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4 Major ELD Exemptions You Need to Know

Governmental mandates can feel like someone stirring an ant hill. There was peace and then there was chaos. Hopefully you feel like the new electronic logging device (ELD) mandate is a natural step rather than an unnecessary bother. But either way, it is here to stay.

Is your fleet exempt from the ELD mandate? Well, the bad news is probably not. But the good news is there are a few exemptions.

The mandate went into place on December 18, 2018. Processing all the ways it will affect the industry will take some time. But increased ELD usage will certainly rise, saving companies money and time.

There are four major ELD mandate exemptions. Understanding them and how they may affect your fleet is critical to grasping and following the mandate as a whole.

1. Tow-away Drivers

This ELD exemption is not as simple as it appears. It applies to tow-away drivers who transport empty vehicles intended for sale, lease, or repair, as long as the vehicle they are driving is:

  • part of the shipment or the vehicle being transported
  • is a motorhome/recreational vehicle trailer with one or more sets of wheels on the surface of the roadway

Because the tow-away driver does not own the Commercial Motor Vehicle (CMV) being shipped, they are not responsible for installing an ELD in it.

2. Vehicles with Engines Made Before the Year 2000

Wait, what? Yes, this is a tricky one. If the vehicle’s engine was manufactured before the year 2000, it is exempt from using an ELD.

This cut off was chosen because most vehicles manufactured prior to 1999 are not equipped with an engine control module (ECM), which is necessary to use an ELD. It is important to note that this ELD exception does not apply to the Vehicle Identification Number (VIN) rather to the engine model year.

In this case, you can qualify for an exemption by using a glider kit. This consists of a new cab and chassis with an older engine and vehicle components. The Federal Motor Carrier Safety Administration (FMCSA) states that in this case, only the model year on the engine can be used to determine if the driver is exempt from the ELD requirements.

So, if you own an older, pre-2000 vehicle with a newer engine switched in, your vehicle will mostly likely not be exempt, and you will need to acquire an ELD.

3. Drivers Who Do Not Maintain RODS

The RODS exemptions are the trickiest to understand. There are many reasons why a driver might not maintain Record of Duty Status (RODS) which fall under the Short-haul Exemption under 49 CFR 395.1 Part E. They include but are not limited to drivers who:

  • operate within 100 air miles of their daily starting location
  • stay on duty 12 hours or less
  • have at least 10 consecutive hours off duty before going back on duty
  • report to the same location to work every day, among other rules.

If your driver does not meet these criteria (or any of the others laid out for the Short-haul Exemption), they are required to to maintain an ELD.  

So, if you never kept RODS before, do you need to do so now? The good news is no, you do not. To clarify the exemption listed above for RODS, under the ELD rule, drivers who use the short-haul exemption with time cards are not required to keep records of duty status (RODS) or use ELDs.

In short, nothing changed about which drivers are required to keep RODS and therefore required to use an ELD.

4. Drivers Who Maintain RODS for Less Than 8 Days

There is another RODS exemption, which is similar to the exemption listed above. There is an ELD mandate exemption for drivers who maintain RODS for less than 8 days in a 30-day rolling period. They do not need an ELD. But remember if the driver violates the terms of this exemption more than 8 times in a 30-day period, that driver will need to maintain an ELD for the rest of the 30-days.

Other Things to Consider

Keep your eyes open, because there have been some minor changes to the ELD mandate since it was enacted. Staying aware of further changes and clarifications would not be a bad idea. Just don’t expect major changes to the meat of the mandate itself.

There is a group that has a grandfathered and temporary exemption: those who are running AOBRDs (automatic onboarding recording devices). These are grandfathered in until December 16, 2019. If you are running AOBRDs, you do not need an ELD.

Small Fleets

One group that is examining the ELD mandate closely are the small fleets who own from one to 10 vehicles. Surveys show that these small carriers are reluctant to move to ELDs. Only 75% of them are ELD compliant, per a recent survey conducted by CarrierLists.

Estimates show ELDs can cost anywhere between $165 to $832, with a popular device rounding out at about $495 per truck. That can be an intimidating amount of capital for a small outfit despite the proven benefits of ELD usage.

The benefits of ELDs are been proven, and the savings in one year usually cover the outlay for a device. The savings round out to $705/year per vehicle. Moving to ELDs offer many benefits, such as driver safety and fuel usage monitoring. It is an easy step to take to help your small business.

If the vehicles of a small outfit were not required to keep RODS before the ELD mandate, they do not need an ELD now. And many small companies fall into this category.

Our Verdict

Ultimately, whether your company is a small up-and-comer or a large mover and shaker, the full mandate with no exemptions applies to the vast majority of commercial motor vehicle (CMV) drivers. That includes even the specialized cases of agricultural carrying fleets, vehicles carrying livestock, and oil field drivers.

Even when vehicles are not covered by the mandate, fleets are adopting them because of their numerous benefits. With the increased efficiency, growth in profits, and reduction in operational costs, the holdouts are looking at them again. Streamlined operations and being ELD mandate compliant is a positive step for any company.