Have a qualified reviewer determine which rules apply to your exact operation. An “oilfield exemption” label alone does not establish eligibility.
What this means for your fleet
For each operation, record the vehicle and equipment, driver’s work, location, and trip. Identify the rule that applies and keep the facts supporting any exception. Test how drivers record duty and contact support at remote sites.
Example to try with your fleet
A qualified reviewer checks a specialized well-service vehicle separately from a general equipment hauler. The review records the vehicle’s construction, driver training, well-site waiting, and route, then cites the rule that applies. The fleet also prepares for loss of connectivity. An oilfield job title alone does not establish eligibility for an exception.
What to check
Use these checks before buying or setting up an ELD. Record the results and resolve any problems before rollout.
| Check | How to verify |
|---|---|
| 1. Get a qualified applicability review | Retain the exact driver, vehicle, service, trip, commerce, jurisdiction and claimed provision with a named qualified reviewer and dated decision. |
| 2. Document each special rule basis | For every special rule, keep the current provision, conditions, supporting facts, excluded operations, decision owner, result, and recheck trigger. |
| 3. Test offline and reconnect behavior | Run a controlled connection loss; retain events before/during/after, queued order, gaps or duplicates, user actions, defect, support case, and retest. |
| 4. Record waiting and equipment movement | Keep arrival, waiting, loading, equipment movement, public-road driving and departure events with timestamps, locations, actual statuses, and annotations. |
| 5. Prepare for a malfunction | Practice the documented malfunction procedure. Check driver notification, the carrier’s response, reconstruction of required records, paper logs, and repair arrangements. Record the outcome and repeat the exercise after correcting errors. |
Limits and exceptions
Use this guide to plan your checks; it does not determine whether a legal exception applies, certify a record, or guarantee compliance, safety, savings, or audit results. Preserve original ELD records and edit history. Use the current rules to determine applicability and the manual for your installed device for operating instructions.
Sources and review date
Reviewed August 10, 2026. Check the latest rules and product information before changing your procedures or signing a contract.
- 49 CFR Part 395: hours of service and ELD requirements — Office of the Federal Register and U.S. Government Publishing Office.
- ELD malfunction and data-diagnostic responsibilities — Federal Motor Carrier Safety Administration.
- Factor ELD products, plans, and support — Factor ELD.
Try the ELD on a typical route
Tell us about your truck, phone, route, and a task you want to test. Request a Factor ELD demo to see how the product works. Your fleet remains responsible for deciding which rules apply.