An overview of the ELD mandate
The ELD final rule is part of the MAP-21 mandate from congress that went into effect in 2017. The ELD mandate was passed as a way to ensure that drivers have a safe work environment and to create an easier system to track and manage records of duty status (RODS). The ELD mandate aims to annually avoid thousands of crashes, save lives by reducing drowsy driving, and save billions of dollars in paperwork expenses.
The ELD mandate includes provisions that are meant to prevent data tampering and driver harassment. It also outlines set procedures for data transfers so it's easier to demonstrate compliance and share RODS with safety officials.
The ELD mandate has two main phases. As of December 17, 2017, all vehicles subject to the ELD mandate must record Hours of Service electronically. The recording device must comply with a set of regulations known as the Federal Motor Carrier Safety Regulation 49 CFR 395.15. All devices installed after this date must be ELDs, though existing automatic on-board recording devices (AOBRDs) may still be used.
The second phase will take effect on December 17, 2019. By this time, data must be recorded directly from the vehicle's engine and automatically transmitted to the Department of Transportation (dot). This means that all devices must be ELDs and AOBRDs will no longer satisfy the mandate.
Vehicles equipped with Samsara's ELD compliance solution will be compliant across all phases of the ELD mandate.
What is an electronic logging device (ELD)?
Electronic logging devices, also known as electronic logbooks or e-logs, connect to a vehicle's engine and automatically record driving time, providing a reliable and seamless way to gather Hours of Service (HOS) data. ELDs have interfaces for drivers to set their duty status, complete daily logs, and present electronic logs to officers performing roadside inspections.
Unlike previously available automatic on-board recorders (AOBRDs) and electronic on-board recorders (EOBRs), ELDs must connect directly to the vehicle's engine and monitor usage to ensure logs cannot be falsified. ELDs must also be registered with and approved by the FMCSA.
How does the ELD mandate affect hours of service (HOS)?
The ELD mandate does not change Hours of Service regulations. However, before the ELD mandate went into effect, drivers could use paper logs to track their Hours of Service. This is no longer the case and all drivers subject to hours of service must now use electronic logs.
What is the 14-hour rule?
The 14-hour rule is part of the Hours of Service regulations for property-carrying CMVs. It refers to the maximum amount of time a driver can be on duty. In most cases, CMV drivers must complete all driving-related work within 14 hours of their first on duty or driving segment. During this period of time, they may only drive up to 11 hours, and they must take a 30-minute break after driving for 8 hours. Before and after each 14-hour period, drivers must be off duty for a minimum of 10 consecutive hours.
Who must comply with the ELD mandate?
Drivers who operate a commercial motor vehicle (CMV) could be subject to the ELD rule. Commercial drivers who are required to maintain records of duty status (RODS) must comply with the ELD mandate.
CMVs are vehicles that are used for business purposes and travel interstate. In addition, they meet one of the following criteria:
Weigh more than 10,000 pounds
Have a gross vehicle weight rating or a gross combination weight rating of more than 10,000 pounds
Are designed to transport 16 or more non-paying passengers, including the driver
Are designed to transport 9 or more paying passengers, including the driver
Transport enough hazardous materials to legally require warning placards
Who is exempt from the ELD rule?
There are two types of situations where drivers may be exempt from all, or parts, of the ELD rule.
Drivers who use short-haul, timecard exemptions do not need to keep records of duty status (RODS)
Drivers who meet the following criteria do not need to use ELDs, however, they still must keep RODS using paper logs, an automatic on-board recording device (AOBRD), or a logging software program:
Drivers who are required to keep RODS for 8 days or less within any 30-day period.
Drivers who are conducting driveaway-towaway operations where the vehicle is being delivered.
What exemptions are there for the ELD mandate?
The ELD mandate covers drivers and fleets across a wide range of industries, so there are several exemptions to account for the various use cases where electronic logging devices might be used.
There are several exemptions to the ELD mandate for agricultural transportation in 395.1:
Covered farm vehicles are exempt from HOS and CDL regulations if the vehicle is over 26,000 pounds and operated within a 150-mile air radius of the farm. Covered farm vehicles under this weight threshold are always exempt, no matter how far they travel.
Exemptions are granted during the planting and harvesting periods of each state.
Drivers who transport bees or livestock for interstate commerce are exempt from the required 30-minute break when there are animals on board.
16-Hour short-haul exemption
There are other exemptions for property-carrying drivers, like the 16-hour exemption in 395.1 (o). The 16-hour exemption applies to drivers who started and ended their day at the same work location for the past five days. Once per cycle, drivers may complete their 11 hours of driving within a shift of 16 hours, rather than the ordinary 14 hours.