<< Home

ELD Exemptions: Frequently Asked Questions on the ELD Mandate

ELD Exemptions: Frequently Asked Questions on the ELD Mandate

Who is exempt from the electronic logging device (ELD) rule? Many people have been asking questions about ELD exemptions ever since the Federal Motor Carrier Safety Administration (FMCSA) announced the ELD mandate for carriers and drivers. Electronic logging devices, also known as ELDs or e-logs, are devices that automatically record drive time and hours of service (HOS) for drivers.

In this post, we’ll walk through the different types of exceptions. Understanding the difference can save you from making a costly mistake.

Who Does the ELD Rule Impact?

First, let’s take a look at who is impacted. The ELD rule applies to commercial motor vehicles. As defined by the FMCSA regulations §390.5, a commercial motor vehicle (CMV) is “any self-propelled or towed motor vehicle used on a highway in interstate commerce to transport passengers or property when the vehicle—

  1. Has a gross vehicle weight rating or gross combination weight rating, or gross vehicle weight or gross combination weight, of 4,536 kg (10,001 pounds) or more, whichever is greater; or
  2. Is designed or used to transport more than 8 passengers (including the driver) for compensation; or
  3. Is designed or used to transport more than 15 passengers, including the driver, and is not used to transport passengers for compensation; or
  4. Is used in transporting material found by the Secretary of Transportation to be hazardous under 49 U.S.C. 5103 and transported in a quantity requiring placarding under regulations prescribed by the Secretary under 49 CFR, subtitle B, chapter I, subchapter C.”

The bottom line is that it doesn’t matter if you operate a tow truck, dump truck, garbage truck, or a cement mixer — if your vehicle meets one of the criteria above, and you are performing work as part of your job, you may be affected by the mandate.

dump truck garbage truck cement mixer heavy truck eld exemptions

Related: What is an ELD?

Who Is Exempt? Overview of ELD Exemptions

Here is the official list of ELD mandate exceptions from the FMCSA’s website:  

  • Drivers using paper RODS no more than 8 days out of every 30 day period.
  • Driveaway-towaway drivers who transport empty vehicles intended for sale, lease, or repair, as long as the vehicle they are driving is part of the shipment.
  • Drivers of vehicles manufactured before model year 2000.

It’s important to note that if drivers are not required to use ELDs, they are not fully exempt from the regulations. They must still record their duty status manually (on paper) according to 49 CFR 395.

Let’s dive into some further questions:

What is the Short-Haul / 100 Air-Mile Radius Exception?

There are a number of requirements to qualify for the short-haul exception from §395.1(e):

  • Operate within a 100/150 air-mile radius of the normal work-reporting location (100 air-miles if you are a commercial driver’s license (CDL) driver and 150 air-miles for drivers without a CDL).
  • Start and return to the same location.
  • 12 consecutive hours of duty time.

An air mile equals 115.08 statute miles (185.2 kilometres), according to FMCSA regulations. It is based on the international nautical mile which is 6,076 feet (1,852 meters).

These additional rules also apply to short-haul drivers:

  • Drive time cannot exceed 11 hours.
  • Must log a minimum of 10 consecutive hours of off-duty time after shift.

If the driver cannot meet these conditions, they will have to complete a logbook for the day as the vehicle is considered a CMV.

The vehicle and trailer are also subject to vehicle inspection as per §396.11 and §396.13 if they collectively meet the criteria of a CMV. A DVIR (Driver Vehicle Inspection Report) will need to be filled, and stored. The next time the vehicle and/or trailer is used, the previous Driver Vehicle Inspection Report (DVIR) must be reviewed prior to operation.

You must store the log records, and the inspection report records, and present it both to law enforcement as well as in the time of a carrier audit.

Does the Pre-2000 Exemption Apply to Model Year or Date of Manufacture?

When the ELD mandate was first released, there was discussion in the media about whether an exception for pre-2000 vehicles referred to model year or date of manufacture. On their website, the FMCSA clarifies that the exception applies to the vehicle’s engine model year. Quoting from the FMCSA, “If the engine model year is older than 2000, the driver is not subject to the ELD rule.”

Is it possible to gain an exemption by using a glider kit (new cab and chassis) with an older engine and vehicle components? Yes, the FMCSA states that the model year on the engine can be used to determine if the driver is exempt from the ELD requirements.

Motor carriers must maintain all documentation on motor and engine changes at their principle place of business, but the driver is not required to carry documentation confirming the vehicle engine model year. However, even though it’s not mandatory for the driver to possess the documentation, it would be a good idea to have it in the event of roadside inspection.

Do Small Carriers Need to Comply with the ELD Rule?

Two surveys last year showed that small carriers are more reluctant to make the move to ELDs. A Transplace survey of more than 400 carriers found that only 33% of small fleets (with less than 250 trucks) had fully installed ELDs, while 38% had “no immediate plans to begin implementation.”

In Land Line magazine, Tyson Fisher reports on a TruckStop.com survey of over 1,000 trucking operators (majority of those owning one to five trucks) which found that 84% had not yet purchased or installed an electronic logging device.

Again, carriers and drivers who are required to maintain RODS, and do not fall under any of the above exceptions, are subject to the ELD rule.

Could a Pickup Truck or Small Vehicle Qualify as a Commercial Motor Vehicle?

The answer to this question on ELD exemptions is related to the Gross Vehicle Weight Rating (GVWR) and Gross Combination Weight Rating (GCWR).

Gross Vehicle Weight Rating (GVWR) Vs. Gross Combination Weight Rating (GCWR):
GVWR is defined as the maximum operating weight of a vehicle as set by the manufacturer including the vehicle itself (chassis, body, engine, engine fluids, fuel and accessories), including the weight of the driver, passengers, and cargo. GCWR is the manufacturer’s specified maximum weight for a vehicle that is towing a trailer (includes the weight of the vehicle, driver, passengers and cargo, plus the attached trailer with load).

Vehicles are often specialized to deliver different types of goods. Semi-trailers can be outfitted with various trailers such as box trailers, flatbeds, car carriers, tanks, and other specialized trailers. Dump trucks and concrete mixers are examples of vehicles specialized for delivery of specific types of goods.

If the GVWR/GCWR of the truck, load, and any trailer (inclusive of load) you are transporting at any point in time exceeds the 10,001 pounds or greater definition of CMV found in §390.5, it will become a CMV. That vehicle would be regulated empty or loaded.

When you find your vehicle, even if it’s a pickup, is now classified as a CMV, the driver of the vehicle must comply with the hours of service regulations. During the time you meet the criteria of a CMV, you need to obey all regulations, which may include stopping at roadside inspection stations or having U.S. Department of Transportation (U.S. DOT) markings on the side of the truck.

ELD Compliance Brings Benefits to Motor Carriers

The first compliance deadline is quickly approaching. Carriers and drivers currently using paper logs (or logging software) must switch to ELDs by December 18, 2017. The time to research ELD compliance solutions is now. Adopting ELDs offer so many benefits, such as driver safety and fuel usage monitoring, to name two. Not complying with the rule is just not worth the risk.

Related Posts:
E-Logs: New Opportunities for Trucking
e-logs electronic logging devices for trucking

IFTA Reporting and the ELD Mandate

Remote Diagnostics for Commercial Trucks
remote diagnostics commercial trucks

While Geotab recognizes our place as a self-registered ELD manufacturer and provider and we will answer questions regarding those Hours of Service (HOS) ruleset options we provide, neither Geotab nor any of its employees, officers or agents can offer legal advice to any resellers or customers concerning which HOS ruleset(s) or exemption(s) may apply to any particular situation. Please contact your local DOT department or refer to the FMCSA website at https://www.fmcsa.dot.gov/ for questions Geotab is unable to answer.

200 Comments

  • Posted September 25, 2018 at 7:57 am | Permalink

    I have a 4 horse trailer with a living quarter and I pull this with my Sportschassis Freightliner. I have a CDL I only take my own personal horses to horse shows or elsewhere around the USA. I ride my horses as an amateur and do not get paid. Do I need an ELD.

  • Posted August 20, 2018 at 2:53 pm | Permalink

    Is the 12 hour duty time driving or all working hours?

    • Posted August 29, 2018 at 1:54 pm | Permalink

      All working hours, the 11 hour driving limit still applies.

  • Posted July 26, 2018 at 8:07 am | Permalink

    Do you need to do edl log everyday if you do a timesheet

    • Posted August 29, 2018 at 1:57 pm | Permalink

      Depending on if you fall under a short haul exemption at all times, possibly no. For further detail, contact your local FMCSA field office regarding your specific situation.

  • Posted July 19, 2018 at 10:24 pm | Permalink

    I tow my own personal equipment, boats, trailers, etc..Using my own personal trucks. All registered in my name all for completely personal use, but over 10000 GCW. Do I need a ELD?

    • Posted August 30, 2018 at 12:53 pm | Permalink

      The ELD rules only apply to commercial vehicles.

  • Posted July 11, 2018 at 12:38 pm | Permalink

    Hello,

    We have several rental tractors in where we have ordered ELD’s; however, we have been told of a three to four week backlog on the units. We have been told that if the driver presents the purchase order this would suffice. Any help would be greatly appreciated.

    • Posted August 30, 2018 at 12:55 pm | Permalink

      You should speak to the enforcement party in your state for details.

  • Posted April 27, 2018 at 8:45 am | Permalink

    We have a driver that only drives every now and then, he mostly works as a mechanic. is he required to login and put himself on duty not driving every day or does he login only when he is driving?

    • Posted July 10, 2018 at 12:38 pm | Permalink

      This would depend on whether he needs to log HOS at all (is he able to use an exemption like short haul), and if he needs to log, is it more than 8 days in a rolling 30? We would suggest reaching out to your local FMCSA field office for guidance.

  • Posted April 20, 2018 at 8:46 am | Permalink

    There is no mention of weight in the ruling for eld usage. So your first statement is incorrect

    • Posted July 10, 2018 at 12:43 pm | Permalink

      The reference to gross vehicle weight rating, gross combination weight rating, gross vehicle weight and gross combination weight are taken from the definitions of a commercial motor vehicle (CMV) and not the ELD rule.

      We appreciate the feedback. Please keep checking back on Geotab.com/Blog for more ELD-related articles.

  • Posted April 19, 2018 at 8:32 am | Permalink

    I am work in a fleet of Hocking College in Ohio. We have one coach bus and have a trip that is 2 weeks long, this is not normal, and a one time thing. Could you please tell me what is the best solution to our dilemma?

    • Posted May 25, 2018 at 3:19 pm | Permalink

      This would depend on many factors and Geotab is unable to provide advice in this way. Please seek an answer to your specific question via the FMCSA website or your local FMCSA field office.

  • Posted April 16, 2018 at 7:50 pm | Permalink

    I have an f350 (gvwr 11,500) that I use to haul my mobile stage (gvwr 20,000lbs) to events. The truck has a gcwr of 28,700lbs. The truck itself weighs 7452lbs and the trailer weighs 14,000lbs empty. My loaded truck and trailer combination will unlikely ever exceed 26,000lbs. I haul my stage less than 7500 miles per year. Basically once a week (to and from a location) for 3-4 months per year. I have a CDL and my truck is DOT’ed. Am I exempt from the ELD? The 8 days in 30 days would possibly happen in a given 30 day period but if figured on a yearly average, it would certainly put me in the exempt category. Please advise.

    • Posted April 19, 2018 at 11:08 am | Permalink

      Unfortunately, Geotab is unable to give advice on specific scenarios due to legal reasons.

      Please speak to the FMCSA directly via their website or your local field office for answers to your specific business requirements.

  • Posted April 13, 2018 at 5:00 pm | Permalink

    How many personal exemptions can I use on a electronic logbook?

    • Posted April 19, 2018 at 11:08 am | Permalink

      Usually, you only need to be exempt from the ELD mandate once — however you may be exempt from ELD for one reason for one part of your month, and then exempt for different reasons in the other part. For details, please speak to the FMCSA directly via their website or a local field office.

  • Posted April 12, 2018 at 6:41 pm | Permalink

    I haul fresh seafood do I need a eld

    • Posted April 19, 2018 at 11:06 am | Permalink

      There are many potential exemptions depending what, where, and how often you drive. Please reach out to your local FMCSA field office or the FMCSA website for specific scenarios regarding your business.

  • Posted April 10, 2018 at 1:36 pm | Permalink

    We have 8 semi trucks. We haul oilfield equipment. We travel not more than a 200 mile radius. We do not cross state lines. During a routine inspection at the scales. A DPS officer told an employee the ELD would not affect us since we are intrastate commerce and not interstate commerce. How true is this and are we required to have an ELD in place?

    • Posted April 19, 2018 at 11:06 am | Permalink

      It is true that drivers participating exclusively in intrastate commerce do not need an ELD. We suggest that you reach out to your local FMCSA field office or the FMCSA website for specific scenarios regarding your business.

  • Posted April 9, 2018 at 10:39 am | Permalink

    For specific answers on compliance, please reach out to your nearest FMCSA Field office or the FMCSA website.

  • Posted April 5, 2018 at 10:33 pm | Permalink

    Is there an exemption card required inside the commercial vehicle if it is exempt from the ELD?

    • Posted May 25, 2018 at 3:19 pm | Permalink

      Most time, yes. It does depend on the individual exemption however, so check with the FMCSA for specific questions on specific exemptions.

  • Posted April 4, 2018 at 4:52 pm | Permalink

    Good Afternoon,

    One of our drivers was stopped by DOT and was told by them that Texas is exempt of the ELD devices for now. Is this true? We haul FOK from Dallas to Lubbock/Amarillo as well as Dallas to Laredo lane with the reloads back to Dallas.

    • Posted May 25, 2018 at 3:21 pm | Permalink

      We are unaware of any state that is exempt from the Federal ELD mandate. However, if you are not partaking in interstate commerce, you would not need an ELD under the normal ELD exemptions.

  • Posted April 1, 2018 at 8:05 pm | Permalink

    I haul over sizes loads do I have to have e logs

    • Posted May 25, 2018 at 3:23 pm | Permalink

      This would depend on how often and where the hauling is taking place. Please contact the FMCSA or your local FMCSA field office for guidance.

  • Posted March 28, 2018 at 4:10 pm | Permalink

    Are hotshot drivers in straight trucks that don’t have set schedules in any way exempt. We have deliveries only when a customer calls? Our trucks are less than 26,000 lbs gvw

    • Posted May 25, 2018 at 3:26 pm | Permalink

      This would depend entirely on how many days the drivers need logs, where they are driving and what. There is no exemption specifically for ‘unscheduled drivers or similar.’ Please contact the FMCSA or your local FMCSA field office for guidance.

  • Posted March 27, 2018 at 1:37 pm | Permalink

    My company specializes in telecommunications repair and maintenance (no installation). I have seen reports that telecom companies are exempt from the EDL mandate. Would we be exempt? And do you have to register or apply to be exempt, or is it automatic? Thanks

    • Posted July 10, 2018 at 12:44 pm | Permalink

      There are many exemptions, some are permanent, some for specific scenarios. Your best course of action would be to contact your local FMCSA field office and ask them for guidance.

  • Posted March 26, 2018 at 12:07 pm | Permalink

    We haul ag products and sometimes when hauling seed we only haul four months out of the year and cross state lines.we are on the short haul exemption. Can I use paper logs.if I have to use elogs do i have to use them all year.

    • Posted July 10, 2018 at 12:50 pm | Permalink

      The agriculture industry has numerous exemptions depending on the time of year, product hauled, destination and distance. Your best course of action would be to contact your local FMCSA field office and ask them for guidance.

  • Posted March 22, 2018 at 7:23 pm | Permalink

    If I cover up my DOT number and driving my tractor trailer can I be on personal with truck or will that effect my hours for the day

    • Posted May 25, 2018 at 3:26 pm | Permalink

      Unfortunately Geotab is unable to answer questions related to specific scenarios. Please contact the FMCSA or your local FMCSA field office for guidance.

  • Posted March 22, 2018 at 7:09 pm | Permalink

    I work for a tree nursery that does travel beyond the 100 air miles and uses tractor trailers and 26000 gvw straight trucks. Drivers of the straight trucks do not have cdls. Drivers do drive more than 8/30 days. Will my company be required to have elds?

    • Posted May 25, 2018 at 3:27 pm | Permalink

      Based on your comments, yes, it is very likely that the vehicles will be required to run with ELDs. Please contact the FMCSA or your local FMCSA field office for guidance.

  • Posted March 22, 2018 at 7:03 pm | Permalink

    So a friend is open dump truck business running the bigger dumps on a single cab semi. Under the 100 mile radius i would be starting at my home and ending at my home. Would i need to run elds or paper logs for this kind of job, hauling dirt lime rock etc. what are the maximum hrs of operation i drive or work for the day, any information would be appreciated as i have never heard of the 100 mile exemption nor have i ran local i run national now with elds and dont know anything about the local positioning on elds under 100 miles

    • Posted May 25, 2018 at 3:28 pm | Permalink

      You can find out more about the exemptions for short haul drivers in the ELD mandate here.

      The short haul exemption allows a driver to keep time cards only, and not take a break during the day. As long as there is less than 11hrs driving, 12hrs of workday, and 10hrs off – you won’t need to run RODS. If you run outside of the short haul exemption for any reason, you need to log that day. If you need to log more than 8 days in 30, you need an ELD. Please contact the FMCSA or your local FMCSA field office for guidance.

  • Posted March 22, 2018 at 2:54 pm | Permalink

    will my Elog also act as my time card or will I still need to fill out a separate one? Is this an option my employer can explore?

    • Posted July 10, 2018 at 12:50 pm | Permalink

      Your employer can explore this. In the case of Geotab, we have integrations to other timecard based systems and also can act as a timecard as well.

  • Posted March 20, 2018 at 7:48 pm | Permalink

    I have 1 box truck,26ft under 26,000 ,non CDL I drive 5 days a week from Tampa to Orlando, approx 200 milesround trip,do I need an ELD

  • Posted March 18, 2018 at 6:50 pm | Permalink

    Want to know is hauling cotton seed included under the the excempt for 90 days waiver for ag ?

  • Posted March 16, 2018 at 10:01 pm | Permalink

    Say you have a truck manufactured dec 1 1999 and a motor manufactured Jan 1 2000. Do you have to use the eld?

    • Posted April 9, 2018 at 10:32 am | Permalink

      The ELD mandate works on the motor’s year — so if it is a 2000 motor, you may need an ELD (depending on what you drive and where, you may be eligible for an exemption).

  • Posted March 16, 2018 at 10:08 am | Permalink

    I haul fresh produce from FL to NJ and ny am I exempt from elds

  • Posted March 16, 2018 at 12:43 am | Permalink

    Hi, I have volvo 1999 and trailer 53′ i have to used electronic logboock…?

    • Posted April 9, 2018 at 10:31 am | Permalink

      1999 and older engines are exempt from the ELD rule — so you should check your engine model year for details.

  • Posted March 15, 2018 at 4:43 pm | Permalink

    Hi,
    I have a small fleet of trucks that operate in Canada. We enter into the USA about once a week, but do not go out side of the 100 mile radius from the US/Canada border. We are never in the US for more then a few hours.
    Am I required to have ELD’s?
    We are hauling plant material.
    Thanks

  • Posted March 14, 2018 at 9:33 pm | Permalink

    What does one do when you’re out of hours on the eld, is there an something I can do to get extra time so I can make it to a truckstop?

    • Posted April 9, 2018 at 10:18 am | Permalink

      In this case, there is no way to extend your driving or workday time. If you must continue driving, adding annotations to the logs to help explain the reason for the violation is likely your best option. For more details, contact your local FMCSA Field office for guidance.

  • Posted March 12, 2018 at 1:33 pm | Permalink

    Was wondering if you work for a drive away company that is exempt from eld can the company force you to still use them although you are exempted?? Thank you!

  • Posted March 12, 2018 at 9:44 am | Permalink

    I’m picking up a mixer truck bought at auction in Denver. Driving to Pullman Wa, 1700 miles away. Will paper logs suffice?

  • Posted March 7, 2018 at 7:11 pm | Permalink

    We are a small harvesting company and have 2 tractor trailers to haul produce are we exempt E-log?

  • Posted March 1, 2018 at 7:47 pm | Permalink

    If my assigned truck is under 10000 pounds gvwr and a driver is sick that has a truck that requires and eld. Can I cover a run for him as long as i dont break the 8/30 rule?

    • Posted March 21, 2018 at 4:58 pm | Permalink

      If you need to log HOS for the trip, and have not logged more than 8 days of HOS in the last 30 on paper – you can complete the trip and use paper logs.

  • Posted March 1, 2018 at 6:24 pm | Permalink

    As a new owner operator…i will only have 1 semi tractor trailer…how many trucks must I own before I am required to install the company elog system… Thank you

    • Posted March 21, 2018 at 4:59 pm | Permalink

      One truck. The mandate does not have a size limit. It is dependent on the vehicle and driving that it does.

  • Posted February 24, 2018 at 3:53 pm | Permalink

    we have 15 tractors with a short haul operation, less than 100 air mile radius, less than 10 hour day, but we cross state lines, do we need the ELD?

    • Posted March 21, 2018 at 5:06 pm | Permalink

      If you cross a state line but you are still within the air mile radius, you can still use the short haul exemption.

  • Posted February 18, 2018 at 6:34 pm | Permalink

    Now with this exemption in place for older trucks I’ve been told that i must keep 4 forms of prof of hours on me every day for a week like Receipts plus i must have a pay stub to show that i did not roll loads(loads that got payed but never logged) is this true?

  • Posted February 17, 2018 at 10:36 pm | Permalink

    My wife and I are considering purchasing a pickup (dodge ram 3500) for drive away camper towing. Are owner operator/ contracted operators towing campers for a manufacturer required to comply with HOS laws and if so ELD as well?

    • Posted March 21, 2018 at 5:15 pm | Permalink

      You may be eligible for an exemption, however you should contact your local FMCSA field office and ask them directly about your business situation for guidance.

  • Posted February 12, 2018 at 1:26 pm | Permalink

    Hi I operate a 33,000 box truck and have a CDL also a 26,000 under CDL, I haul packages to the post offices in my region, I never leave the state in other words I only do intrastate no more than 10 hours per shift and less than 150 one way, am I required to use an ELD? Please help I’m confused. Thanks.

  • Posted February 8, 2018 at 12:02 pm | Permalink

    Do you know how ELD’s will affect drivers of water trucks that are contracted by the Forest Service to assist with wild fires?

  • Posted February 7, 2018 at 2:29 pm | Permalink

    I have 2 trucks registered apportioned and only leave the state of California 3 times a month, do I still need ELD even if my registration is apportion?

  • Posted February 5, 2018 at 3:42 pm | Permalink

    I own a 2004 Peterbilt, for private use only to haul my antique trucks to shows.
    I only do two to three shows a year. Am I required to use an eld? My tractor is
    never used commercially.

    • Posted February 7, 2018 at 11:23 am | Permalink

      If you do not benefit commercially, nor hold a commercial license, the ELD mandate may not apply. For the best information, contact your local FMCSA field office and ask them directly.

  • Posted January 31, 2018 at 9:10 pm | Permalink

    We haul water to and from oil sites. We drive to locations and hook up and wait 30-40 minutes to load, or sometimes we are on stand by for hours. Does this time count toward our driving time or our on duty time? I am trying to figure out if we qualify for the 100 air mile exemption. We may work over 12 hours at times but we are sitting on location for periods of that time.

    • Posted February 7, 2018 at 11:23 am | Permalink

      You may be able to use the Wait at Well exemption which is a special type of status that doesn’t use up your workday time. Check with your carrier and the FMCSA to be sure you are able to use this as an option – then have your admin enable it on your profile in MyGeotab. Then you will see a Wait at Well toggle in the Exemptions section of your HOS options in Geotab Drive.

  • Posted January 30, 2018 at 9:35 pm | Permalink

    I carry 79000 lbs and go from Bakersfield to Carson and back do I need an elog? I think it’s roughly 130 miles one way…

    • Posted February 7, 2018 at 11:24 am | Permalink

      If you are outside of the short haul radius, then you need to complete Hours of Service. If you need to complete Hours of Service for more than 8 days in a rolling 30 day period, you need an ELD.

  • Posted January 26, 2018 at 1:33 pm | Permalink

    We have 2 stake trucks one is 6000lb load cap. the other is 10000 load cap. which we use maybe 4-8 times a year for pick up and delivery to and from our shop combined. We travel out of state to our customers. Do we need a ELD for each truck or can it be shared between the 2 vehicles.

    • Posted February 7, 2018 at 11:26 am | Permalink

      If you need to log Hours of Service for more than 8 days in a rolling 30 day period, you need an ELD. It sounds like you are using the vehicles far less than this – so a paper log would be an option. Contact your local FMCSA field office for details.

  • Posted January 25, 2018 at 3:07 pm | Permalink

    Hi I have a question about the 100 mile short haul. I work for a company who doesn’t go past the 100 mile radius. However, we do drive more than 8 days out of the month. As long as I am under the 100 mile radius, do I need an ELD system? Even if I drive that more than 8 days out of the month?

    • Posted February 7, 2018 at 11:28 am | Permalink

      You do not need to log Hours of Service, and therefore don’t need an ELD if you operate solely under the short haul radius, regardless of the number of days. If you go outside of the radius, you need to log hours of service on that day (or if you work for more than 12 hrs, or start the day and end the day at different locations). If you need to log HOS for more than 8 days in a rolling 30 day, then you need an ELD.

  • Posted January 23, 2018 at 11:32 am | Permalink

    We have ELD’s in our 2 semi’s. We haul strictly heavy equipment from our site to either customer locations who bought the equipment, or are renting it, and it’s sometimes over our 100 mile radius. Or we haul equipment to jobsites we are working on that range from within our 100 mile radius or out 500 plus miles. I read Agricultural equipment is exempt, so would construction equipment be exempt as well? (Scrapers, Dozers, Loader, Bobcats, Excavators, etc)

    • Posted February 7, 2018 at 11:33 am | Permalink

      To our knowledge there is no exemption for construction equipment, but there is one for drive-away-tow-away operations which you may be able to use.

      In this case, your best point of contact would be your local FMCSA field office to ask for guidance.

  • Posted January 23, 2018 at 8:29 am | Permalink

    Does the 150-air mile exemption apply to passenger carriers in non-CDL vehicles?

    • Posted February 7, 2018 at 11:34 am | Permalink

      The 150 Non-CDL exemption listed in CFR 395.1 pertains to property carrying vehicles only.

  • Posted January 22, 2018 at 10:09 pm | Permalink

    if you drive a commercial pick-up with a team driver and they sleeping in the back seat are they consider off duty

    • Posted February 7, 2018 at 11:37 am | Permalink

      Off Duty pertains to whether the employee is being paid or is receiving compensation and able to do work for the carrier – so in this case, just being in the cab and asleep may not justify the OFF duty status.

  • Posted January 20, 2018 at 10:38 am | Permalink

    My question is regards to Trucks 2000 and older, when will they have to comply with ELD devices? Is there something available now?

    • Posted February 7, 2018 at 11:41 am | Permalink

      We operate under a reseller network. Please contact your Authorized Geotab Reseller for support.

  • Posted January 19, 2018 at 10:44 am | Permalink

    I conduct mobile hearing tests. I do travel outside of the 100 mile radius but not more than 8 days in a rolling 30 day period. I do have a DOT number and medial card as those times I do go past the 100 mile radius I can travel across state lines. I use an electronic Log on my phone daily but only for convenience so I don’t forget to log those times I do go outside of the 100 mile radius. It sounds as if I do not need an ELD according to your explanation. My only question is that once a year I do go outside the 100 mile radius and stay at a city/hotel for a month (catching clients in that area). DOT told me that moving my “Home” to that city for the month is okay to do as I do not go over the 100 miles each day I am there returning to the same hotel daily. Thus, my only official 2 days to log would be my drive over and and my drive back. Am I still exempt from using the ELD on my truck when doing that testing? Note: I do not drive most of the time. I am a mobile office/trailer and on a daily basis may drive 15 minutes to 45 minutes to get to a site and back. The rest of the day the truck is off while I work in the office of the trailer. I do track my HOS daily as well and never exceed the 14 hours maximum.

    • Posted February 7, 2018 at 11:42 am | Permalink

      Your understanding is correct – however, one clarification. To stay exempt under the 100 mile short haul you must not work more than 12 hours.

      On a day that you must log (one of your 8 days in 30), you can work 14 – but any day that you work 14, and are still under the 100 mile radius – those extra two hours would force you to log hours of service on that day, regardless of how far you were from your home terminal.

      Also, the FMCSA clarified at on a webinar in October, that moving your home terminal for the purposes of long stretches of work at another location is within the rules.

  • Posted January 10, 2018 at 12:16 pm | Permalink

    If im hauling Non Hazardous waste 70,000 pds too and from the port within a hundred-mile radius, do I have to log into my e log?

    • Posted January 18, 2018 at 1:58 pm | Permalink

      We are not able to answer a question like this due to the many variables that apply. Your best option would be to contact your local FMCSA field office for guidance.

  • Posted January 8, 2018 at 12:13 am | Permalink

    I have a 2004 Chevy 2500 hd I get hay every other year my weight is over 10,000 for both truck and trailer it is not a business what is the requirements for me

    • Posted January 18, 2018 at 1:55 pm | Permalink

      The ELD mandate is based around commercial motor vehicles. If you are not operating a commercial vehicle, the mandate does not apply. You can contact your local FMCSA field office if you would like more information.

  • Posted January 7, 2018 at 10:34 pm | Permalink

    If you run 8 days Interstate in a 30 day period then the rest
    of the month intrastate I but over a 100 mile radius.
    Do we still need Elds

    • Posted January 18, 2018 at 1:54 pm | Permalink

      We are not able to answer a question like this due to the many variables that apply. Your best option would be to contact your local FMCSA field office for guidance.

  • Posted January 6, 2018 at 11:08 pm | Permalink

    Why the trucks 2000 and older are exempt of ELG

    • Posted January 18, 2018 at 1:53 pm | Permalink

      Good question. Part of the ELD mandate relies on receiving data from the engine’s on board computer. 1999 engines and older don’t have this information available from them – hence they are exempt from the mandate.

  • Posted January 4, 2018 at 6:45 pm | Permalink

    I use a Motorhome to tow a racing trailer to races around the country. All of these races are trophy classes and we have no expectation of earning money. My motorhome and trailer combined require an over length permit in the state that we live in and our combined weight is 76,000 lbs, but in a 30 day period, we only run 5 or 6 days. Do we fll uder paper logs, and also, if I am required to run an ELD, do I have to get a DOT number for my RV?

    • Posted January 18, 2018 at 1:54 pm | Permalink

      We are not able to answer a question like this due to the many variables that apply. Your best option would be to contact your local FMCSA field office for guidance.

  • Posted January 4, 2018 at 3:56 pm | Permalink

    I tow an enclosed two axle trailer with a race car inside with a 34 ft. Class A gas motor home.Is the RV exempt? I also tow with a 2005 Dodge 3/4 ton 2500 diesel pickup. I only tow about 3-5 times a year and usually within 250 miles as the crow flies. Am I exempt? Thanks

    • Posted January 18, 2018 at 1:53 pm | Permalink

      We are not able to answer a question like this due to the many variables that apply. Your best option would be to contact your local FMCSA field office for guidance.

  • Posted January 3, 2018 at 9:26 pm | Permalink

    Lately I’ve seen more and more trucks on the side of the road because the driver ran out of hours because of these ELD’S and the state troopers are fed up with these devices because the trucks can’t to a truck stop or rest area because of these devices congress that signed into law they should behind the wheel of these big trucks first before the driver and me the American tax payer didn’t agree with these stupid devices honestly I thank these devices are a waste of taxpayers money and this is my point of view on this subject it’s congress is going to shut this country down before it’s all said and done and honestly it’s congress fault and FMCA and if i got yank those devices out of those trucks to get these drivers back on track I’ll be coming after congress and FMCA consider this a real WARNING TO BOTH OF YOU IDIOTS fix this or personally making a visit all of you Signed the American taxpayer

    • Posted January 18, 2018 at 1:50 pm | Permalink

      Thank you for sharing your opinion.

  • Posted January 2, 2018 at 8:27 pm | Permalink

    Hi Toney, are trucking companies with 10 or 20 trucks required to use elds?

    • Posted January 18, 2018 at 1:50 pm | Permalink

      Potentially, Yes. The requirements to have an ELD revolve around the vehicles themselves, where, and what they carry, so small fleets, even as small as 1 vehicle may be required to use an ELD. You can contact your local FMCSA field office if you would like more information.

  • Posted December 28, 2017 at 12:27 pm | Permalink

    An ELD vendor recently told us that the 8 days in a rolling 30 only applied only 1 time – meaning once a driver meets that requirement, he will from then on be required to use ELD regardless of distance ( short haul exemption) and regardless of weight class ( 10,001 and over)
    He stated the weight class no longer applies once a driver uses an ELD for the first time. If the driver gets into a small car or truck while working for the carrier, after having to use an ELD for the firs time, then he must continue to run logs from then – on even if that small vehicle is under the weight class, not placarded or designed to transport 15 or more passengers.
    We understood any time a driver in a single vehicle or combination vehicle over 10,001 while working for the employer, and has been driving for more than 8 days in any rolling 30 days would use an ELD. Once that driving stint was over and he no longer had 8 days in a rolling 30, he did not need the ELD and may use the paper log until such time that he again had 8 days or more in any rolling 30, drove outside his short haul exemption, – at such time he would go back on the ELD. Our rep said that was wrong.

    • Posted February 7, 2018 at 11:43 am | Permalink

      We have not heard of this and it does seem to contradict the notion of a rolling 30 day period.

      While we cannot offer legal advice via our blog, we would encourage you to contact your local FMCSA field office for a final answer.

  • Posted December 27, 2017 at 11:32 am | Permalink

    Hello- How can my drivers show an accurate electronic compliance report at a roadside stop if they drive trucks Geotab equipped and non-ELD trucks (model year 1998)?

    • Posted January 18, 2018 at 1:45 pm | Permalink

      These drivers shouldn’t be using Geotab Drive as they aren’t required to use an ELD. A paper log would still be in use.

  • Posted December 24, 2017 at 2:13 am | Permalink

    I’m driving a new 2017 Ford F450 pick up truck for my personal use, GVWR 14,000. Am I required to have ELD or HOS record keeping?

    • Posted January 18, 2018 at 1:44 pm | Permalink

      The ELD mandate is based around commercial motor vehicles. If you are not operating a commercial vehicle, the mandate does not apply. You can contact your local FMCSA field office if you would like more information.

  • Posted December 20, 2017 at 2:23 pm | Permalink

    Vik,
    What happens with the HOS users that cross borders and Jurisdictions are not loaded to Geotab Drive to get current location.
    For example, Mexico HOS users are not taking the current location (it takes the closest EUA city). Would this affect the compliance of ELD rules?

  • Posted December 18, 2017 at 4:05 pm | Permalink

    Since the ELD mandate started today, December 18, does the 30 day rolling period start today as well? In other words, what trips were taken prior to the December 18 start date do not have to be counted in the new 30 day window going forward?

    • Posted December 21, 2017 at 2:23 pm | Permalink

      This has not been addressed by the FMCSA. If you are concerned with the 8 day paper log exemption, it would be best to speak to your local DOT field office for guidance.

  • Posted December 17, 2017 at 11:17 pm | Permalink

    Say I’m driving a pumper truck and I get to my job site and I need to idle the truck up is the eld gonna read that the truck is in driving mode or not driving?

    • Posted December 21, 2017 at 2:11 pm | Permalink

      No, it will detect that the vehicle has stopped due to the speed readings by the ELD. If you do notice that the vehicle does not switch to ON automatically, or if you notice it moving to D automatically when stopped, please contact your Geotab Reseller.

  • Posted December 15, 2017 at 8:14 pm | Permalink

    Hello, I have a fixed ELD in my truck, but when a breakdown occurs, I will sometimes receive a substitute truck that does not have an ELD. Will I be able to run paper logs temporarily? Thanks!

    • Posted December 21, 2017 at 2:24 pm | Permalink

      You can only run paper logs for a replacement truck if it is a rental, and only for 8 days. See this FMCSA notice for more details. If it is a normal truck from your fleet, and no exemptions can apply (like short haul for example), then an ELD would be required in that truck as well. Remember, the logs follow the driver, not the vehicle.

      • Posted December 22, 2017 at 11:47 am | Permalink

        Ok, does your ELD transfer from truck to truck easily?

        • Posted February 7, 2018 at 11:44 am | Permalink

          Yes – the device that plugs into the truck is plug and play – and the driver portion of the ELD can be on a phone or tablet that is mobile.

  • Posted December 12, 2017 at 1:03 pm | Permalink

    Where do I find the summary sheet that is to be in the truck in case of questions by DOT to the drivers for explanation on how your system works.

    • Posted December 21, 2017 at 11:25 am | Permalink

      The in-vehicle documents that are required within the CMV can be found on the Geotab Drive page on the Geotab Marketplace:
      https://marketplace.geotab.com/solutions/geotab-drive

      These are the following documents that are required to be placed within the CMV:
      *Driver’s Drive App Manual [Print & Place in CMV]
      *Driver’s Guide to Data Transfer at Roadside Inspection [Print & Place in CMV]
      *Driver’s Guide to Data Diagnostics & Malfunction Events [Print & Place in CMV]

  • Posted December 11, 2017 at 5:58 pm | Permalink

    Do we need to comply with ELDS? We are a horse training business and haul horses to shows for our clients. We have never kept RODS and the vehicle we use to haul is our own.

    • Posted December 21, 2017 at 2:28 pm | Permalink

      If your combined weight of truck and trailer exceed 10,000 lbs, then you may be required to record HOS. If you need to record HOS, you may be required to use an ELD. There are exemptions for the agriculture industry, as well. We would recommend reaching out to your local DOT field office for guidance on your specific situation.

  • Posted December 8, 2017 at 9:55 am | Permalink

    ARE MECHANICS REQUIRED TO USE E LOGS WHEN WORKING ON A CUSTOMERS TRUCK AT A DEALERSHIP.

    • Posted December 21, 2017 at 9:36 am | Permalink

      In this case, there are likely exemptions that would apply such as the short haul, driveaway-towaway, or 8 day paper log.

      You should contact your local DOT department or the FMCSA for questions pertaining to whether you are or are not required to use an ELD.

  • Posted December 7, 2017 at 8:59 pm | Permalink

    We have 2 tractor truck to haul containers from port. we dont exceed the 100/150 miles radius daily. Are we exempted? Also is the 100/150 round trip or one way.

    Please clarify.

    • Posted December 21, 2017 at 9:36 am | Permalink

      You may be eligible for either the 100 air mile or 150 air mile non-CDL exemptions. There are specific requirements that you must follow to use these exemptions that can be found in the FMCSA rule here.

      The 100/150 is a radius around your home location – so the number of miles you drive within the radius is not used – rather that all the driving you do is within that distance of your location.

  • Posted December 5, 2017 at 8:50 am | Permalink

    Hi & thanks for the artical.

    Couple questions. I work for a Peterbilt dealership and move new cab and chassis along with finished trucks with bodies. I could be in 2 0r 3 different trucks within the same day. Usually all within 100 air miles. Rarely do we go above that but on occasions we have. Also we rarely drive a cmv all day. Most of the time we have a chase car that picks us up. We always start at our shop in the morning and return in the same place.
    From what ive read we are exempt and can use paper logs. Is this correct?
    Ive been using a phone app logbook instead of paper. Should I revert back to paper?
    Also we may pick up costomer trucks for our service dept to work on. these. These have their dot numbers and business info on the trucks. How should we move these trucks?

    Thanks
    Paul

    • Posted December 21, 2017 at 11:14 am | Permalink

      You may be eligible for the short haul exemption, or driveaway-towaway exemption.

      Please contact your local DOT department or the FMCSA for questions pertaining to whether you are or are not required to use an ELD.

  • Posted December 3, 2017 at 9:41 pm | Permalink

    work for a bus company and wanted to know is there an exemption that could be used for Driver applicants? Our applicants aren’t hired with the company until they complete two weeks of driver training and one week of test taking. If they are not actually employed with us how do we log them while they are doing driver training?

    • Posted December 21, 2017 at 11:14 am | Permalink

      We are not aware of an exemption in this case. You may be able to use paper logs for 8 days or less as part of the normal ELD exemptions. However it may be best to track their hours of service with an ELD for ease of use if they go over 8 days.

      Please contact your local DOT department or the FMCSA for questions pertaining to whether you are or are not required to use an ELD.

  • Posted December 1, 2017 at 6:39 am | Permalink

    Hello, I own a recreational vehicle/toter Home manufactured in 2000. It is used privately. Gvw is over 10,0000 and has air brakes. I am a not for profit car collector and drag racer. There is no prize money ever! Sometimes I drive across country to pick up a new toy/car. I have multiple trailers that I may pull depending on what I am doing. Am I exempt? What documents do I need to prove to an officer should I get pulled over to show I’m not commercial? Do I need a cdl? Thank you.

    • Posted December 21, 2017 at 11:15 am | Permalink

      There are many exemptions to hours of service and ELD, such as the 8 day rule that may apply to you.

      Please contact your local DOT department or the FMCSA for questions pertaining to whether you are or are not required to use an ELD.

  • Posted November 29, 2017 at 9:45 pm | Permalink

    My husband has a 2000 Freight liner which was manufactured 1999. The ELD is connected to his truck, but it won’t read that the truck is even running. Do you have any idea what may be causing this?

    • Posted December 21, 2017 at 11:15 am | Permalink

      ELDs are only required for trucks with engines from 2000 or higher. We suggest checking on the year of the engine in the vehicle.

  • Posted November 17, 2017 at 5:05 pm | Permalink

    Hi, I have a Straight Truck GVW 25990 Lbs year 2012, working for Warehouses and logistics owner Non CDL under my corporation, My operation is strictly Intrastate in a Short haul radius (Last Mile).

    -Do I need an ELD device?
    -If I add a Cargo VAN and a Driver for the same area and duties, does he need to have an ELD in the van?

    Thanks

    • Posted December 7, 2017 at 11:29 am | Permalink

      Based on what you have described, it does not sound like you would require an ELD. You should still contact your local DOT department or the FMCSA for questions pertaining to whether you are or are not required to use an ELD. You should contact your local DOT department or the FMCSA for questions pertaining to whether you are or are not required to use an ELD.

      Depending on your business and driving requirements you may be eligible to use a short haul exemption.

  • Posted November 16, 2017 at 11:26 am | Permalink

    we have newer dump truck haul sand and gravel work 50 hours aweek stay under 100 mile radius wil we need eld

    • Posted December 7, 2017 at 11:30 am | Permalink

      You should contact your local DOT department or the FMCSA for questions pertaining to whether you are or are not required to use an ELD.

      You may be eligible to utilize a short haul exemption.

  • Posted November 6, 2017 at 5:25 pm | Permalink

    I do dealer trades for an Automobile company. I am using a pickup truck with a single car flatbed trailer. I am currently keeping logs and have a DOT medical card. Do I have to comply with the ELD rule?

    • Posted December 7, 2017 at 11:31 am | Permalink

      You should contact your local DOT department or the FMCSA for questions pertaining to whether you are or are not required to use an ELD.

      You may be eligible to use a short haul, 8 day, or driveaway-towaway exemption.

  • Posted November 4, 2017 at 12:37 pm | Permalink

    My question is for those of us who operate under 26k lbs that are NOT required to comply to IFTA regulations during operating hours but also use our trucks for personal use ! What are we required to do when not in service and need to use our trucks (PickupTrucks) ? Is there a Not In service mode or ? For instance if I hook up to my toy hauler and want to go 800 miles up the road to our destination is the ELD recording ? Am i required to comply to ELD requirements?

    • Posted December 7, 2017 at 11:32 am | Permalink

      If you are using the vehicle for legitimate personal use, every ELD has a mode that you can enable called ‘Personal Conveyance’ that allows the logs that are created in the ELD to be flagged as personal. Thus not impacting the HOS logs. You will just need to remember to use this mode when using the vehicle for this type of use.

    • Posted December 28, 2017 at 9:51 am | Permalink

      If we are exempt under the short haul rule so we still have to have the ELOG installed in our trucks. ?? I’ve been told different things on this. So could you clarify for me if indeed we have to have them in the truck even though we don’t have to use them? Thank you.

      • Posted January 18, 2018 at 1:46 pm | Permalink

        In this case, if you know you will never need an ELD, you don’t need one. However, you should note that if a driver operates outside of the short haul exemption, they need to use Hours of Service for that day. Filling out a paper log for this type of day is fine, unless you do more than 8 in a rolling 30 days. The 9th day would need to be done with an ELD.

  • Posted November 2, 2017 at 7:54 pm | Permalink

    I will be Exempt becuase i am on a time clock pay by the hour . If pull over how do i show this?

    • Posted December 7, 2017 at 11:37 am | Permalink

      If you are not required to have an ELD, you need to tell the officer this and should know the details as to why you are exempt. If you are using the short haul exemption, your carrier will keep the records needed to prove this to the DOT.

  • Posted November 1, 2017 at 9:55 am | Permalink

    I am so confused. I have one truck that delivers and picks up material in MA, RI, NH and CT.
    Truck and cargo don’t exceed 26,000 lbs. It appears that you need ELD if required to keep record of duty status RODS and/or hours of service log HOS. Who is required to fill out these two items? We currently fill out a Driver Trip Report and a Driver Vehicle Inspection Report. We travel approximately 600 miles per week, starting and returning to the same location daily. 8 hour shift, 5 days per week, not always on the road.

    • Posted December 7, 2017 at 11:33 am | Permalink

      You should contact your local DOT department or the FMCSA for questions pertaining to whether you are or are not required to use an ELD.

      You may be eligible to use a short haul exemption depending on your business and driving requirements.

  • Posted October 31, 2017 at 10:13 am | Permalink

    Our welding and fabrication company has two trucks that fall within 10001 to 26000 # gvw range, one is a service truck setup with a welder and tools and the other is a delivery truck. Both trucks may log 4- 10 hour for driving time a week, our work week is based on 8 hrs a day 40 hrs a week (punched time cards). The company is base in Ma and don’t exceed the 150 mile radius but we do cross two state lines NH and ME and still fall within 150 mile radius. The drivers all have health cards and the trucks are DOT inspected each year. My Question is do we have to keep a log book in both truck and if we do does the driver have to fill out the log book on the days that they do not drive? If we don’t need a log book or what do we need in the truck that would prove that I qualify for the 150 mile radius exemption when I cross state lines?

    • Posted December 7, 2017 at 11:34 am | Permalink

      You should contact your local DOT department or the FMCSA for questions pertaining to whether you are or are not required to use an ELD.

      You may be eligible to utilize a short haul exemption.

      If you are required to obtain an ELD, please refer to the FMCSA FAQ: https://www.fmcsa.dot.gov/faq/who-responsible-integrity-rods to learn more about maintaining the integrity of the driver’s records.

  • Posted October 24, 2017 at 6:45 pm | Permalink

    I have a old kw k100 cabover. Do I have to worry about elds.

  • Posted October 12, 2017 at 10:18 am | Permalink

    We have a small towing company with 2 trucks that already have a GPS device installed for years now. Is that good enough or do we need an additional device installed?

    • Posted October 26, 2017 at 4:56 pm | Permalink

      This would depend on other elements of your business such as the types of vehicles and where they operate. See the FMCSA FAQ here for more details. Also, it’s important to note that ELD and GPS trackers are different. The ELD mandate requires the device to be synchronized with the engine of the vehicle and record engine data. There is also a technical spec the manufacturer of the device would need to abide by, and the vendor will also need to be certified on the FMCSA list of Registered ELDs.

  • Posted October 9, 2017 at 11:24 am | Permalink

    If I have a 1999 truck with 1999 engine, does it mean that after December 18 2017 I can still run paper logs?

    • Posted October 26, 2017 at 4:54 pm | Permalink

      Yes. Unless your engine is year 2000 or newer, you do not need an ELD. For more info, please see the FMCSA FAQs.

  • Posted October 3, 2017 at 1:58 pm | Permalink

    Our video production company owns one truck. But due to weight guidelines, we are subject to log books, vehicle inspections, DOT & UCR registrations, etc. We also occasionally rent trucks from Ryder, Penske, and the like, when we are contracted at multiple shows, on the same dates. Not being anything close to a trucking company, it is incredibly hard to determine what rules effect us and reading official guidelines, has left me more confused, then educated. Who can we turn to, to give all details of our operations and advise us properly? We transport large video screens and camera equipment, to events in a 5 state area or so and after shows are done, always return, with our equipment, to our shop. Can you direct me or advise?

  • Posted October 1, 2017 at 11:52 am | Permalink

    hello, maybe we miss out but what about the carrier or companies with one truck? with is my for example, 2002 truck?thx you

    • Posted October 4, 2017 at 9:05 am | Permalink

      There isn’t an exemption for carriers or companies with one truck. You are subject to the ELD mandate, unless you qualify for one of the exemptions mentioned in the blog post. To confirm for certain whether you fall under the ELD mandate, we recommend to please contact the FMCSA directly.

  • Posted September 27, 2017 at 12:01 pm | Permalink

    I believe your statement on glider kits is incorrect.
    Based on the FMCSA ELD FAQ which you link to in the question, glider kits ARE exempt from ELD requirements if the engine is pre-2000. For confirmation of this, please see https://www.fmcsa.dot.gov/faq/if-vehicle-registration-commercial-motor-vehicle-reflects-model-year-2000-or-newer-b-0

    • Posted September 29, 2017 at 4:38 pm | Permalink

      Thank you. We have updated the article.

  • Posted September 21, 2017 at 3:15 pm | Permalink

    My drivers meet the short haul exemption, but they haul hazmat (fuel, etc.) Are they still exempt, or are ELD’s required since they haul hazmat?

    • Posted September 29, 2017 at 10:34 am | Permalink

      Thanks for the question. Vehicles transporting hazardous materials are not exempt from the ELD rule. At this time, our system does not directly support the Hazmat exemption for breaks, but we will be including this in the near future. Currently, existing users can change their ruleset when operating under the hazmat exemption to No HOS Ruleset and apply the ON duty status. The logs in this duration can be annotated to show that the Hazmat exemption was applied.

      • Posted November 15, 2017 at 9:19 am | Permalink

        Can you provide the location in the mandate stating that you are not exempt from ELD if hauling Hazmat within 150 miles?

        • Posted November 24, 2017 at 10:15 am | Permalink

          Thank you for your question. To confirm for certain whether you fall under the ELD mandate, please contact your local DOT department directly.

  • Posted September 2, 2017 at 2:27 pm | Permalink

    We have 5 vehicles which transport damaged vehicles from various auctions through-out New England and Long Island N.Y.
    All our trips are within 150 miles one way and the drivers are back home each and every day.
    Might we be exempt from the ELD Rule?

    • Posted September 6, 2017 at 9:39 am | Permalink

      Hello Tony,
      I believe you are talking about the 150 air-mile radius exemption for non-CDL drivers. The requirements to qualify for this exemption are your drivers must drive a truck that is a “commercial motor vehicle” but does not require a CDL, and work within a 150 air-mile radius of their normal work reporting location and return there each day.

      If you meet the criteria for using the non-CDL short-haul exception:
      • You must not drive for more than 11 hours following 10 consecutive hours off duty;
      • You must not drive past the 14th hour after coming on duty 5 days in any period of 7 consecutive days; and
      • You must not drive past the 16th hour after coming on duty 2 days in any period of 7 consecutive days.
      • You must not drive after being on duty 60 hours in any 7 consecutive days or 70 hours in any 8 consecutive days (unless you took 34 consecutive hours off to restart a 7/8-day period that meets the conditions listed above).

      If they meet these requirements, then they do not need to log hours of service (although they will need to keep time records showing time in, time out, and total number of hours). Based on what you’ve said, it sounds like you may be exempt from equipping your vehicles with an ELD. Just remember that if you have a driver who meets the requirement to log hours of service on a paper log 8 days or more in a rolling 30 day period, then you must equip your vehicle with an ELD.
      Vik Sridhar, Solutions Engineer, HOS Expert

  • Posted August 28, 2017 at 7:39 pm | Permalink

    If I read the exemptions correctly, if the vehicle is registered as a tow truck, towing companies are exempt regardless of the weight?

    • Posted September 1, 2017 at 11:52 am | Permalink

      Thanks for the question Jerry.
      In order to qualify for the drive-away tow-away operation exemption, the vehicle being driven must be the commodity being delivered, or the vehicle being transported is a motor home or a recreation vehicle trailer with one or more sets of wheels on the surface of the roadway. If you don’t meet these requirements, then you will not be exempt.
      Vik Sridhar, Solutions Engineer, HOS Expert

      • Posted September 8, 2017 at 7:07 pm | Permalink

        Okay, just so that I understood this correctly, I want to hear it in layman’s terms. I haul recreational camper trailers for a living. I tow them on my bumper or fifth wheel on my pick up truck, and never more than one trailer at a time. The wheels of the recreational camper trailer are always on the pavement.
        Am I exempt from using an ELD?

        • Posted September 29, 2017 at 10:15 am | Permalink

          If you are operating in Ontario, there is a list of exemptions to hours of service which you can find here: http://www.mto.gov.on.ca/english/trucks/handbook/section1-7-2.shtml. Please review this information. If you don’t meet one of these conditions, then you will have to log hours of service. Do you operate in the US or Canada? Please keep in mind, at this time, only the U.S. has an ELD mandate.

  • Posted August 28, 2017 at 5:33 pm | Permalink

    Have you heard anything on the Small carrier extension?

    • Posted September 1, 2017 at 11:51 am | Permalink

      Hi Andrea,
      We do not expect a delay in the ELD mandate for small carriers. Please do not wait. We highly recommend you begin evaluating ELD solutions as soon as possible, so that you’re ready when December 18th arrives.
      Vik Sridhar, Solutions Engineer, HOS Expert

  • Posted July 19, 2017 at 9:52 pm | Permalink

    Are milk haulers or any agricultural hauler exempt

    • Posted September 6, 2017 at 11:56 am | Permalink

      Currently our trucks are running “Ag Exempt” on log books. Will we have to log hours on the ELD system, or how would we change that on the the ELD system? Could someone clarify how this will work for “Ag Exempt” drivers? Thanks

      • Posted September 29, 2017 at 10:06 am | Permalink

        At this time, our system does not directly support the Agriculture exemption, but we will including this in the near future. Currently, existing users can change their ruleset when conducting agricultural operations to the No HOS Ruleset as long as the driver does not exceed the 150 mile radius. Logs created while applying that exemption can be annotated by the driver to reflect that the Ag exemption was applied.

  • Posted June 15, 2017 at 6:09 pm | Permalink

    We have drivers that could need to use the EDL only once or twice a year. Can they do this and revert to short haul forms the rest of the time?

  • Posted May 26, 2017 at 12:52 am | Permalink

    I am wondering how the ELDs work for a small business. I have 4 trucks and wondering if I would have to put the ELDs in them. I have been told that as long as I have under 10 trucks I don’t have to worry about the ELDs that I can still use the paper logs but I have also been told that if I have more than 2 trucks I need to install the ELDs so I was wondering how that worked. I am only a small start up company and trying to make sure that I am in compliance because I have heard so many different things and each site is saying different things.

    • Posted May 30, 2017 at 3:32 pm | Permalink

      Hi Tiffany,
      The FMCSA regulations indicates everyone must become ELD-compliant with the following three exceptions:
      *Driveaway-towaway operations are not required to use an ELD, provided the vehicle driven is part of the shipment
      *ELD are not required on CMVs older than model year 2000
      *Drivers who use paper RODS for not more than 8 days during any 30 day period.
      An important fact to remember is that the regulations have not changed, only the method of recording them. You can find additional information on the FMCSA’s website. Look for Part 395 of the Federal Motor Carrier Safety Regulations.
      Robin Kinsey, HOS/ELD Training Specialist

  • Posted April 20, 2017 at 5:09 pm | Permalink

    We are a small company. one that does a lot of work out of town. We are not a trucking company but we do haul our own equipment. Now there is very seldom a day where a driver will be in a truck more than 2 days. Now these trucks ( some are actually pickups that with a trailer become a CMV ) are also used at home where we would fall under that 100 mile radius. So how do you use an ELD once in awhile? The pickups may leave town as a CMV but once they get where they are going and drop a trailer they are below the weight. I am very confused as to how this is going to work for a small company such as ourselves that is not a trucking company.

    • Posted April 28, 2017 at 1:10 pm | Permalink

      Hi Terri,
      That’s a great question. ELDs will be required if the driver meets the requirements to log on paper 8 days or more in a rolling 30 day period. Based on what you’ve said, it sounds like you might very occasionally meet the requirements to log, but doesn’t look like it would be greater than 8 days in a rolling 30 day period. You will still need to log a paper log for those days where you meet the requirements, but may not need an ELD. You can find more information on the ELD Mandate and a link to the FMCSA’s website in this post: https://www.geotab.com/blog/quick-guide-fmcsa-eld-mandate/
      Vik Sridhar, Solutions Engineer, HOS Expert

  • Posted April 20, 2017 at 11:59 am | Permalink

    Hey,
    Thanks so much for this post! I’m so glad that you included information about who the ELD rule will impact. It is so important to keep track of what limitations you may have on the road! Especially if you handle project deliverables that are time sensitive, you don’t want to get held up!
    Best,
    Dennis

    • Posted April 28, 2017 at 1:18 pm | Permalink

      Thanks for your comment Dennis. We agree!

  • Posted March 28, 2017 at 11:45 am | Permalink

    How do ELD’s apply to recovery vehicles (wrecker trucks)?

    • Posted April 5, 2017 at 11:11 am | Permalink

      If the vehicle meets the requirements for the definition of a CMV as outlined in the blog post, and the driver operating the vehicle meets the requirements to log 8 days or more in a 30 day period, the ELD rule will be applicable to these vehicles.
      Vik Sridhar, Solutions Engineer, HOS Expert

Leave a Reply

Your email is never published nor shared. Required fields are marked *


Subscribe Now
Get more Geotab news. You can unsubscribe at any time.