The Electronic Logging Device (ELD) mandate applies to the majority of commercial motor vehicle (CMV) drivers who are currently required to maintain records of duty status (RODS). The Federal Motor Carrier Association (FMCSA) estimates the mandate will impact over 3 million trucks and 3.5 million drivers. Do you need to comply? Find out!
ELD Mandate Exemptions
Although the majority of drivers are impacted by the ELD mandate, the FMCSA has allowed for a few exemptions. We are regularly being asked questions about exemptions during our webinars and on social media, so we wanted to shed some more light on who is exempt.
Exemption 1: Drivers who are not required to keep records of duty status (RODS)
If you’re not currently required to keep RODS, you do not need to run an ELD. This includes short haul drivers, following hours-of-service rules. If you stay within a 100-air mile radius of your home termine, you do not need an ELD. You do need an ELD is you run outside of the short haul classification.
Exemption 2: Drivers who keep RODS no more than 8-days during a 30-day period
This one is pretty straight-forward. If you’re logging for less than 8-days during a 30-day period, you don’t need to run an ELD. Remember – this is a rolling window of 30 consecutive days, not within a specific month. Once you go over 8 days, you need to be running an ELD.
Exemption 3: Driveaway-towaway operations
If you’re a driver for a driveaway-towaway operation and the commercial motor vehicle (CMV) being driven is part of the shipment (empty vehicle for sale, lease or repair), then you are not required to use an ELD. This is because you don’t always know what make, model, of year of vehicle you’ll be driving and you’re not expected to carry multiple cables to plug in an ELD.
Exemption 4: Drivers of vehicles manufactured before year 2000 (1999 and older)
This has always been an exemption but was recently updated by the FMCSA to provide some more clarification around the required specs. If you’re driving a CMV that was manufactured before 2000, so 1999 or older, you will not need an ELD. This rules applies to the year of the engine within the CMV and not the body. Why? Many vehicles manufactured before 2000 do not have an electronic control module (ECM). ECMs are used to control engine performance, fuel efficiency, and emissions. An ECM provides the ELD with the data needed to comply with the mandate requirements.
But what about glider kits? A glider kit is essentially a new truck ordered from the factory without an engine or transmission. A rebuilt or remanufactured engine and transmission are then added to complete the truck. The ELD mandate applies to the engine year, not the model year of the truck. So, for example, if you’re running a 2003 body with a 1998 engine, you will not need an ELD.
Important Things to Remember
You still have to follow HOS rules if you’re exempt from the ELD mandate
The exemptions above relate specifically to the ELD mandate…you still need to comply with the hours of service (HOS) rules and keep simplified records (if required). Unfortunately, you don’t get to stop tracking your hours completely!
You can still run an ELD if you’re exempt from the ELD mandate
If you’re exempt, you’re not prohibited from running an ELD. In fact, many exempt fleets and owner-operators are opting to use ELDs because of the many benefits that they offer including reduced paperwork, improved accuracy, ability to maintain/improve CSA scores, and overall simplicity. Additionally, if there is a chance that you’ll run outside of an exemption, it’s better to have an ELD.
How BigRoad Can Help
With our DashLink ELD you have the option to run as an automatic onboard recording device (AOBRD) or an electronic logging device – putting you in control of your compliance. With an AOBRD, you can run with more flexibility for an additional two years before you need to transition to an ELD. More information on the benefits of AOBRDs can be found here or request a demo to see how easy compliance can be with us!