JULY 18, 2017 – As the deadline for the Electronic Logging Device (ELD) mandate approaches, there is still a considerable amount of confusion surrounding who exactly will be exempt from installing the devices into their Commercial Motor Vehicles (CMVs). We’ve covered many of these exemptions in the past, but there’s still a big one that deserves some attention: the 100/150 air mile exemptions. If you meet the criteria for either of these exemptions, you aren’t required to follow federal hours of service regulations – and therefore won’t be required to have an ELD.
Demystifying the 100/150 Air Mile Exemptions
If you are a short-haul, interstate carrier that operates within either 100 or 150 air miles of your work location, you may be exempt from the ELD mandate. To qualify, you must meet all of the following criteria.
If you are a CDL driver, you:
- Must operate solely within a 100 air-mile radius*
- Must be completely off-duty within 12 hours
- Must report back to the same work location every day
- Must have at least 10 consecutive hours off-duty between each shift.
If you are a non-CDL driver, you:
- Must operate solely within a 150 air-mile radius*
- Must not drive through any state that requires a CDL for the type of vehicle being operated
- Must report back to the same work location every day
- Must not drive after the 14th hour of coming on duty 5 days in a period of 7 consecutive days
- Must not drive after the 16th hour of coming on duty 2 days in a period of 7 consecutive days
Drivers are currently required to fill out a paper log if any one of the criteria listed above is not met. For example: a CDL driver gets a job that will bring in a lot of cash, but he has to travel 300 air miles to deliver the load. He is required to maintain a paper log for the duration of the trip.
Other ELD Exemptions
If the 100/150 air mile exemptions don’t apply to you, there are currently three other major ELD exemptions, as determined by the FMCSA. They include:
- Drivers who keep logs for no more than 8 days during a 30-day period. Many drivers infrequently travel over the 100/150 air mile radius. Take the example given above of the CDL driver who goes over 100 air miles one time. Even though he has to keep a paper log for that trip, he does not have to purchase an ELD provided that the situation rarely occurs…specifically, no more than 8 days in any 30-day period.
- Driveaway-towaway operators who meet one of two specific criteria: either the vehicle being driven is the commodity being delivered OR the driver is transporting a motor home or recreational vehicle trailer with one or more sets of wheels are on the roadway.
- Drivers of vehicles with a model year (or engine year) of 1999 or earlier. These vehicles are exempt simply because some do not have the ports required to connect an ELD. There has been some confusion about model vs. manufacture year, but the FMCSA has been clear: it’s the model year of the vehicle or it’s engine that they’ll use to determine compliance. So if you have a 2005 truck with a 1999 engine installed (for example), you wouldn’t need an ELD.
Hopefully, this has helped answered some common questions regarding ELDs. Please be sure to let us know by leaving any comments or questions below!
.png)