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Transportation Expert:

Electronic Device Mandate 2017

4 Federal Exemptions


By John Ross


 Transportation Trucking Forensics Expert


Evidence Solutions, Inc. has written about the upcoming Electronic Logging Device (ELD) mandate: Trucking Regulation Expert Article: ELD Required in December 2017.

 Evidence Solutuions Trucking Expert


Currently the rule is set to take effect in December of 2017. The ELD Mandate will affect millions of commercial drivers. Part of the rule will allow some Commercial Motor Vehicle Operators to be exempt. These exemptions relate only to the ELD Mandate and not to the Hours of Service (HOS) requirements spelled out in Part 395 of the Federal Motor Carrier Safety Administration’s (FMCSA) Federal Motor Carrier Safety Regulations (FMCSRs).


Generally, drivers are still required to keep a time record showing the time they report for duty and when they are released from duty. This still must be kept for each day and must tally the total number of hours on duty.  Drivers, depending upon the type and scope of their operation, may qualify for one of the four federal ELD exemptions. Here is a brief synopsis of the exemptions:


1.  Short-haul drivers Part 1


CDL Short Haul Drivers who operate within a 100 air mile radius and non-CDL Short Haul Drivers who operate within 150 air mile radius of their normal work location, who work no more than a 12 hour shift and have at least 10 consecutive hours between shifts, are exempt from the ELD rule. These drivers are not required to keep a daily log of their duty status. See Sections 395.1(e)(1) and 395.1(e)(2[2] [3] of the FMCSR for short haul definitions.


2. Short-haul drivers Part 2


Drivers who fall under Short-haul part 1, but occasionally exceed the 100 air mile radius limit are exempt from the ELD rule so long as they do not exceed the 100 air mile radius limit more than eight (8) times in any 30 day period. This 30 day period is a rolling 30 day period.


3. Pre-2000 vehicles


Vehicles with a Vehicle Identification Number (VIN) dated 1999 or earlier are exempt from the ELD Mandate. This only applies, however, to drivers who only operate Commercial Motor Vehicles manufactured prior to 2000.


4. Dealership Delivery Operations


If the semi-truck is being driven as part of a shipment an ELD is not required. Generally, this exception applies to Class 8 and Class 7 truck dealerships that transport for delivery multiple tractors to their customers. This only applies if the CMV being driven is part of the delivery. An example would be two or three tractors that are piggy-back secured to the lead tractor and the lead tractor is part of the delivery.


The ELD vendors are encouraging those who are not legally required to switch to ELDs, touting the many benefits to switching to an automated compliance and fleet management solution.


Air Miles versus Statute Miles

Air Miles are actually Nautical Miles, which a different measurement than what is used for statute miles on a roadmap.  An air mile is approximately 1.15 of a statute mile. Statute miles are 5,280 feet and a Nautical mile is approximately 6,076 feet.

Therefore, a 100 air-mile radius from a work reporting location is equal to 115.08 statute, or “roadmap,” miles (185.2 km). A 150 air-mile radius from a work reporting location is approximately 172.6 statute miles (277.8 km).


By John Ross


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