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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

96 Comments

  • 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 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 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

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