In essence, an electronic logging device is a device that captures movement of a commercial motor vehicle. The requirement behind ELDs is that any time a truck is moving, the device will measure the number of miles the truck moves and will periodically provide updates regarding where the truck is located. The rule has very special requirements on how this is done. The device must capture the location of the truck at each change of duty status or at least once every hour. The device must also capture the location each time the engine is turned on or off.
While these devices are required to automatically capture drive time, all other duty statuses will require some input or intervention from the driver. For example, let’s say a driver drives for 100 miles and then stops. If the driver does nothing, the device will start an internal clock at the time the truck stops. After 5 minutes, the device is required to move the driver to on-duty/not driving status. The device is required to display a warning to the driver that it is shifting from driving status to on-duty/not driving status. If the driver does nothing else – the device will continue to keep the driver in on-duty/not driving. If the driver wishes to go off-duty, the driver must manually enter the new duty status into the device.
There are other nuances to the rule. As mentioned above, these devices are really only intended to automatically capture movement of the truck and record it as drive time. Neither the driver nor the carrier can remove drive time. All time a truck moves must be captured in the system and assigned to someone.
The U.S. Congress required the Federal Motor Carrier Safety Administration, or FMCSA, to publish a rule (mandate) requiring these devices in commercial motor vehicles. Additionally, Congress required the agency to make this rule apply to motor carriers and their drivers within two years of publishing the rule.
The FMCSA estimates the rule will help avoid 1,844 crashes, 562 injuries and save 26 lives annually. This data is based on improved compliance with Hours of Service (HOS) regulations.
All interstate truck drivers who currently are required to fill out records of duty status (RODS) or log books are required to have an ELD. However, there are a few categories of drivers that are NOT required to have these devices.
THE EXEMPT DRIVERS INCLUDE:
1. Drivers who use paper RODS for not more than 8 days during any 30-day period.*
2. Drivers who conduct driveaway-towaway operations, where the vehicle being driven is the commodity being delivered.
3. Drivers of vehicles manufactured before model year 2000.
*This group is primarily made up of short-haul drivers that currently use time cards instead of logbooks. However, if a short-haul driver uses a paper ROD more than 8 days in any 30-day rolling period, that driver must have an ELD installed in their truck.
Even though drivers mentioned here do not have to have an ELD, they must still comply with the HOS rules and keep required documents as detailed in the current rules. Additionally, motor carriers that employ ELD-exempt drivers must still have a system in place to ensure their drivers fully comply with HOS rules.
Many states automatically adopt federal rules for intrastate operations. If you live in a state that automatically adopts the federal rules, it is likely the federal ELD requirement will also apply to all your intrastate operations. Carriers that switch between intra- and interstate operations must do as before and comply with the federal regulations in the previous seven days prior to making an interstate trip. If you are a carrier that frequently switches between intra- and interstate operations, it may make more sense to install an ELD and comply with federal HOS regulations.
Each motor carrier should check with their state trucking association or state enforcement agency to find out if their state will adopt the federal ELD requirement and the timing of that adoption.