Who must comply with the ELD rule?

Motor carriers and drivers subject to the ELD rule must start using ELDs by the compliance date of Dec. 18, 2017, unless they are using a grandfathered AOBRD.
A grandfathered AOBRD is a device that a motor carrier installed and required its drivers to use before the ELD rule’s Dec. 18 compliance date. The device must meet the requirements of 49 CFR 395.15. A motor carrier may continue to use grandfathered AOBRDs until no later thanDecember 16, 2019. After that, the motor carrier and its drivers must use ELDs.

WHO NEEDS AN ELD and WHO’S EXEMPT

The ELD rule applies to most motor carriers and drivers currently required to maintain records of duty status (RODS) per Part 395, 49 CFR 395.8(a).

The rule allows limited exceptions, including:

• Drivers who operate under the short-haul exceptions may continue using timecards; they are not required to keep RODs and will not be required to use ELDs
• Drivers who use paper logs for not more than 8 days out of every 30-day period
• Drivers operating a power unit that is part of a driveaway/towaway shipment
• Drivers who are driving or towing a recreational vehicle that is part of a driveaway/towaway shipment
• Drivers who are operating vehicles with an engine model year older than 2000
• Drivers of property-carrying CMVs rented for eight days or less (this exemption was added in October).

How will ELDs handle HOS exemptions such as oil field logging?

FMCSA emphasizes that the ELD rule did not change hours of service rules or existing exemptions.

As far as the required recording functions, AOBRDs and ELDs are not impacted by the use of exceptions, such as the 24-hour restart provision allowed to drivers hauling exclusively in support of oil and gas field operations. As long as the system is recording the hours, the system is compliant. As long as when the driver’s records are reviewed, the driver’s record shows that the driver is staying within the appropriate limits and using exceptions correctly, the driver is compliant. The key word here is “exemption”.

If I’m driving a truck under 10,000 pounds, do I need to use ELDs?

Most tend to forget about the fact the federal definition of CMVs can include pickup trucks or large passenger vans.
If the vehicle’s total gross vehicle weight rating (GVWR), gross combination weight rating (GCWR), is 10,001 pounds or more, and is used in interstate commerce, then ‘Yes,’ the driver(s) would be required to use a compliant ELD.

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