We know what you must be thinking. Why should short-haul fleets install ELDs? Aren’t they exempt from the ELD mandate?
Yes, they are exempt. However, there are still so many short-haul fleets that are installing ELDs ahead of the upcoming ELD mandate deadline.
If you are a short-haul driver or fleet manager, you should probably do the same. Because the ELD mandate exemption regarding short-haul drivers is tricky and can result in you being noncompliant.
In this blog post, we explain why. To be precise, we discuss the following:
Ready? Let’s begin from the top.
The FMCSA is pretty specific in defining short haul drivers. As per the FMCSA’s definition, short haul drivers:
If you fulfill all these requirements, you can be classified as a short-haul driver, as per the FMCSA’s regulations.
And what does it mean to be a short-haul driver in the context of ELD implementation?
Short-haul drivers are not required to maintain Records of Duty Status (RODS). Therefore, they are also not required to install ELDs.
Now, let’s discuss the four major ELD mandate exemptions before addressing the short-haul exemption in a bit more detail.
Although the ELD mandate applies to most CMVs and fleets, it does not apply to:
It’s important to note that the “30-day period” here does not represent a month. Instead, a period of Aug 20 to September 20 would be considered as a 30-day period.
Now, let’s specifically discuss the short-haul exemption and the big problem associated with it.
As mentioned earlier, the FMCSA exempts short-haul drivers from the ELD mandate because they do not maintain Record of Duty Status.
However, it gets tricky when sometimes drivers exceed their short-haul limitations.
For instance, what if one day a short-haul driver drives for more than 11 hours, does not come back to the home base within 12 hours, or drive beyond the 100 air-mile radius to finish his tasks?
According to the FMCSA, on such days, short haul drivers will have to maintain the Record of Duty Status (RODS).
Now, the most important part.
According to the FMCSA, if a short-haul driver has to maintain RODS for more than 8 days in a 30-day period, he or she will require an electronic logging device or ELD.
This changes everything.
Now, short-haul fleets can’t sit back and relax that they are exempt from the ELD mandate and will never need electronic logging devices. They may realize on the seventh day that they need an ELD. And then there won’t be enough time to install the ELD and remain compliant.
The FMCSA’s director, Joe DeLorenzo, also expressed his concern regarding the unseen consequences of the 8-day short-haul exception rule. In fact, he termed it as his “biggest concern”.
This is what he said:
“The one [area] that I’m most concerned about is the 8-day rule. Because the 8-day rule is the one where you can’t be figuring this out on the seventh day in any 30-day period and finding out that this is going to be a problem. That’s what happens a lot: ‘my driver went down sick for a couple of days, and now, suddenly, I’m going to be losing this exception, and that [other] driver is going to need an ELD’. Then you have to got to go back, and you have got to enter all that information into the ELD so the driver can use it, and then it’s just a lot more work for everyone.”
However, he said that by planning ahead, understanding the short-haul exemption in its entirety, and understanding the possibilities of needing ELD, short-haul fleets can avoid the dreaded fate of being noncompliant.
“I don’t think I can stress that enough — thinking ahead and figuring out what you as a carrier are really going to need in terms of those exceptions is going to be really important.”
As you can see, there can be instances when even short-haul fleets would require ELDs. The worse part about it is that they will most likely realize it at the very last moment.
This is why it is so important to utilize the next week or two to think ahead and identify if your fleet requires electronic logging devices. Look at the records and figure out how many times your drivers exceed the short-haul limitations and maintain RODS in a 30-day period.
If you suspect that they would need ELDs, you should begin the ELD implementation process right now. Waiting for the last minute to implement ELDs has its own problems.
Additionally, there are various benefits of ELDs that you will be able to enjoy, e.g., idle-time tracking and avoiding fuel wastage, vehicle diagnostics and fault-code alerts, identification of dangerous driving behaviors and improving safety, vehicle-location monitoring, calculating 100 air-miles for short-haul drivers, etc.