In a recent webinar, Joe DeLorenzo, the Director of the Office of Compliance and Enforcement at the FMCSA, discussed the short-haul exemption in the context of ELD implementation.
He recapped the short-haul exemption, to whom does the exemption applies to, and highlighted a few things that short-haul fleets and short-haul drivers should be wary of.
Furthermore, we also heard from two companies, who have implemented ELDs, despite having many short-haul drivers who are exempt from the ELD mandate. They explained their reasons for installing ELDs despite the exemption.
In this blog post, we are going to discuss all of that.
Let’s start from the top, i.e., what is the short-haul exemption?
As per the FMCSA’s rules, vehicles driving within a short-haul (within a 100 air-mile radius) are exempt from installing ELDs. There are a few other requirements as well.
If a driver fulfills all these requirements, he can be termed as a short-haul driver. It also means that he or she won’t require electronic logging devices after December 18, 2017.
Having said that, however, many short-haul drivers and companies are still installing electronic logging devices.
They are fully aware of the ELD exemption that they can avail, but they are implementing ELDs anyway, and they have good reasons for doing so.
You see, the short-haul exemption means short-haul drivers do not need ELDs. However, there is a catch.
Sometimes, short-haul drivers drive beyond 100 air-mile radius for making a delivery. If they do so for more than 8 days in any 30-day period, they would need ELDs.
This is why the short-haul exemption becomes slightly tricky to plan and manage.
Here is what Joe DeLorenzo, the FMCSA Director, had to say about this:
“Essentially what we do with this short-haul exemption is we say if you’re leaving from the same place and you return to your normal work reporting locations, operating within that 100-air-mile radius, you’re not going to have to fill out a log book. That’s fine as long as that doesn’t happen more than 8 days out of every 30 you can maintain your hours of service on a paper log. You want to make sure drivers could articulate that. What you don’t want to do with these exemptions is figure out on day eight or day nine of those 30 days that you needed to have a record of duty status and therefore have an ELD.”
He further added, “It goes by driver, so as a company, if you’re going to manage to this exemption you need to make sure each driver stays within those eight days out of every 30, then you’ll be OK.”
Since the short-haul exemption could be tricky, Joe reminded everyone to make sure drivers and fleet managers are trained and prepared for this. He said:
“My advice to anybody that operates under these exemptions is to make sure that your drivers understand the exemption and are able to articulate that in the event that they’re stopped so that it’s clear why they don’t have a log book. It’s also important that at the carrier’s place of business, that documentation of that driver’s time is maintained.”
While some fleets are holding off on ELD adoption just because they qualify for the short-haul exemption, many other fleets are quickly transitioning to ELDs.
Lindenmeyr Munroe and Preferred Meals are two such companies that have successfully installed ELDs across their fleets, despite the fact that many of their drivers are short-haul drivers.
Here is what they had to say.
Matthew Mascia is the Corporate Transportation & Logistics Director in Lindenmeyr Munroe, which is an independent paper and packaging distributing company. Regarding the ELD adoption process, Matthew explained:
“Being a sales driven organization, we’re going to make our deliveries where our customers need us to. So if we didn’t have that ability or an unavailable driver, that would be unacceptable from a delivery perspective. Lindenmeyr Munroe implemented ELDs across its entire fleet, in an effort not to handicap itself and to ensure its operations were compliant.”
Additionally, Matthew Mascia also mentioned that before ELDs they were facing several fleet management challenges, including driver shift sheets, IFTA fuel tax reporting, and undocumented or unintentional RODS and HOS violations.
Matthew added, “When the mandate came around, it kind of created the perfect storm for us to really sit down and talk about what we were going to do for our operating fleet.”
Now, as Matthew mentioned, Lindenmeyr Munroe is fully prepared for making deliveries wherever and whenever their clients need them to. They won’t be limited or handicapped in any way, and they won’t have to worry about any of their drivers exceeding the 100 air-mile radius limit for more than 8 days in a 30-day period.
Preferred Meals is another company that is largely comprised of short-haul drivers. However, instead of being selective, the company installed ELDs across its entire operations.
Now, apart from ensuring fleet uniformity and compliance, Preferred Meals is also enjoying several other ELD benefits.
Some of the ELD benefits that Perman Rejepov, a distribution metrics specialist at Preferred Meals, highlighted are:
Do you qualify for the short-haul exemption?
If you don’t qualify, there is no reason to wait at all. The ELD mandate is just 50 days away from now. You have to be fully prepared for the compliance deadline.
On the other hand, if you do qualify for the short-haul exemption, it is still crucial to take a good, hard look at your fleet operations. If you do not want to feel handicapped and limited after the ELD mandate becomes mandatory, you should install electronic logging devices now — despite the exemption.