ELD Rule Exemption Hypothetical

The only possible issue I can see is the 12 hours. It has to be 12 hours from coming on duty, not just 12 driving. For example they can work an 8 hour shift on the floor, but then can only drive for 4 more hours.

Everything else sounds correct though. Heck, they can even go over the 12 hours or the 100 air miles 8 days in 30 and still not need an ELD.

 

I'll have to re-read the regs, but under the 100 air mile rule, drivers don't need to keep logs, that's accomplished by the office's timesheets.

Where I'm fuzzy at is if it's ok to keep a logbook under the exemption. And if it is, couldn't it just be confusing to a DOT that's used to locals with just a DVIR book & everyone else with ELDs?

 

100 air miles? To and from origin? No logs no nothing needed. You can run 24/7 if you had robot employees that never sleep or eat. //satire...

There is a dividing line between a vehicle needing ELD etc and one that does not.

Your company is smart, they know whats possible using that 100 mile rule.

I would hate to see truckers be fully HOS and electronically monitored to the minute delivering somewhere 50 miles away and return in a few hours for the day. Even though there are times I have had that happen in my own full Class A trucking etc.

 

You can keep a log book in the truck but because the driver doesn't have to log, the ELD requirement exemption doesn't exist because the requirement doesn't apply to this situation.

Pretrip and other requirements don't need to be met, unless the truck and driver goes across state lines for an occasional trip.

 

X1 you can't run 24/7, all states don't allow that, you have a limited drive time and unlimited work hours with drive time returning after 10 hours of off duty time with no other employment activities.

 

Look at the next line...

(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:

Followed by several ways to not need an ELD.
Basically if you need to graph log 8 days or less in any 30 or no log (timecard) or a year 2000 engine, or a drive a way operation you don't need an ELD.

 

I think you are simply reading too much into it. If an ELD isn't required to be used, it isn't required to be installed. Even if it's not specifically spelled out, and I read it as it is, the guidance makes it very clear if it's not required, it's not required.

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