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Looking for ELD Exemptions?

[Update] If you’re looking for ELD loopholes, we have some bad news: The odds of finding an exemption to the Federal Motor Carrier Safety Administration (FMCSA) Mandate are slim. That said, there are still some exceptions to the Electronic Logging Devices mandate that went into final effect in December of 2019. They’re really not loopholes; they’re just vehicles and situations that aren’t applicable to the ELD mandate.

eld exemptions, electronic logging device mandate, electronic driver logs

A Quick Refresher: ELDs at a Glance

To be in compliance, and ELD must automatically record:

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The date, time, and vehicle geographic location information
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Engine hours
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Vehicle miles
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Driver or authenticated user identification data
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Vehicle identification data
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Motor carrier identification data

The purpose of electronic driver logs is to improve road safety, save time on logbook audits, improve maintenance, make dispatching more efficient, increase driver productivity, and eliminate common violations. The FMCSA predicted these benefits would result in a $1.17 billion boost to the industry.

From the driver’s perspective, it also puts them in greater control. They must sign off on any edits made to their logs. With AOBRDs and paper logs, dispatchers and managers could change their logs without their consent. It’s also harder to tamper with logs to hide HOS violations.

Today, most drivers use smartphone-based ELD apps. There are still some that use dashboard-mounted tablets, though. Paper logs were already rare before the ELD Mandate deadline.

Not ELD Loopholes, but Exemptions

Most vehicles are now required to use ELDS. But there are a few cases where drivers won’t be required to use ELDs.
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Those who use paper record of duty status (RODS) for no more than eight days out of every 30-day period (this eight-day period must be over a single 30-day period and doesn’t have to be in the same month, e.g., May 15-June 15).
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Those who conduct driveaway-towaway operations, where the vehicle being driven is the commodity being delivered.
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Those whose vehicles were manufactured before 2000.
eld exemptions, electronic logging device mandate, electronic driver logs

These cases are all still bound by the RODS requirements, though. They have three options for preparing their logs: on paper, using an Automatic On-board Recording Device, or with a logging software program. The section of the FMCSA website covering Part 395 has more details, including guidance for specific situations. If the truck is a rental or a leased vehicle, there are still no exceptions if the driver or fleet is required to record Hours of Service (HOS). If the fleet is exempt from the requirements of FMCSA regulations part 395.8, then it is likely exempt from the ELD Mandate.

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A Few Caveats About Older Vehicles

Even if you’re driving an exempt vehicle older than the 2000 model year, you may not be exempt. Here are two exceptions to the exemptions:
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A vehicle that has a glider kit that is newer than the year 2000, but the vehicle’s model-year is older than 2000.
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If the engine does not support an engine control module (ECM), the fleet must use an ELD that does not rely on ECM connectivity.
The FMCSA does allow a driver to use an ELD on a commercial vehicle that is older than model-year 2000. However, the ELD must comply with the technical specifications of the rule and it may use alternative sources to obtain or estimate the required vehicle parameters.
eld exemptions, electronic logging device mandate, electronic driver logs
eld exemptions, electronic logging device mandate, electronic driver logs

Grandfathered Extensions are Gone

Some carriers hoped for ELD exemptions similar to the extensions they received from installing AOBRDs on or before Dec. 18, 2017. The FMCSA didn’t budge, even though as many as 60,000 non-compliant vehicles were on the roads as the 2019 deadline approached.

The FMCSA also pledged that there would be no soft enforcement. Non-compliant drivers would be placed out of service for 10 hours. This penalty could have a huge impact on carriers and customers.

No ELD Loopholes – What Now?

The weeks before and after the ELD Mandate deadline resulted in many fleets rushing to get compliant. That made the transition more frantic. Installers were booked, and there were fewer experts to get drivers up to speed on using ELDs. Now that the final crunch time is over, ELD installers and providers can help.

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