The company I work for is a driveaway/towaway operation. We have 3 vehicles that are fleet and sometimes used to tow the "commodity" back to the shop. From what I understand, the 3 fleet vehicles are required to have ELD's. (Please, someone, validate me on this or tell me I'm wrong.) The REAL confusion comes to the commodities we drive back. Originally when I read the exemptions on the FMCSA website, driveaway/towaway operations are exempt if the vehicle they are driving is the commodity. I found another section of the website yesterday that stated the paper logs needed to be produced by an AOBRD. So are the drivers allowed to use normal, handwritten paper logs for those vehicles, or does the company need to invest in portable devices? (I've called a million places and even emailed them and in 2 weeks I have received no response.) All of our drivers are going on a trip Monday and I'm trying to figure out what I need to do. Thanks in advance.
Handwritten paper logs are fine. You were probably reading the part where an AOBRD has to be able to produce paper logs if requested. Just ignore it. AOBRDs will be phased out and are being replaced with ELDs. The ELD regulations are far more comprehensive.
Most likely yes*, depending on where they go and for how long. If your drivers need to use logs (i.e., they're not exempt) then your owned CMVs will need to be compliant. *"Most likely" because I am too lazy today to actually look up and quote chapter and verse.
What section of the regs did you read that? Post a link? But it sounds lie what not4hire said. It's an old regulation that, unless you were already using it, is no longer valid after last December 18th.
Driveaway/towaway operations are exempt from ELDs and permitted to use paper logs if; The vehicle being driven is the commodity being transported as part of the shipment, or The vehicle is a recreational vehicle trailer being transported with it's own wheels on the ground This means towaway operators delivering RV trailers are ELD exempt even when using their own trucks. As for your company owned tow vehicles, unless they meet one of the other ELD exemptions below or are towing RV trailers then yes, they need compliant ELDs eventhough you are a driveaway/towaway operation. General ELD exemptions are; Chassis or engine model year of 1999 or older Used in an operation requiring a paper log 8 or fewer days in any 30 day period See 49 CFR 395.8 (iii) (iii)(A) A motor carrier may require a driver to record the driver's duty status manually in accordance with this section, rather than require the use of an ELD, if the driver is operating a commercial motor vehicle: (1) In a manner requiring completion of a record of duty status on not more than 8 days within any 30-day period; (2) In a driveaway-towaway operation in which the vehicle being driven is part of the shipment being delivered; (3) In a driveaway-towaway operation in which the vehicle being transported is a motor home or a recreation vehicle trailer; or (4) That was manufactured before model year 2000, as reflected in the vehicle identification number as shown on the vehicle's registration. Note, it is regulatory guidance that gives the engine model year exception not the text of the regulation.
At our company if you are in the drive away division you are required to use the Keep Trucking app for your logs. Apparently this satisfies DOT requirements. You still need to carry backup paper logs in case the app or your phone has a seizure
