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Safety Corner

Ask our panel of experts, Marc, Guy and Brayn, any questions you may have around fleet safety, compliance, DOT audits, roadside inspections, CSA scores, or installation best practices.

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A reader of Marc's Safety Corner and customer of BigRoad recently asked an interesting question. How are Hours of Service (HOS) recorded when you have two vehicles – one that is ELD-enabled, while the other is not? Below, read Marc’s expert answer.

Truck driver looking at his mobile device and hours of service.


We have a small fleet of three trucks, of which two trucks are new Ford F450 pulling trailers. Our third truck, a 1998 Kenworth, isn't ELD compatible. If a driver begins the day with an F450 and needs to switch to the Kenworth, how is that recorded? Also, what do you present for the inspection?


Dear Reader,

To begin, I will make a few assumptions, as I don't have the full scope of your operations for ELD purposes.

  1. My first assumption is that the Ford F450s pulling trailers are, in fact, Commercial Motor Vehicles (CMV), as defined in Part 390 of Federal Motor Carrier Safety Regulations. Specifically, a CMV means any self-propelled or towed motor vehicle used on a highway in interstate commerce to transport passengers or property when the vehicle:
    1. Has a gross vehicle weight rating or gross combination weight rating, or gross vehicle weight or gross combination weight, of 4,536 kg (10,001 pounds) or more, whichever is greater; or
    2. Is designed or used to transport more than eight passengers (including the driver) for compensation; or
    3. Is designed or used to transport more than 15 passengers, including the driver, and is not used to transport passengers for compensation; or
    4. Is used in transporting material found by the Secretary of Transportation to be hazardous under 49 USC. 5103 and transported in quantity requiring placarding under regulations prescribed by the Secretary under 49 CFR, subtitle B, chapter I, sub-chapter C.

Therefore, any 1 of these four categories makes the above vehicles a CMV.

  1. My second assumption is that the Ford F450s are manufactured in the year 2000 or later.
  2. My third assumption is that you are not otherwise exempt by any section in Part 395, therefore require an ELD in specific instances.

As you likely know, the ELD rule allows limited exceptions to the ELD mandate, including drivers of vehicles manufactured before 2000. Therefore, the driver of the 1998 Kenworth is not required to comply with ELD. That said, the driver of this commercial motor vehicle is still bound by the RODS requirements in 49 CFR 395. Therefore, he must prepare RODS when required, using paper logs, an Automatic On-Board Recording Device (AOBRD), or a logging software program.

On the other hand, when the driver is operating one of the fully regulated F450 trucks with a trailer, he will now require the deployment of a certified ELD (unless otherwise exempt).

In this specific instance, just before he or she is about to operate the F450 pulling a trailer, a driver should have in his or her possession a signed statement that gives the total time on duty during the immediately preceding seven days. Moreover, the time at which the driver was last relieved from duty before beginning work for the motor carrier.

In the alternative that the driver was going from an ELD-deployed vehicle to a non ELD-deployed vehicle, the driver may present copies of the day in question when stopped by DOT, along with the previous seven days' records of duty status or a print-out from his or her motor carrier's ELD system.

The above information is for informational purposes only, and should in no way be relied upon as legal advice.

  Jul 30, 2019     Marc Moncion

Ask the expert - Marc Moncion (Safety, compliance and regulatory affairs expert)


Marc Moncion linkedin2

Lead Expert - Fleet Complete

Marc is the Head of Safety, Compliance & Regulatory Affairs at Fleet Complete. He is an author and industry subject matter expert who has worked in numerous senior transportation management roles for over 25 years, including an Inspector for the MTO. Marc sits on several Federal/State/provincial regulatory bodies and frequently provides commentary on emerging technology, best practices and regulatory affairs. In addition, Marc is a commercial driver's licence (CDL) holder and can drive all types of commercial vehicles in North America.

Get to know Marc here!



Ask The Expert - Guy Broderick (Driver trainer)


Guy Broderick linkedin2

Guest Expert - APPS Transport Group

Guy is a Driver Recruiter/Training Supervisor and Social Media Specialist at APPS Transport Group. Certified under the WSIB guidelines and a member of JHSC, Guy is an integral force behind the company's impeccable driving record. The APPS Safety Team has achieved the highest rating of Commercial Vehicle Operator Registration (CVOR) given by the Ministry of Transportation in Ontario. Since 2010, Guy has written for and contributed to numerous publications and associations, as well as has been elected as Chair of Ontario College of Trades Tractor Trailer Driver Trade Board, recently re-elected as Chair for the TTSAO Carrier Group, has sat on numerous provincial industry committees and is a Award Winning Driver recognized on both sides of the border.



Ask The Expert - Brayn Levi Gomez (professional installer)


Brayn Gomez  linkedin2

Guest Expert - Certified Professional Installer

Brayn transformed his passion and hobby of installing multimedia devices and car kits in luxury vehicles into a career in 2004. Since then, Brayn has installed thousands of electronics and GPS systems in a variety of vehicles and machines with or without a power source, even on bicycles. Bryan provides professional installation, re-installation and on-site technical services to Fleet Complete customers. Throughout his career, Brayn has encountered the effects of improper GPS system installation on the integrity of the vehicle and driver's safety, and offers his insights and tips to help ensure fleet managers and technicians are using best practices to install GPS equipment in their vehicles.