work.
Those activities should be recorded separately. A single “driver” label is not enough to decide coverage or the correct classification.
Capture the route and activity
Record the employer, origin, destination, relationship of support sites to the project, time on the site, material moved, and any installation or other construction work. Coverage can differ across those activities.
When a driver performs non-delivery construction work, analyze that time like the same work performed by any other laborer or mechanic.
Keep current litigation and contract dates visible
DOL’s current resource book notes a 2024 preliminary injunction affecting parts of the 2023 rule, including a truck-driver provision. Do not reduce this area to a fixed yes-or-no shortcut.
CWHSSA overtime analysis is not limited in the same way as Davis-Bacon’s site-of-the-work coverage. Preserve all covered contract hours needed for the overtime review.