Follow the decision in order
- Identify the applicable rules. Establish the operation, vehicle and jurisdiction. Interstate and intrastate requirements can differ.
- Determine whether RODS are required. A driver meeting every condition of the relevant short-haul exception may use the required carrier time records instead. For the 49 CFR 395.1(e)(1) exception, the radius is 150 air miles and the driver must return to the normal work-reporting location and be released within 14 consecutive hours, among the other conditions.
- If RODS are required, check a specific ELD exception. Examples include recording RODS on no more than eight days in any rolling 30-day period, qualifying driveaway-towaway operations, and the pre-2000 model-year provisions explained by FMCSA.
- If no exception applies, use the required ELD. Keep the basis for any exception with the carrier’s records and reconsider it when the operation changes.
The calendar-month trap
Five RODS days near the end of one month and four near the start of the next can fall inside the same 30-day period. That is nine days, even though neither calendar month has more than eight. Another applicable exception would need its own basis.
See the detailed applicability guide for the supporting records to assemble.