While FMCSA still in Phase 2 of ELD Implementation, December 16, 2019, is a critical date as the AOBRD grandfather provision expires. This provision allows fleets that had AOBRDs installed in their trucks prior to December 18, 2017, to continue using AOBRDs for two years following the ELD Compliance Date. Beginning December 16, 2019, motor carriers and drivers subject to the ELD rule must use self-certified ELDs that are registered with FMCSA.
The ELD rule applies to motor carriers and drivers who are currently required to keep records of duty service (RODS) under the hours-of-service (HOS) regulations. Drivers who use the time card exception, and don’t keep paper RODs, will not be required to use ELDs. The following drivers may keep paper RODS:
- Drivers who keep RODS no more than 8 days during any 30-day period.
- Driveaway-towaway drivers (transporting a vehicle for sale, lease, or repair), provided the vehicle driven is part of the shipment or the vehicle being transported is a motor home or recreational vehicle trailer.
- Drivers of vehicles manufactured before model year 2000.
However, a carrier can choose to use an ELD, even if it is not required.