ELD and paper log combination

The company I work for (in the office) is a dealership that is a driveaway/towaway operation. We are mostly exempt from the ELD mandate with the exception of our 3 IFTA vehicles that are required to have ELDs.

I am working on filing for an exemption for our 3 IFTA vehicles and need some guidance. The research I am focusing on is centered around how it would just as safe for us to run paper logs as the ELD's in those CMVs. It is getting a bit messy paperwork wise when our guys have to bounce back and forth.

Anyone have any constructive information on this or can point me in the correct direction?

 

Can you elaborate what you mean by that?

We have the VDO Roadlog and it works great. Just gets messy when attempting to combine my paper and electronic records. Most of our guys don't have smart phones so we went with something basic.

 

The issue is the app would mean they would all have to be provided with smart phones. (Boss doesn't want to do that because of initial cost and monthly fees.)

I've talked to them about getting at least one pre-2000 truck to just automatically be exempt in that vehicle. They guys don't mind their paper-logs. Maybe it is because it is familiar and they're use to using them.

 

If you don't do my job then you wouldn't know how it is messy for me.
In all fairness, I think whether or not we should be allowed the exemption should be judged on the FMCSA.

 

They do not edit logs at all. We have had 1 incident since we started and that was handled. I get that you all don't see an issue, that's fine. I'm not going into full detail because it is a lot to list and I genuinely was looking for guidance. If you all don't feel it is something we deserve, no worries. The FMCSA will turn down my request and I will be better at my job with the research I will be doing.