1. The short-haul exception
This is the exemption most fleets can use. A driver who operates within a 150 air-mile radius of their normal work reporting location, returns to that location within 14 consecutive hours, and starts and ends at the same place is not required to keep RODS. A driver not required to keep RODS is not required to run an ELD.
The carrier keeps time records instead: report time, release time, and total hours on duty each day, retained for six months. That is a lighter burden than full logs.
- 150 air miles is roughly 172 road miles, and it is measured as a straight-line radius rather than driving distance.
- Blow the 14-hour return even once and that day requires a full RODS.
- Exceed the exception more than 8 days in any 30-day rolling period and the driver needs an ELD.
The 8-days-in-30 rule is where fleets slip. A short-haul driver who covers a long run twice a month is fine. Twice a week is not.
2. Engine model year before 2000
If the vehicle's engine model year is 1999 or earlier, no ELD is required. Note that this is the engine model year, not the vehicle model year and not the VIN year. A glider kit with a rebuilt older engine can qualify even in a much newer chassis.
Keep documentation. An officer looking at a 2015 truck has no reason to believe the engine is a 1998 unless you can show it.
3. Driveaway-towaway operations
When the vehicle being driven is itself the commodity being delivered, the ELD requirement does not apply. A truck being delivered to a dealer, an RV moved to a buyer, or a tow operation where the towed unit is part of the shipment all fall here.
This one is narrow and specific. Hauling freight in a truck you also happen to be selling is not a driveaway operation.
4. Drivers who rarely keep RODS
A driver who is required to keep RODS on 8 days or fewer within any 30-day period may use paper logs for those days. This catch-all covers occasional long runs by otherwise-local drivers, seasonal work, and the mechanic who takes a truck out of the radius twice a quarter.
It is a rolling 30-day window rather than a calendar month. Fleets that track it on a calendar find themselves out of compliance in the last week of a busy month.
Agricultural operations: an HOS exception, not an ELD one
The agricultural commodity exception suspends HOS requirements entirely for the transport of agricultural commodities, livestock, or farm supplies within a 150 air-mile radius of the source during planting and harvesting seasons as defined by the state.
Because HOS doesn't apply during those movements, there is nothing to record. But the moment a driver operates outside the radius or outside the defined season, the normal rules snap back into place, including the ELD requirement. The device is still expected to be in the truck.
Agricultural relief comes from the HOS side. It is an exception to the hours, not permission to leave the ELD behind.
Things people think are exemptions and aren't
This list is longer than the real one, and every item on it has been argued at a roadside inspection.
- Owner-operators. Fleet size has never been a factor. A one-truck operation subject to RODS needs an ELD.
- Intrastate-only operation. The federal rule targets interstate commerce, but most states have adopted equivalent intrastate rules.
- Leased operators. The requirement follows the operation, not the ownership structure.
- Running under 26,001 lbs. The CMV threshold for HOS purposes is 10,001 lbs GVWR, not the CDL threshold.
- Hauling your own goods. Private carriage is still commercial motor carrier operation.
- Being a small business. There is no small-carrier exemption.
If you're exempt, document it
An exemption you can't demonstrate at the roadside is functionally not an exemption. Keep the engine model year documentation in the cab for pre-2000 vehicles. Keep time records current for short-haul drivers. Keep a written policy describing which drivers operate under which exception and how you monitor the 8-day threshold.
You are not trying to win the argument later. You are trying to not have the argument.
