By December 18, 2017, most commercial vehicle operators who are required to keep Hours-of-Service (HOS) Records of Duty Status (RODS) will also be required to use Electronic Logging Devices (ELD). FRA Staff are aware that there seems to be some uncertainty or confusion over which truck drivers in the forest products industry will need to comply with this ELD mandate. Here is a brief synopsis of the rule and major exemptions from the mandate, based on our examination of the FMCSA website and informal conversations with a few key FRA trucking members as well as the American Trucking Associations: The ELD mandate applies to all drivers of a Commercial Motor Vehicle (CMV), beginning December 18, 2017.

If the company is using another (“grandfathered”) automatic onboard HOS recording device prior to that date, they have until December 16, 2019 to comply with all ELD rules.

The HOS rules do not change with the use of an ELD.

There are several exemptions to the ELD mandate, including the following:

• If a driver qualifies for the 100 air-mile radius (short haul) general exemption or 150 air-mile ag exemption from HOS, they are not required to have an ELD. This includes Interstate transport (e.g., a log trucker who meets the 100 air-mile exemption from HOS will not be required to use an ELD, even if hauling across state lines.)
• If the driver is required to use a Record of Duty Status (Paper Log) not more than 8 days in a 30 day period, they are not required to use an ELD.
• If the vehicle driven is a model year before 2000, the driver is exempt from an ELD. (But as soon as a driver switches to operating a model year 2000 or newer, he/she is then required to have an ELD.)
• Drivers who conduct drive-away-tow-away operations, in which the vehicle being driven is the commodity being delivered.

For more details, see the FMCSA website’s ELD Frequently Asked Questions section: https://www.fmcsa.dot.gov/hours-service/elds/faqs

FRA will continue to monitor the status of this mandate and will inform you of any updates we receive.