Start with whether the vehicle itself is the shipment
49 CFR 395.8(a)(1)(ii) permits manual duty-status records instead of requiring an ELD in specified driveaway-towaway operations, including where the vehicle being driven is part of the shipment delivered. An ELD exception does not by itself erase other applicable hours or recordkeeping duties.
Describe the actual movement and identify the vehicle being delivered, the vehicle being driven and any later nonqualifying assignment. Carrying automobiles as cargo on a transport truck is a different fact pattern from driving the delivered vehicle; do not apply the same conclusion just because both involve vehicle delivery.
Driveaway-towaway evaluation worksheet
| Decision point | Next question |
|---|---|
| Vehicle being driven is part of the shipment | Does the actual operation meet the specified exception? |
| A separate truck carries the vehicles | What recording requirements apply to the carrier and driver? |
| Different assignment follows | Does the earlier exception still apply to this movement? |
| ELD required or voluntarily chosen | Can the actual vehicle and installation arrangement support it? |
Bring the actual truck configuration
If an ELD is appropriate, ask Factor ELD to review engine and connector details and obtain permission for any installation on a delivered vehicle. Do not assume equipment can be attached to every customer-owned unit.
The PT30 manual provides vehicle-selection and log-review steps for that product. Use those as a demonstration only after compatibility and the proposed installation arrangement are confirmed.
For the broader fleet discussion, see auto transport. Use the ELD rollout checklist to assign training and review responsibilities, and check ELD applicability for the actual operation.
Driveaway-towaway questions
Must every driveaway operator buy an ELD?
No. The federal rule permits manual records for qualifying operations. Establish applicability before choosing a product.
Does an ELD exception mean there is no daily record to keep?
Not necessarily. The exception concerns the recording method; other applicable duties and records still need review.