Determine whether an ELD is required
Separate the recording method from the HOS limits.
RODS first, device second
A record of duty status (RODS) records the driver’s work and rest. Covered drivers who need RODS generally need an ELD unless a specific exception applies. An ELD exception may allow paper logs; it does not automatically remove HOS limits.
Check the specific recording exception against the actual work pattern.
Common ELD exceptions
- RODS required on no more than eight days in any rolling thirty-day period.
- Qualifying driveaway-towaway work, including when the driven vehicle is the delivered commodity and specified recreation-vehicle moves.
- Qualifying pre-2000 vehicle/engine cases under FMCSA model-year guidance, including its replacement-engine rules.
For the eight-day rule, count days requiring RODS, not calendar months or only driving days. Include days when a short-haul driver no longer meets the time-record exception.
Keep evidence of eligibility
For an older-engine exception, retain the applicable model-year evidence. Truck age by itself, a verbal claim, or the trailer’s year is not enough.