Are you Exempt from ELDs?
If you are claiming the short haul exemption, then quite simply, you’re not required to maintain RODS and you won’t need to log your hours with an ELD.
However, if you break the short haul rules more than eight times in a 30-day rolling period, you will need an ELD to log your hours until you get back to the number of eight or fewer in a 30-day period.
Paper logs are not acceptable if you break short haul, law enforcement and DOT will consider you to not have a logbook. And since the April 1, 2018 deadline for 'Soft Enforcement' has ended, this may effect your carrier's CSA score.
How does FMSCA define short-haul?
There are five required components to classify your vehicle as short haul:
- Start and return to the same location within 12 hours of duty time
- Drive no more than 11 hours
- Have 10 consecutive hours off between shifts
- Maintain your time clock function or time card
- Not exceed a 100 air-mile radius from your starting location
How to maintain short-haul
If your drivers change their normal work-reporting location from time to time, they must maintain RODS for trips between the locations. According to the FMCSA:
...when the motor carrier changes the normal reporting location to a new reporting location, that trip (from the old location to the new location) must be recorded on the record of duty status because the driver has not returned to his/her normal work reporting location.
Under the DOT guidelines, drivers who claim short haul must have proper documentation aka "mandatory information" to backup the claim including:
(1) the time the driver reports for duty each day;
(2) the total number of hours the driver is on duty each day;
(3) the time the driver is released from duty each day; and
(4) the total time for the preceding 7 days in accordance with §395.8(j)(2) for drivers used for the first time or intermittently.
Another thing to keep in mind is that the driver's name, or other identification along with the date worked must appear on the timecard.
Using paper RODS as timecards
You may use paper records of duty status (RODS) as timecards if you are claiming short-haul, but bear in mind that paper logs are not acceptable if you break short-haul.
What to do if you need to break short-haul
Drivers who leave the 100 air-mile radius more than 8 days out of a 30 day rolling period will need to maintain RODS with and ELD, from the FMCSA:
The driver must only have in his/her possession a record of duty status for the day he/she does not qualify for the exemption.
A driver must begin to prepare the record of duty status for the day immediately after he/she becomes aware that the terms of the exemption cannot be met.
The record of duty status must cover the entire day, even if the driver has to record retroactively changes in status that occurred between the time that the driver reported for duty and the time in which he/she no longer qualified for the 100 air-mile radius exemption.
This is the only way to ensure that a driver does not claim the right to drive 10 hours after leaving his/her exempt status, in addition to the hours already driven under the 100 air-mile exemption.
Why Short Haul is Being Used
Some carriers are using the short haul exemption to avoid using ELDs all together. Many business owners and fleet managers feel it is too much of a headache to deal with ELDs.
The issue is that many safety managers rushed into finding an ELD to be compliant with the changing laws and regulations. They didn't take the time to research which fleet management company fits their specific fleet needs. While ELDs are still somewhat new to the trucking industry, it can be challenging to find a reputable company to trust.
Finding the Right ELD
When you do your research and find a fleet management company that:
- Works with you
- Customizes a solution for your mobile workforce
- Has easy to use technology
- Helps you with any problems along the way
It makes managing any fleet of vehicles so much easier. ELDs were designed to make fleet management overall more efficient. Many companies just haven't had the luxury of finding an ELD system that operated to their liking. It's common to hear "we don't like using ELD's, they never work properly and make things more difficult," and it's hard to fault a carrier for those feelings.
Think about similar sentiments said about any new technology brought into trucking like automatic transmissions, DEF, and Forward Collision Warning systems. Time will help mature the ELD into a regular staple in the industry and shed the negative stigma behind the technology.
Once you have a system that works how you expect and want it to, it allows you to spend that time you were fixing your ELD logs to review the other capabilities that come with ELD like tracking, timecards and maintenance reports that can allow you to operate at a much more productive level.
Learn more about making the switch from AOBRD to ELD.