Do you need to use electronic logging devices (ELDs) for your commercial vehicles? The short answer is most likely yes. However, the FMCSA continues to receive requests for exemptions. Plus, the agency is still refining guidance for both the agricultural industry and personal conveyance. On March 13, 2018, the FMCSA announced a 90-day temporary waiver from the ELD rule for agriculture-related transportation. No doubt confusion about who must use an ELD persists.
The Electronic Logging Device (ELD) mandate went into effect last December and the full enforcement begins in just a few days—on April 1, 2018. Drivers not in compliance will be placed out of service and a company’s Compliance, Safety, Accountability carrier score might suffer.
This mandate represents change, but not as much as you might think. If you maintained paper hours of service (HOS) records before the ELD mandate, you’re still required to maintain records. What has changed is the way you keep those records. For most carriers, if you keep HOS records, you should have ELDs installed in your commercial vehicles.
So, who is exempt from the ELD requirement? The FMCSA offers few exceptions. Drivers who don’t drive very often or very far may be exempt. Drivers who drive vehicles with older engines that do not have the compatible technology are exempt. Finally, drivers who are transporting agricultural products shorter distances are exempt. Let’s look at a few examples.
- Joe manages a fleet of commercial vehicles. Most days he works in the office, managing paperwork and working with clients. Sometimes if a driver calls in sick, Joe can cover deliveries. He never drives more than 8 days out of any 30-day period. Joe can continue to use paper HOS logs. However, if the vehicle he drives has an ELD, he should have an operator account so the miles can be accurately attributed to Joe.
- Alex drives large recreational vehicles for a rental company. She moves the vehicles from one location to another, as customers and agencies need them. Because Alex drives the commodity being delivered she does not have to use an ELD. This is a drive-away-tow-away operation exception.
- Martin drives an older vehicle, with an engine that was manufactured before the year 2000. He does not have to use an ELD, but he does have to keep HOS logs on paper.
- Luis is driving harvested soybeans from local farms to the soybean processing plant. Because the processing plant is within a 150 air-mile radius from the farm, no ELD is required. However, if the processing plant is farther away, the vehicle would have to have an ELD device installed. Luis could enable an ELD device after the 150 air-mile radius and annotate the miles that were not recorded by the ELD. While the FMCSA has recently announced a 90-day temporary waiver from the ELD rule, carriers should use this time to prepare their fleet if their vehicles will transport agricultural commodities long distances.
Most other drivers who are operating commercial vehicles will need to have an ELD in place before April 1, 2018. In addition to using an ELD to track driver HOS, drivers are required to keep some information in the vehicle cab. Drivers should be prepared to provide information from the ELD during a roadside inspection.
If you would like more information on the ELD mandate and CalAmp’s V-Series ELD solution, visit our information page calamp.com/eldsolutions.com