ELD Mandate Update: Short Term Rental Exemption

Previously, we reported that the Truck Renting and Leasing Association (TRALA) filed for an exemption with the FMCSA for short-term rental vehicles from requiring ELDs for short-term breakdowns for up to 30 days. The FMCSA published in the Federal Registry, as of October 10, 2017, that an exemption will be granted for short-term trucks. Instead of covering trucks rented for 30 days, as petitioned by TRLA, the FMCSA will grant the exemption for trucks rented eight days or fewer.

Here are the key things to know:

  • This exemption covers a rental period of eight days or fewer, whether or not a breakdown.
  • If there is a continuous eight-day cycle of a rental — as in renewing every eight days — it will be considered a violation. The violation would be that of failing to use an ELD.
  • Drivers using this exemption are still subject to Hours of Service limits and must keep RODS if required.
    • The driver must possess copies of their RODS for the current day and the prior seven days if required on those days. If you’re running short haul, RODS are not required.
  • Drivers must have a copy of this notice or equivalent signed FMCSA exemption document in their possession while operating under the terms of the exemption.
    • The exemption document must be presented to law enforcement officials upon request to show they are under the exemption.
  • Drivers must have a copy of the rental agreement in the CMV, and make it available to law enforcement officers on request.
    • The agreement must clearly identify the parties to the agreement, the vehicle, and the dates of the rental period. This verifies the term of the rental period does not exceed eight days.