Travel between job sites can count as hours worked, but the trip from home to the first site is ordinary commuting. Cornell Law School states that normal travel from home to work is not worktime.
Key takeaways for travel time between work sites during the workday
- Mark the drive from home to the first job site as ordinary commuting, which is not hours worked according to Cornell Law School.
- When an employee must return to the employer's premises after finishing a later job, all of the time is working time, as stated by Cornell Law School.
- Plan to pay for travel to an alternate site over 30 miles from the normal fixed work location when the employer requires it, since the Oregon Bureau of Labor and Industries says employers generally must pay for that travel.
- Exclude the travel time between home and the job site from work time, noting that commuting does not count as work time according to the District of Columbia Office of the Attorney General.
Which trips between sites these pages count as hours worked
The federal regulation defines ordinary commuting as a normal incident of employment, meaning it is excluded from paid hours. This baseline rule applies when the person starts and ends their day at their residence.
When the day involves moving between different locations after the initial arrival, the classification changes. The distinction hinges on whether the person must return to the employer's premises to do the day's work. If the schedule requires them to go from one job site to another during the workday, that inter-site travel can be counted as hours worked. However, if they go home from the later job instead of returning to the main premises, the travel back to the residence reverts to ordinary commuting status. You must look at the endpoint of each trip segment to determine its payability. A trip that connects two work locations within the same shift operates differently than a trip that concludes with the person going home.
A filled reference table of the four travel rules
The following table summarizes how different publishers define when travel time counts as hours worked. Each row ties a specific rule to its source publisher and provides a summary of the quoted language used to establish that standard.
| Publisher | Rule Stated | Source Quote Summary |
|---|---|---|
| Cornell Law School | Ordinary home-to-work travel is not work time. | Describes commuting from home before the regular workday and returning home at the end as ordinary travel. |
| Cornell Law School | Travel after a later job is work time if the employee must return to the employer's premises. | States that if an employee finishes one job and is sent to another, then required to return to the employer's premises, all that time is working time. |
| Oregon Bureau of Labor and Industries | Travel to an alternate site over 30 miles from the normal fixed work location is generally paid. | Notes that employers generally must pay for travel time when requiring report to an alternate site over 30 miles away. |
| District of Columbia Office of the Attorney General | Commuting between home and job site does not count as work time. | Explicitly states that commuting, defined as travel time between home and the job site, does not count as work time. |
Ordinary travel from home to work
Before you approve a timesheet that includes driving time, you must distinguish the trip from home to the first job site from any other movement during the day. The federal rule on this topic is clear: an employee who travels from home before his regular workday and returns to his home at the end of the workday is engaged in ordinary home to work travel which is a normal incident of employment Cornell Law School.
The key distinction for your schedule is the starting point and ending point of the day’s travel. If your hourly staff member leaves their residence to go to Site A, that drive is commuting. You should not mark the morning drive from home to the first site as paid hours, nor the evening drive from the last site back home. These segments are excluded from the calculation of hours worked because they are part of the standard daily commute structure described in the regulation.
Travel from one job site to another in the same day
When an employee moves between two jobs during a single workday, whether that travel counts as hours worked depends on where they go after finishing the second job. Cornell Law School distinguishes between returning to the employer's premises and going home instead. This distinction determines if the time spent driving or commuting is compensable work time for your hourly staff.
According to Cornell Law School, if an employee normally finishes their first job at 5 p.m. and is sent to a second job which they finish at 8 p.m., the status of the subsequent travel hinges on the requirement to return. If the employee is required to return to their employer's premises and arrives there at 9 p.m., all of that time is considered working time. This includes the work performed at both sites, and the travel between them and back to the main premises. The key factor here is the obligation to report back to the employer's location before the day ends.
However, the situation changes if the employee does not have to return to the main premises. According to Cornell Law School, if the employee goes home instead of returning to their employer's premises after finishing the second job at 8 p.m., the travel after 8 p.m. is classified as home-to-work travel and is not hours worked. The final leg of the journey from the last job site to the employee's residence is treated as ordinary commuting, which is generally unpaid.
For managers approving timesheets, this means you must verify the destination after the second job. If the schedule requires the worker to check in at the main office or warehouse, the time from the end of the first job through arrival at the main premises is compensable. If the worker is free to go directly home from the second site, the clock stops when they leave the second site, and the drive home is excluded from paid hours. Always confirm whether the "return to premises" condition applies to the specific assignment before marking the inter-site travel as paid.
A one-day trip to another city and Oregon's 30-mile line
When a regular worker gets a special one-day assignment in a different city, the federal rule treats that travel differently from a normal commute. According to Cornell Law School, this situation arises when an employee who usually works at a fixed location in one city is sent to work for a single day in another city. The source provides a specific example to illustrate how the hours are counted. In that scenario, an employee based in Washington, DC, with regular working hours from 9 a.m. to 5 p.m., receives instructions to leave Washington at 8 a.m. for a special assignment in New York City. The employee arrives in New York at 12 noon, ready for work. The special assignment finishes at 3 p.m., and the employee arrives back in Washington at 7 p.m. You should not apply these specific clock times to your own shop’s schedule; they exist only to demonstrate the concept of a special one-day assignment away from the normal base.
Oregon has its own distinct threshold for when travel time must be paid. The Oregon Bureau of Labor and Industries states that if an employer requires a worker to report to an alternate work site over 30 miles away from their normal fixed work location, the employer generally must pay for that travel time. If you manage staff in Oregon, check whether the destination site falls outside this 30-mile radius before deciding if the drive counts as hours worked. For teams operating across multiple jurisdictions, remember that the federal example and the Oregon rule address slightly different triggers: the federal rule focuses on a special one-day assignment in another city, while the Oregon rule focuses on the distance from the normal fixed location. Keep each rule tied to its specific publisher and jurisdiction when reviewing timesheets. Do not assume that every minute in a car during these trips is automatically paid without checking the specific conditions listed by the relevant authority.
How to sort today's site-to-site trips
Sort each trip before you approve the hours. Oregon Bureau of Labor and Industries states that travel between worksites includes travel within a single day between multiple work sites. Label each trip as either commute or site-to-site travel based on that definition.
Note the start site and next site for every person who changed locations today. For location records, see geofencing checks for accurate time tracking. If the trip is part of the daily route between job sites, record it as site-to-site travel according to the Oregon page. Do not mark the initial drive from home as site-to-site travel. Once every trip is labeled, move to your timesheet approval and edit rules to verify the entries match the clock records.
FAQ: Travel time between work sites during the workday
What does the federal home-to-work page say about ordinary commuting?
According to Cornell Law School, an employee who travels from home before their regular workday and returns home at the end of the day is engaged in ordinary home-to-work travel. The source describes this specific type of movement as a normal incident of employment. The source states this is true whether the employee works at a fixed location or at different job sites, so the home-to-work rule covers the home-to-first-site and last-site-to-home legs, while trips between sites are governed by the same-day travel rules.
What does the same-day travel page say if the person must return to the employer's premises after a later job?
If an employee finishes a later job and is required to return to the employer's premises, Cornell Law School states that all of the time is working time. The example provided involves a worker finishing a second job at 8 p.m. and returning to the premises by 9 p.m. In this scenario, the travel time back to the original location counts as hours worked because the person was required to be there.
What does it say if the person goes home from that later job instead?
When the employee goes home instead of returning to the employer's premises after the later job, Cornell Law School notes that the travel after 8 p.m. is home-to-work travel. Consequently, this specific segment of the journey is not hours worked. The distinction relies on whether the final destination is the employer's site or the employee's residence.
What distance does the Oregon page name for a one-day assignment away from the normal site?
The Oregon Bureau of Labor and Industries names 30 miles as the threshold for a one-day assignment away from the normal fixed work location. If an employer requires reporting to an alternate site over 30 miles away, they generally must pay for that travel time. This rule specifically addresses assignments that are significantly farther from the usual workplace.
What does the District of Columbia page say about commuting and travel between two work sites?
The District of Columbia Office of the Attorney General states that commuting, defined as travel between home and the job site, does not count as work time. However, the same source indicates that time spent traveling for the employer’s business, such as travel between two work sites, does count. Managers should distinguish clearly between leaving the home base and moving between active work locations when reviewing timesheets.