Does my company need ELDs?

You will need to haveElectronic Logging Devices (ELDs) unless your operations are covered by an exemption. Here are the only exemptions from the ELD regulation:

ELD Rule Exceptions

The following are not required to use ELDs (but carriers may choose to use ELDs even if they are not required):

1. Drivers who use paper logs no more than eight days during any 30-day period.
2. Driveaway-towaway drivers (where the vehicle driven is the commodity, i.e. empty vehicle for sale, lease, or repair, provided the vehicle is part of the shipment) or the vehicle being transported is a motor home or a recreation vehicle trailer (at least one set of wheels of the vehicle being transported must be on the surface while being transported)
3. Drivers of vehicles manufactured before model year 2000 as determined by VIN/Vehicle Registration and or by the year of manufacture for the engine by VIN if manufactured prior to model year 2000.

Some MTAC member operations may be covered under the first option, if they comply with what is known as the “short haul” exemption from RODS. This exemption is also known as the 100/150 air-mile radius exemption.

The 100 air-mile radius driver exemption from RODS applies to drivers operating a motor vehicle requiring them to have a commercial driver license (CDL) who stay within 100 air miles of their normal work reporting location and are released from work within 12 consecutive hours. The carrier must also maintain true and accurate time records showing time beginning duty, time released from duty and total hours for the day for a period of six months.

Property carrying drivers must also have at least 10 consecutive hours off-duty separating each 12 hours on duty. If all conditions are met, records of duty status (driver logs) are not required. If any of the requirements are not met, i.e. the driver is not released from duty within 12 consecutive hours from their normal work reporting location, the 100 air-mile radius is exceeded, the driver does not have at least 10 consecutive hours off-duty separating each 12 hours on duty or the carrier does not maintain a true and accurate time record showing time beginning duty, time the driver is released from duty and total hours on duty that day for a period of six months, a record of duty status (driver log) must be completed.

If a record of duty status (driver log) must be completed more than eight times in any 30-day window, an ELD will be required.

The 150 air-mile radius driver exemption applies to drivers of motor vehicles not requiring them to have a commercial driver license (CDL). For these individuals to be covered under this exemption, they must stay within a 150 air-mile radius from their normal work reporting location, the driver must not drive after the 14^th hour after coming on duty on five days of any period of seven consecutive days and after the 16^th hour after coming on duty on two days of any period of seven consecutive days.

The carrier must also maintain true and accurate time records showing time beginning duty, time released from duty and total hours for the day for a period of six months. If all conditions are met, no records of duty status (driver logs) are required. If any of the requirements are not met, i.e. the driver drives after the 14^th hour after coming on duty on five days of any period of seven consecutive days or drives after the 16^th hour on two days of any period of seven consecutive days, the 150 air-mile radius is exceeded, or the carrier does not maintain a true and accurate time record showing time beginning duty, time ending duty and total hours for that day for a period of six months, a record of duty status (driver log) must be completed.

If a record of duty status (driver log) must be completed more than eight times in any 30-day window, an ELD will be required.

This is a reminder that the ELD regulation DOES NOT CHANGE the existing Hours of Service rules but how HOS are recorded.