Review the vehicle’s use, not only the company name
A contractor may assign a road vehicle to different kinds of work. Create an inventory showing the vehicle, its actual service activity and any other transport assignments before deciding which units need an ELD. Do not assume every vehicle used by a utility contractor follows one logging rule.
49 CFR 395.1(n) excludes drivers of qualifying utility service vehicles from Part 395; the definition is in 395.2. Have the carrier document whether that definition applies to the specific operation. A company label is not a substitute for that assessment.
Utility contractor evaluation worksheet
| Inventory field | What to establish |
|---|---|
| Road vehicle and engine | Actual unit, model year and connector |
| Service activity | Work the vehicle performs and the basis for the rule decision |
| Other assignments | Transport work needing a separate applicability review |
| Driver and mobile device | Named user, supported phone or tablet and training needs |
Bring the actual truck configuration
For units that require or elect to use an ELD, ask Factor ELD to confirm the specific configuration and show vehicle selection and record review using the PT30 manual where applicable.
Keep bucket controls, power take-off equipment and job-management functions outside the proposed driver-log scope unless separately documented. Test one representative road vehicle before extending a recommendation to the fleet.
For the broader fleet discussion, see construction. Use the ELD rollout checklist to assign training and review responsibilities, and check ELD applicability for the actual operation.
Utility contractor questions
Does working for a utility automatically require an ELD?
No. Establish the actual operation and any applicable exception before selecting equipment.
Does the proposal include bucket or field-project monitoring?
Those capabilities are not established by the driver-log documentation. Specify them separately if needed.