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:
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.