Private-carrier status does not by itself remove HOS or ELD duties. Applicability depends on the vehicle, driver, commerce, route, and operation, so a fleet hauling its own goods still needs a documented determination.
What this means for your fleet
Private fleets often combine delivery, service, sales, maintenance, and warehouse roles. Map when an employee becomes a covered driver and how non-driving work is recorded before dispatch.
Example to try with your fleet
A warehouse employee hauls the company’s goods across state lines twice a week after doing warehouse work. Before the trip, the fleet checks the vehicle and route, determines whether a record of duty status (RODS) is required, and confirms how to record warehouse work. It also checks the employee’s ELD account and any applicable state rules.
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. Classify vehicles and commerce | Keep each vehicle/VIN and rating, owned/private use, route, commodity, commerce, jurisdiction, current provision, reviewer, and classification. |
| 2. Identify covered employee-drivers | Retain each employee-driver role, driving frequency, vehicle, RODS requirement, claimed exception, supporting facts, reviewer, and result. |
| 3. Map warehouse and service work | Time warehouse, loading, service, driving and paperwork events; keep actual statuses, annotations, route, driver, and review outcome. |
| 4. Manage occasional-driver accounts | Check the driver’s account, vehicle assignment, and training before each assignment. Disable unused accounts and resolve shared-login problems; each driver must use their own account. |
| 5. Review exceptions and state rules | Cite the applicable state and federal provisions, list exact driver/vehicle/trip facts and exception conditions, name the reviewer, and keep the dated decision. |
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.
- Official ELD exceptions and exemptions FAQ — Federal Motor Carrier Safety Administration.
- FMCSA ELD resources for carriers and drivers — 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.