The document discusses the upcoming ELD mandate requiring most commercial vehicles that cross state lines to use electronic logging devices to track hours of service by December 18, 2017. It explains that the law applies to vehicles over 10,000 lbs and vehicles transporting more than 8 passengers, with some exceptions. The document provides steps fleets should take to comply, including determining applicability, selecting a provider, installing devices, and training drivers. It recommends Geotab's ELD solution and notes long-term benefits will be improved safety and cost savings despite short-term costs of compliance.

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THE PATH TO ELD
COMPLIANCE
WHITE PAPER SPRING 2017

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The Federal Motor Carrier Safety Administration (FMCSA) is requiring Electronic
Logging Device (ELD) compliance beginning December 18, 2017. As the
deadline fast approaches, professional drivers and fleet managers are seeking
clarification on whether or not the new law applies to their operations and, if so,
how to transition to the new technology.
The FMCSA notes that most carriers and drivers currently logging hours of
service (HOS) to meet records of duty status (RODS) regulations are affected,
with some exceptions. This can be misleading because there are many operators
who may not realize they are required to keep logs, so they are already out of
compliance and will be affected by the new law. Every month, tens of millions
of dollars in fines are leveed for HOS and RODS violations, so the first order
of business for operators is to evaluate their vehicle classifications and usage
to determine whether or not they should be implementing the technology and
procedures required to meet all regulations.
The good news is that there are substantial benefits from the improved driver
safety and hours-of-service monitoring efficiencies ELDs provide, including
potential long-term cost savings.

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DO WE NEED TO COMPLY?
The misperception that the new ELD mandate only applies to those currently
using logs has created some confusion. The law applies to all interstate
Commercial Motor Vehicles (CMVs) as defined by the Department of
Transportation that are required to maintain logs, which would affect those
currently using paper logs, logging software or automated onboard recording
devices (AOBRDs). In addition to trucking and busing, this can include fleets with
box trucks, passenger vans, and even some heavy-duty pickups.
COMMERCIAL MOTOR VEHICLES ARE USED ON A HIGHWAY IN INTERSTATE
COMMERCE TO TRANSPORT PASSENGERS OR PROPERTY AND HAVE THE
FOLLOWING SPECS AND USAGE:
• A gross vehicle weight rating or gross combination weight greater than 10,000
pounds (whichever is highest)
• Designed or used to transport more than 8 passengers (driver included) for
compensation
• Transports material deemed hazardous by the Secretary of Transportation in a
quantity requiring placarding
THE PATH TO ELD COMPLIANCE
OVER 10,001 LBS
COMBINED WEIGHT
HAZARDOUS
MATERIALS
MERCHANTSFLEETMANAGEMENT.COM
MORE THAN
8 PASSENGERS
(DRIVER INCLUDED)
FOR COMPENSATION
NEXT
STEPS Prepare a training schedule for drivers
and support staff
WHO NEEDS
TO COMPLY? HEAVY-DUTY
PICKUPS
PASSENGER
VANS
BOX TRUCKS
BUSES
TRUCKS
1.
2.
3.
4.
5.
Determine if you fall under these regulations
and need to comply
Select a certified ELD provider
Purchase and install ELDs
Develop procedures to incorporate the ELD
rule into day-to-day operations
MORE THAN
15 PASSENGERS
(DRIVER INCLUDED)
NOT FOR COMPENSATION

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THERE IS A SHORT-HAUL CMV EXEMPTION. TO QUALIFY FOR THAT EXEMPTION
YOU MUST:
• Operate within a 100-mile radius of your home base if you are driving with a
commercial driver’s license, or within 150 air miles for non-CDL drivers
(Applicable only within the state lines. As soon as a vehicle crosses a state line they are no longer exempt)
• Start and return to the same location within 12 hours of duty time
• Drive no more than 11 hours and have 10-hour breaks between shifts
• And use a time clock
WHAT IS THE TIMETABLE?
YOU MUST BE USING ELDS NO LATER THAN DECEMBER 18, 2017 IF:
• You operate CMVs requiring RODS including those currently using paper logs
or logging software
YOU MUST IMPLEMENT ELDS BY DECEMBER 16, 2019 IF:
• You are using ABORDs before December 18, 2017
EXCEPTIONS:
• Drivers who use the timecard exception and do not keep RODS
• Drivers who use paper logs 8 days or less in a 30-day period. (This is a
consecutive 30-day period, not a calendar month.)
• Driveaway-towaway operations in which the vehicle being driven is also the
commodity being delivered
• Vehicles older than model year 2000 because they will not have the electronic
control module needed for ELD integration

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ARE WE ALREADY COMPLIANT IF WE USE
MONITORING?
Only those operators that have already integrated federally approved and
registered ELDs and trained drivers and administrators to use them are
already complying. Those using AOBRDs have more time to comply, but those
systems do not satisfy the requirements. ELDs must meet the exact technology
specifications in the rule. It is the manufacturers’ responsibility to meet those
specifications, self-certify and register their devices with the FMCSA.
ELDS MUST BE ABLE TO:
• Integrally synchronize with the commercial motor vehicle’s engine to capture
engine power status, vehicle motion, miles driven and engine hours (GPS-
derived data is not allowed as a substitute)
• Automatically record date, time, location information, engine hours, and
vehicle miles in addition to identification information for the driver, vehicle, and
motor carrier
• Be able to provide data to an authorized safety office on demand during
roadside inspections by either a telematics transfer via wireless web services
and email or a local transfer via USB2.0 and Bluetooth®
• Be manufacturer certified as compliant and registered on the FMCSA’s website
WHAT STEPS SHOULD WE TAKE NOW?
MOTOR CARRIERS AND DRIVERS SHOULD:
• Determine if they fall under CMV regulations for HOS/RODS, and thus need to
comply with the ELD law
• Select a certified ELD provider that delivers the best solution for your fleet
operations and can implement before the deadline so you have time for training
• Allocate the funding needed to purchase and install ELDs
• Develop and implement procedures that incorporate the ELD rule into day-to-
day operations
• Prepare a training schedule for drivers and support staff

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MERCHANTS RECOMMENDED ELD SOLUTION
Merchants Fleet Management product specialist, technology experts and
strategic consulting team evaluated available ELD solutions and recommends
Geotab Drive, Geotab’s FMCSA-compliant solution for hours of service (HOS),
driver/vehicle inspection reporting, and driver identification. The smart driver
app synchs data between the Geotab GO device and a tablet to provide
functions such as automatic duty status changes, violation alerts, and complete
end-to-end inspection workflow.
To schedule a demo of Geotab Driver, contact Merchants by emailing:
leasecontact@merchantsfleet.com.
LONG-TERM BENEFITS
The ELD mandate was established to make it easier to keep logs and inform
drivers and carriers so they can better manage fatigue. Increased safety leads
to fewer accidents, which saves lives in addition to reducing costs. ELDs will
also streamline logging procedures, cut down on paperwork and facilitate
quicker roadside inspections.
Fleet managers should begin the implementation process as soon as possible
in order to find the right ELD solution and have enough time to transition and
train their professional drivers.
Merchants Fleet Management can help you meet new rules and regulations
and stay compliant so you can focus on your core business operations. Visit
merchantsfleetmanagement.com for more information.
To read the ELD Rule in its entirety, visit the Federal Motor Carriers Safety
Administration website.
DISCLAIMER: The information contained in this paper has been provided by Merchants Fleet Management
for information purposes only and is based on our interpretation of the FMCSA published rules and
regulations. This information does not constitute legal, professional or commercial advice. While every
care has been taken to ensure that the content is useful and accurate, Merchants Fleet Management
gives no guarantees, undertakings or warranties in this regard, and does not accept any legal liability or
responsibility for the content or the accuracy of the information so provided, or, for any loss or damage
caused arising directly or indirectly in connection with reliance on the use of such information.
References: Federal Motor Carriers Safety Administration; “ELD Exemptions” by Vik Sridhar, Geotab
solutions engineer and HOS expert.