ELD Exemptions & Exactly Who Can Obtain Them in 2024

eld exemptions article

If you own a fleet of commercial vehicles, you need to understand virtually everything about Electronic Logging Devices (ELDs) – which devices are acceptable, how to install them, who is required to use them, and what the ELD exemptions are. In this article, we’ll concentrate especially on that last item, ELD exemptions, and will also give you some information about the ELD mandate in general.

ELDs have been mandated by the Federal Motor Carrier Safety Administration (FMCSA) to ensure compliance with Hours of Service (HOS) regulations. The ELDs installed in your fleet’s vehicles automatically record your drivers’ time on the road, monitor vehicle engine hours and movement, track miles driven, and provide you with location information.

All the above is done in the name of safety – safety for everyone who comes into close proximity with your fleet. Still, there are exceptions to the rule within the mandate, and it’s these exemptions that we’ll explain below. If your fleet is relatively small or you’re an owner-operator, you’ll be particularly interested in whether the exemptions apply to you, so you can determine the most efficient and cost-effective approach to logging your driving hours.

Understanding the ELD Mandate

The Electronic Logging Device Mandate applies to you if you’re required to maintain Records of Duty Status (RODS), also known as a Driver’s Log, which, in turn, is a mandated part of the Hours of Service (HOS) rules.

Key Aspects of the ELD Mandate:

  • Implementation Date: The mandate went into full force on December 18, 2017. As of this writing, it’s still in effect.
  • Connectivity: ELDs must be connected to your commercial vehicle’s engine to record driving time (and other data) automatically.
  • Data Transfer: Devices must be capable of transmitting data to enforcement officials during roadside inspections. Normally they’ll also be able to send their data back to the home office as well.

Your ELDs must be certified and registered with the FMCSA. The FMCSA maintains a list of nearly 900 models of ELDs that it approves.

Who Must Comply with ELD Regulations

Electronic Logging Device regulations are an important component of road safety and compliance for commercial vehicle operations in the United States. They mandate electronic record-keeping for hours of service to make sure your drivers aren’t operating their vehicles while fatigued.

Commercial Trucking Requirements

Your commercial trucking company and your drivers must comply with ELD regulations if you operate any of the following.

  • Interstate commercial trucks: These are vehicles with a gross vehicle weight rating (GVWR) or gross vehicle weight (GVW), or a gross combination weight rating (GCWR) or gross combination weight (GCW) of 10,001 pounds or more.
  • Hazardous materials haulers: This includes any of your trucks that transport hazardous materials that require safety permits.
  • Passenger carriers: If your fleet consists of commercial buses and/or motorcoaches that engage in interstate business, then ELD regs apply to you.

Regulated parties include:

  • Long-haul truckers
  • Short-haul operators who don’t qualify for timecard exceptions

Criteria for ELD Exemptions

Here then are the reasons your fleet might be exempt from the ELD Mandate. The FMCSA stipulates clear criteria for these exemptions, so if you have questions about these exemptions, we suggest you contact that organization.

Sporadic Drivers

Any of your drivers who maintain Record of Duty Status for not more than 8 days within a 30-day rolling period do not need an ELD. They must still keep paper logs though.

Short-Haul Exceptions

Eligibility for the short-haul exemption includes these items.

  • Your drivers must operate within a 100 air-mile radius (if commercial).
  • Your non-CDL freight drivers must operate within a 150 air-mile radius.
  • Your drivers should not exceed a 12-hour work shift.

Any of your drivers who use this short-haul exception don’t have to keep Records of Duty Status and are thus exempt from ELD requirements.

Driveaway-Towaway Operations

You own a driveaway-towaway operation if you have an empty or unladen motor vehicle with one or more sets of wheels on the surface of the roadway and it’s being transported:

  • Between vehicle manufacturer’s facilities
  • Between a vehicle manufacturer and a dealership or purchaser
  • Between a dealership, or other entity selling or leasing the vehicle, and a purchaser or lessee
  • To a motor carrier’s terminal or repair facility for the repair of disabling damage
  • To a motor carrier’s terminal or repair facility for repairs associated with the failure of a vehicle component or system, or
  • By means of a saddle-mount or tow-bar.

Such driveaway-towaway operations are exempt from the ELD Mandate when the vehicle you’re driving is part of the shipment being delivered or is a motorhome or recreation vehicle trailer. This exemption applies regardless of the vehicle’s age. (We mention this because of the final age exemption below.)

Exemptions for Agricultural Operations

Agricultural exemptions are pretty straightforward. These two points apply to the drivers themselves.

  • Transporting agricultural commodities within a 150 air-mile radius from the source of the commodities during planting and harvesting periods, as determined by each state.
  • Driving covered farm vehicles including vehicles operated by a farmer or farm employee which are not used in for-hire motor carrier operations.

And these two apply to the vehicles.

  • You must use the vehicle within 150 air-miles of the farm.
  • You must not be carrying hazardous materials that require a placard.

Older Vehicle Exemptions

If your vehicle has an engine that pre-dates model year 2000, you are exempt from the ELD mandate. Note that the exemption is based on the engine model year, not the vehicle’s registration date. Your drivers need to keep documentation proving the engine’s model year.

Impact of ELDs on Fleet Management

Electronic Logging Devices have significantly changed fleet management through improved compliance with regulations, better operational efficiency, and an emphasis on safety and accountability.

Compliance with Regulations

ELDs automatically record driving hours. You can be sure your fleet adheres strictly to Hours of Service regulations. ELDs reduce human errors associated with manual logbooks, and they help you to avoid potential penalties by providing you with the following.

  • Real-time tracking of your drivers’ hours
  • Alerts for HOS violations, so you can manage scheduling better
  • Electronic reports for quick inspections, so your drivers can spend more time in transit

Operational Efficiency

As a fleet operator, you can experience increased efficiency because the  ELDs streamline your daily operations. You’ll have the data that can lead to:

  • Optimized route planning reducing fuel consumption and idle times
  • Faster scheduling with accurate ETA predictions
  • Automated IFTA reporting so you spend less time on admin

Safety and Accountability

ELDs contribute to the safety of your fleet’s operations and enhance accountability on several levels. They give you:

  • Prompt incident reporting with time-stamped data for investigations
  • Driver performance monitoring so you can identify and correct unsafe driving habits
  • Regular maintenance alerts so you can be sure your vehicles are reliable and safe

ELD Compliance and Enforcement

The Electronic Logging Device mandate, enforced by the FMCSA, requires commercial motor vehicle operators to record their hours of service with an ELD, with the exemptions mentioned above.

You can expect the occasional compliance check to be conducted by roadside enforcement and at weigh stations. Officers may request to see a driver’s logs and, if required, the ELD data transfer. They can choose at least one telematics transmission method and one local method.

ELD data transfer methods:

  1. Wireless Web services (telematics)
  2. Email (telematics)
  3. Bluetooth (local)
  4. USB 2.0 (local)

If your driver is found to be in violation, this can result in fines, out-of-service orders, and impacts on a carrier’s Safety Measurement System (SMS) results. In addition, you need to make sure your devices are registered on the FMCSA’s list of certified ELDs to avoid other penalties.

You should make sure your drivers receive training on ELD use because recording their hours properly is necessary to remain in compliance.

You should also have clear protocols for ELD use and malfunction reporting. You must retain records for six months, and your drivers are required to keep supporting documents for the same period.

Choosing the Right ELD Solution

It shouldn’t be too hard to find an ELD that suits you. Actually, you biggest problem will be narrowing down your choices, since the FMSCA has about 900 they’ll let you use. Check out the features, the vendor’s reputation, and the cost to help you decide.

Features to Look For

Look for these features in any potential ELD you might want for your fleet.

  • Compliance: Obviously you want to adhere to FMCSA regulations.
  • Ease of Use: An intuitive interface makes life easier for drivers and fleet managers.
  • Reliability: It’s not much good if it’s not working.
  • Integration Capability: It’s best if it works with your other in-cab technologies.

Vendor Considerations

When assessing potential vendors, you should consider the following.

  • Industry Experience: Do they have a proven track record in the trucking industry?
  • Customer Support: How accessible and knowledgeable is their support team?
  • Updates and Maintenance: Do they provide regular software updates and system maintenance?

Cost Analysis

When you conduct a cost analysis, think about these things.

  • Compare what your initial hardware costs would be, plus any installation fees.
  • Calculate your ongoing monthly service fees.
  • Figure out the long-term savings you’ll get due to increased efficiency and compliance.

Implementing ELDs in Your Fleet

Implementing Electronic Logging Devices into your fleet involves training drivers, managing data, and integrating these devices with your existing business processes.

Training for Drivers

Your drivers need training to understand how ELDs work. They should also be aware of compliance regulations. Their training should include:

  • Device Operation: How to log in, log off, and navigate through the ELD’s functions.
  • Record Maintenance: How to annotate and edit logs, if they’re permitted to do so.
  • Inspection Requirements: How to provide ELD data during roadside inspections.

Managing ELD Data

Managing the data from your ELDs involves these important items.

  • Data Security: Be sure your ELDs use encryption and secure data storage to protect sensitive information.
  • Data Analysis: You should use the data to review driving hours and identify patterns that could indicate the need for improvements to your current practices.
  • Data Reporting: You need to know how to generate reports for compliance audits.

Integration with Business Processes

You want your ELDs to work in harmony with your existing business processes. Consider the following points of contact.

  • Fleet Management Software: Your ELDs should be compatible with what you’re using for scheduling and route optimization.
  • Communication Tools: If your ELDs have a messaging feature, what does that mean for your current means of communication?
  • Maintenance Tracking: Use your ELD data in concert with existing preventative maintenance schedules.

Challenges and Considerations

You and your drivers may encounter technical, privacy, and regulatory hurdles that will need to be overcome.

Technical Issues

You must consider device compatibility, as not all commercial vehicles may be compatible with the latest ELD technology. Ideally, you thought about this before you made your initial selection of an ELD model.

If your drivers have to travel in remote areas, you may experience connectivity issues with them. This can mean a lapse in tracking, thus complicating regulatory compliance.

Data Privacy

You drivers’ location data and hours of service are sensitive information that require protection. You have to make sure that you’re in compliance with data protection laws (such as the General Data Protection Regulation, for European drivers) and that your data encryption methods meet industry standards.

Regulatory Changes

Regulations governing ELDs aren’t set in stone. You have to stay abreast of changes, which are almost inevitable, to maintain compliance.

Frequently Asked Questions

What are the conditions that allow local drivers to be exempt from ELD use?

Local drivers are exempt from ELD use if they operate within a 100 air-mile radius of their work reporting location, complete their workday within 12 hours, and maintain time records.

What are the FMCSA’s paper log requirements for drivers not using ELDs?

Drivers not using ELDs must prepare paper logs if they are required to keep records of duty status (RODS). Of course, these logs need to be accurate and complete and must include all hours of service, with graphs and remarks as needed.

Which types of trucks are exempt from the ELD mandate?

Trucks manufactured before the year 2000 are exempt from the ELD mandate, due to compatibility problems between older engines and the ELD system. Some special vehicle configurations may also be exempt.

Under what circumstances can a truck driver operate without an ELD?

A truck driver can operate without an ELD if they are a short-haul driver, use paper RODS for not more than 8 days within a 30-day rolling period, drive a vehicle manufactured before 2000, or are conducting driveaway-towaway operations.

What specific rules apply to agricultural drivers regarding ELD exemptions?

Agricultural drivers are exempt from ELD use when transporting agricultural commodities within a 150 air-mile radius (from the source of the commodities) during planting and harvesting periods, as determined by each state.

How does one obtain an exemption from the ELD requirements?

To obtain an exemption from the ELD requirements, a driver or carrier must apply to the FMCSA describing the reason for the exemption and how safety would be maintained. The FMCSA reviews these applications on a case-by-case basis and grants exemptions for up to 5 years, subject to renewal.


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