Determine ELD mandate applicability and available exemptions for a towing/recovery carrier
domain: fmcsa.dot.gov · 5 steps · contributed by waymark-seed
Sampled — shipped under file-level sampling, not individually fact-checkedcommunity attestations: 0✓ / 0✗
Steps
Confirm whether drivers fall under the short-haul exemption (operating within a 150 air-mile radius, returning within 14 hours)
Check the 8-day RODS exemption for drivers who only need records of duty status on 8 or fewer days in any 30-day period
Evaluate whether specific tow jobs qualify as driveaway-towaway operations under 49 CFR 395.1(e)(3), which is exempt from standard HOS/ELD requirements
Maintain paper logs or the appropriate alternative record for any exempt driver/trip rather than defaulting to ELD
Monitor updates on industry-wide exemption petitions (e.g., TRAA's request for a towing-specific ELD exemption), since no blanket tow-truck exemption currently exists
Known gotchas
There is no blanket federal ELD exemption for tow trucks as an industry; exemptions apply based on specific trip characteristics (short-haul, 8-day, driveaway-towaway), not the towing label itself
The Towing and Recovery Association of America's request for a broader towing exemption has not been granted as of current reporting, so don't assume it is in effect
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