Opinion letter · United States · Wage and Hour Division

Wage and Hour Division says pre-shift client scheduling calls can make a field engineer's drive to the first job paid work time

As of our last check on November 2, 2026, this is agency guidance, not a rule. It explains how the agency reads the law and does not create a legal requirement on its own.

Added to AmendSignal

In short

What changed
The Wage and Hour Division (WHD) issued an opinion letter on how the Fair Labor Standards Act (FLSA) treats a field engineer's pre-shift pages, client scheduling calls and drive time in an employer-provided vehicle. It says receiving pages is unpaid, but scheduling calls are paid work. When those calls fill most of the hour before or during the drive, the drive to the first client site is paid too.
Who's affected
The letter answers one field service engineer's facts. It is most relevant to employers whose employees drive an employer-provided vehicle from home to client sites and must schedule appointments before or during that drive.
What to do
This letter creates no new legal requirement for employers. Employers with field staff who make required scheduling calls before or during their drive may want to review how that call time and the drive time that follows are recorded and paid.

What changed

Who is affected

What it means in practice

What to do

AmendSignal analysis sorts these by whether this document changes them.

Already required

Worth considering

Open questions

The source leaves these open. We'll update this record if a later document answers them.

  • How much time on calls during the drive is enough to make the whole drive after the first call paid time?

    WHD says it does not consider whether a smaller amount of call time while driving would change its conclusion.

  • Does paying a fixed shift plus overtime for travel beyond an hour cover all hours worked in this situation?

    WHD says it does not consider whether the employer's current pay practices are enough, because that would require more facts.

  • Is receiving pages still unpaid time if the vehicle is used outside the normal commuting area or without an agreement on its use?

    The letter's conclusion on pages assumes both conditions are met and does not address what happens if they are not.

Related changes

History

  1. Latest · · Issued

    FLSA2026-10: Whether time spent by an employee receiving pages, calling clients and other workers to schedule appointments, and driving from home to the first client appointment is worktime that an employer must record and pay for under the FLSA. Source (opens in a new tab)

Sources