ELD Rule Exemption Hypothetical

I've already quoted the specific regulation. You choose to read more into it than what is there. Sorry I can't help further.

 

In theory you could have 4 different drivers sharing the same truck and as long as none of them need a graph log more than 8 days out of 30 then the truck doesn’t need an ELD. The ELD is for the driver to log their hours of service, it isn’t for tracking the vehicle.

 

You’re missing the fact that an ELD isn’t for tracking the vehicle. It is for the driver to record their hours of service. You’re overthinking this is all. You’ll be running under an exemption. You don’t need to do a paper log so you don’t need an ELD. Really no different than people running on the Ag exemption or the livestock exemption.

 

It’s not for the vehicle. It’s for the driver. If the driver doesn’t need it the vehicle doesn’t need it. I don’t know how else to say it. You’re thinking into it way too much.

You can have a brand new truck and if the driver doesn’t need a paper log more than 8 days a month it wouldn’t need an ELD.

 

You leave us to assume that the Class B drivers are on a time clock (or salary). Secondly, the restriction/exemption is 150 air miles, not 100.
In your scenario, these drivers begin and end their shift at the same location, and records are kept at the plant. Management has given them specific responses to any questions from DOT, including show them a current log.

My question: Why confuse a situation with unnecessary documentation? Are they local or not? Since they qualify for local transport;
1. 150 air mile radius
2. Begin and end shift same location.
3. Don't exceed the 14 or 11 hour rule.
They are LOCAL DRIVERS,
If one of the interstate drivers were to be used to do a local run for a day or so, his/her duty hours would need to be recorded into the ELD data after the shift is completed, they should maintain a paper log for the day and transfer the hours to the data base.
Don't complicate a relatively simple situation with excessive documentation. Bills of lading, registration, and proof of insurance along with a current license is all these drivers need if stopped by DOT.

 

The 150 air miles is for non-cdl cmv's.
The op's statement of 100 air miles is correct. Also, to qualify for the non-eld timecard exemption, one cannot be on duty for more than 12, so the 14 hour rule doesn't apply.