ELDs (Electronic Logging Devices) vs. IFTA and IRP Requirements
Many carriers will be required to install ELDs in their vehicles to comply with DOT requirements by the end of 2017. However, don't assume that the ELD will record all mileage information required by IFTA and IRP. Some important points to consider when purchasing an ELD or other GPS system that you would also like to use for IFTA and IRP reporting are:
- IFTA and IRP require that the data be collected for individual vehicles (vs. drivers).
- The data must be retained and/or accessible for four years for IFTA and five years for IRP.
- IFTA and IRP require that ALL miles be recorded and logged, even if exempt from ELD.
- IFTA and IRP required the miles to be recorded between signals, (pings,) and for the reports to list routes, miles per state and total miles.
Did You Know: Regarding ELD implementation
Enforcement of the Electronic Log Mandate Begins December 18.The electronic logging device (ELD) mandate takes effect on December 18, 2017. In a recent survey 60% of fleets running between one and 100 trucks indicated they have not yet put electronic logs in their trucks. Virtually every truck driver will need to start using an ELD on that date, with the following exceptions.
- Drivers of vehicles with engines manufactured before model year 2000.
- Drivers who conduct driveaway-towaway operations where the truck being driven is the product being delivered.
- Short haul drivers using the logbook timecard exception (i.e., 100 air miles for CDL drivers or 150 air miles for non-CDL drivers).
- Drivers of trucks rented for 8 days or less.
One of the biggest questions asked is about the 100-air mile exception for CDL drivers who do not have to use a logbook. A one-page summary of the exception is available.
Recently the Commercial Vehicle Safety Alliance affirmed that officers will begin enforcing the rule on December 18 with fines and citations issued; however, there will be some limited enforcement modifications as follows:
* FMCSA has directed roadside enforcement personnel to issue violations under 49 C.F.R. 395.22 – Registered ELD Required – until April 1, 2018. This violation will not be included in a carrier's Compliance, Safety, Accountability profile and will therefore not negatively impact a carrier's CSA scores.
* Drivers without electronic logs will not be placed out-of-service until April 1, 2018if they are in compliance with the hours of service regulations.
* Beginning April 1, 2018 roadside enforcement who find a driver operating without an ELD will begin issuing citations under 49 C.F.R. 395.8 – for failure to have a record of duty status. These drivers will be placed out-of-service until they have corrected the problem by repowering the load with a driver not required to use an ELD or having one installed.