FMCSA ELD exemption question.

Discussion in 'Experienced Truckers' Advice' started by John Bertucci, Sep 16, 2020.

  1. John Bertucci

    John Bertucci Light Load Member

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    In regards to my question.
    FMCSA rule book states for a vehicle to be exempt it must meet this criteria.
    • Drivers of vehicles manufactured before 2000.
    I am the proud owner of a 2000 Mack Vision, this truck was built and left the factory with a 1999 engine and that is indicated on the engine as well as on the inside of the door sticker. I was hoping to find information that would clarify if I am exempt from running ELD or required to have one.

    Thank you
     
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  3. Ridgeline

    Ridgeline Road Train Member

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    It is always the engine, so 1999 you’re green to go!
     
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  4. ZVar

    ZVar Road Train Member

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    It is engine model year, not just engine build year.

    If the engine is stamped built on 1999 to meet 2000 model year emissions it would not be exempt. If it was simply stamped model year 1999, or simply a build date of 1999 with no mention of model year it would be exempt.
     
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  5. John Bertucci

    John Bertucci Light Load Member

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    going to look into this. not sure exactly what it states so i have to be sure. Thank you.
     
  6. Long FLD

    Long FLD Road Train Member

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    It goes off the year of the truck unless it’s a glider or been repowered, then it’s engine.
     
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  7. Ridgeline

    Ridgeline Road Train Member

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    Zvar, the emissions doesn’t have anything to do with it, the manufacture date of the engine only matters to the fmcsa. States aside, they have been clear about this, the manufacturer date matters.
     
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  8. ZVar

    ZVar Road Train Member

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    Except the guidance specifically states "engine model year" and not build date. While it doesn't specifically state anything about emissions, well that's what makes it a model year.
    Stating build date is factually wrong and someone could get in trouble if they listen to you. Here is the guidance.


    Question 20: When does the pre-2000 model year exception apply?
    Guidance: When a vehicle is registered, the model year should follow the criteria established by the National Administration (NHTSA). Generally, the model year is determined by reviewing the VIN on the vehicle registration. If the model year is pre-2000 based on the VIN, an ELD is not required. However, there may be instances when the model year reflected on the vehicle registration is not the same as the engine model year, most commonly when a vehicle is rebuilt using a “glider kit” or when an engine is swapped from one vehicle to another. Vehicles with engines predating model year 2000 are also accepted and are not required to have an ELD, even if the VIN number reported on the registration indicates that the CMV is a later model year. While the driver is not required to possess documentation that confirms the vehicle engine model year, 49 CFR Part 379 Appendix A requires motor carriers to maintain all documentation on motor and engine changes at the principal place of business.
     
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  9. magoo68

    magoo68 Road Train Member

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    Dang I was manufactured in 68 I guess I’m exempt lol
     
  10. Ridgeline

    Ridgeline Road Train Member

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    well no they won’t get into trouble if they listen to me because you stated that emissions drives the issue when it doesn’t.

    The fmcsa is talking only about pre-2000 engines, these are engines that include fuel systems that include an older fuel management system (electric) that did not use the j1939 CAN standard. The j1939 standard (and others that work with it) allows more interoperability within the chassis system, like abs and body management systems and this leads to better/tighter emission control. Some of these pre-2000 engines using the older sae CAN standards didn’t include the required data sets that the eld regs were requiring, which I have to say is a joke when you look at the list. The government didn’t mandate this standard, the sae and manufacturers agreed to it and 2000 was the year of change.

    So gliders are mentioned in the guidance and it explains the vin as a deciding factor of what is and isn’t a glider (I won’t get into what is called an assembled truck) but what is lacking is the legal requirement of an engine identification plate, there is none in any state or for the feds for pre-emissions engine. This means if I decide to build an engine with a pre-emissions block (the prime unit under the law), and do so with a mix of used and new parts, there is no requirement for even a serial number. If I get a glider and put that engine in it, then I’m legal all the way around because there is no legal requirement for me to identify that engine by a manufacturer plate when I built it.

    This goes for the registration of the truck, the states stopped using motor numbers in the fifties because the motors are exchanged, and new engines are stamped with the old number.

    So taking a look at the post-2000 engines, they are broken down by emissions for obvious reasons. Having a pre-2007 engine is one bracket that isn’t allowed in a truck built in 2013, which is a given but after 2000 eld is required,
     
  11. ZVar

    ZVar Road Train Member

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    Except I've seen an engine with a 1999 build date, and a stamp that it was a 2000 model year. That engine would not be exempt as the guidance states model year, no mention of build date anywhere.
     
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