10 FAQs on the ELD Mandate, Answered

By June 30, 2016Regulations

December 2017 will be here sooner than you think. Will your fleet be ELD-compliant by then?

Though that impending date is just a year and a half away, there are still many questions that fleet owners and managers have. Recently, fleet tracking and telematics industry leader, TeletracNavman presented a webinar to our NationaLease members that answered many of those most frequently asked questions. Here are ten of those questions…and the answers:

Basic Questions

Q: How many trucks are needed in a business to be required by law to have electronic log book devices?

A: There is no minimum/maximum limit. All regulated drivers who currently are required to use a paper Record of Duty status (RODs) will be required to transition to an ELD.

Q: Is it true that the new ELD rule does NOT apply to carrier’s under 20 trucks, and they can continue to use paper logs?

A: No. the ELD mandate applies to all carriers (even a one-truck owner operator) that, due to the nature of operations, require a RODs to be maintained.

Q: Are intrastate drivers required to comply?

A: The ELD mandate is a federal (or interstate) rule and therefore would not be applicable to a solely intrastate carrier. In this case the carrier would defer to the individual state’s motor carrier safety regulations.

Q: If some, but not all of a company’s fleet currently has ELD devices, when are they required to be compliant?

A: Any fleet vehicle that is not currently equipped with a compliant AOBRD (Automatic on-board recording device) or an EOBR (electronic on-board recording device) must be equipped with an ELD by 12/2017. Whereas, any fleet vehicle that is currently equipped with an AORB or EORD has until 12/2019 to implement a compliant ELD solution.

Q: How long must motor carriers retain RODS and supporting documents?

A: The retention requirements for RODs and supporting documents did not change with the publication of the ELD mandate. RODs and all supporting documentation must be retained for a period of six (6) months.

Q: How do we know in advance where to buy compliant equipment and who to buy it from?

A: The Federal Motor Carrier Safety Administration (FMCSA) will publish a list of registered ELD providers on their website starting on 02/16/16. www.fmcsa.dot.gov/hours-service/elds/equipment-registration.

Exemption Qualification Questions

Q: What are the exemptions or exceptions to the ELD mandate?

A: There are only three (3) exceptions noted in the ELD mandate: (1) Drivers who keep RODS no more than 8 days during any 30-day period; (2) Drive away-tow away drivers (transporting an empty vehicle for sale, lease, or repair), provided that the vehicle driven is part of the shipment; or, (3) Drivers of vehicles manufactured before model year 2000.

Q: How will the ELD handle a CMV that is on “exempt” customer harvesting for six months and then regular commercial driving for six months?

A: Use of the ELD would not be required during exempt harvest time periods as determined by individual intrastate regulations

100 Air-Mile Radius Stipulation Questions

Q: Is a company with delivery trucks that usually stay within a 50 air-mile radius of the home office and run 8-10 hours a day 5-6 days a week subject to ELDs?

A: No, as these drivers would fall under the federal 100 air-mile radius exception, they are exempt for the ELD mandate.

Q: Is a company required to have ELD if the company is within 100 air-miles radius and only travels outside this radius 5-6 times a month?

A: An ELD is NOT required IF the driver operates no more than 8 days in any rolling 30-day period outside the parameters of the interstate or intrastate short-haul exception.

These are certainly just a portion of the questions carriers have regarding this very important mandate. What are the most important questions for your fleet? Let us know.

Jessica Boss

About Jessica Boss

2 Comments

  • Dennis Giff says:

    Has anything been discussed with respect to rental units? The GPS devices are vertically integrated with Log Software and therefore a large company that gets rentals from several vendors will have driver log data in multiple systems. Additionally, the customers fleet management/safety won’t have visibility/ access to their drivers logs or they will have to go into multiple systems to track.

    • TeletracNavman states, “Because the ELD rule provides a performance-based standard for ELDs, motor carriers will have a number of options to choose from the market place of ELD providers. This includes portable units that stay with the driver as opposed to being installed in the vehicle. Motor carriers that rely upon long-term leases of CMVs can work with the leasing companies to identify options and implement solutions to the challenge of using ELDs with leased vehicles. Therefore, the FMCSA has not included an exception for leased or rented CMVs. However, FMCSA does not regulate truck-rental companies. There is no requirement or prohibition for a rental agreement or short-term lease to include an ELD. A rental company might choose to include an ELD as a part of the agreement, just as they might include another piece of equipment. The ELD mandate does not apply to vehicle leasing companies.”

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