JJ Keller put out an article, that points out the following exemptions to the new ELD (EOBR) Mandate.
The electronic logging device (ELD) mandate will affect roughly 3.5 million CMV drivers, but notall commercial drivers will need to use ELDs. Some drivers will still be allowed to use paper logs or may be exempt from logs.
The federal HOS rules include the following exemptions from needing ELDs.
- Drivers who are exempt from the HOS rules entirely will continue to be exempt, such as government drivers and drivers of utility service vehicles.
- Drivers who are entirely exempt from logs will continue to be exempt, such as certain church-bus drivers and those who consistently use a short-haul 100/150-air-mile exemption.
- In-state-only (intrastate) drivers who are exempt from federal ELD rules by their state. Some states may grant additional exemptions for certain drivers who stay within the state.
- Drivers who only need logs infrequently, such as those using the 100- or 150-air-mile-radius exemptions, as well as "intermittent" or "occasional" drivers who simply do not drive very often.
Those who need to use logs on 9 or more days in any 30 consecutive days will need to start using an ELD on the 9th day unless another exemption applies.
- Drivers operating in a "driveaway-towaway" operation (as defined in Section 390.5) in which the vehicle being driven is part of the shipment being delivered, such as manufacturers delivering vehicles to dealers, or dealers to buyers.
- Drivers of vehicles that were manufactured before model year 2000, since these vehicles were not required to have electronic control modules (ECMs) to which an ELD can connect. The vehicle ID number (VIN) is used to determine which vehicles qualify for this exemption.
- Finally, drivers who are using a compliant, automatic on-board recording device (AOBRD) by December 18, 2017, will not need to use an ELD until December 16, 2019. The extra two years allows extra time to make the device compliant with the ELD standards or to replace the device with an ELD.