ELD Rule - Answers to Commonly Asked Questions

We have received many inquiries regarding the Federal Electronic Logging Device (ELD) regulation. Read below to find answers to the most common ELD questions. 

What are the key requirements of the Electronic Logging Device (ELD) rule? 

The ELD rule:

Who is exempt from the Federal ELD rule? 
Drivers who use the timecard exception are not required to keep records of duty status (RODS) or use ELDs. Additionally, the following drivers are not required to use ELDs; however, they are still bound by the RODS requirements in 49 CFR 395 and must prepare logs on paper, using an Automatic On-Board Recording Device (AOBRD), or with a logging software program when required:
Source: FMCSA FAQs

Does the Federal ELD rule apply to CA intrastate carriers? 
Currently, the rule only covers interstate carriers. The CHP’s current intention is that by December 31, 2020, California (intrastate) carriers must equip their vehicles with ELDs unless an exemption is met. This is subject to change. CTA will update members with any changes.

View the CHP’s presentation on the ELD rule: Electronic Logging Devices PowerPoint

What is the difference between interstate and intrastate commerce?

Interstate commerce is when a person drives a CMV:
• From one State to another State or a foreign country;
• Between two places within a State, but during part of the trip, the CMV crosses into another State or foreign country; or
• Between two places within a State, but the cargo or passengers are part of a trip that began or will end in another State or foreign country.
 
Intrastate commerce is when:
A person does not meet any of the descriptions above for interstate commerce.
The cargo or passengers originate in and the final destination is in California.
A person does not cross state or international borders.
 
Are motor carriers that meet the agricultural exemption defined in 395.1(k) or the covered farm vehicle 395.1(s) subject to the ELD rule?
 
The ELD rule does not change any of the current hours of service exemptions. Therefore, motor carriers that meet the exemptions defined in 395.1 are not subject to Part 395, including the ELD rule while they are operating under the terms of the exemption. The duty status of the driver may be noted as either off-duty (with appropriate annotation), or "exempt." Click here for additional information on the agriculture exemption.
 
Source: FMCSA: ELD Hours of Service (HOS) and Agricultural Exemptions

For more information on ELDs or to find answers to compliance questions, contact Heather Ward, Compliance Coordinator, at hward@caltrux.org