The Best ELD for AG Haulers: 3 Things Your AG ELD Should Have
Wait a minute, “Best ELD for AG Haulers”, I thought AG Haulers were exempt from hours of service (HOS) rules when hauling agricultural loads and were not required to use an electronic logging device (ELD). Technically, you are correct, the FMCSA provides for the “Agricultural Commodity” Exception in 49 CFR 395.1(k)(1) to the Hours of Service Regulations, but there are very specific requirements that must be met to use the AG exemption. If you meet all of the requirements, which I will not go into here, you are not required to use an ELD nor keep paper logs to track HOS while operating within the “exemption zone”, a 150 air (172 statute) mile radius from the origin of the agricultural commodity.
A 172 statute mile radius circle is a HUGE area, in fact, it’s 92,940.88 square miles. That is an area approximately 95.7 % the size of the state of Wyoming or 134 % the size of the state of North Dakota. So if you are lucky enough to have an area of operations about the size of Wyoming and the distance from the origin of an agricultural commodity to the processing plant is less than 172 statute miles and don’t go any further, then yes, you are correct, you are exempt from HOS rules and don’t have to read any further. But, if you are an AG hauler that has an area of operations where you drive beyond the 172 statute mile radius, your professional life just got a whole lot more complicated with certain working and driving hours being exempted from HOS rules and others being subject to them. The minute the 150 air-mile radius boundary is crossed, you are subject to HOS rules and are required to use an ELD.
How Do I Know If My ELD Supports AG?
The best way to evaluate an ELD is to examine the different criteria through the filter of two words, automatic or manual. Does the ELD application handle the criteria automatically, requiring no or very little interaction from the driver or does the app require the driver to complete certain steps manually at different times during the trip? The more manual intervention by the driver, the higher the level of distraction, the less actual driving done by the driver, and the lower the evaluation score for the ELD app. The more the ELD app can do automatically to manage the driver’s HOS and keep track of his location within the AG circle and determine when a zone boundary is crossed, the better.
3 Criteria for AG Friendly ELD
1. Determining the 150 Air Mile radius based on the Agricultural Commodity origin point.
2. Handling of duty status changes when crossing the radius boundaries.
3. Dealing with the five AG exemption scenarios.
Determining the accurate determination of the 150 air-mile radius boundary is extremely important to ensure you are in strict compliance with the FMCSA AG exemption. Does the ELD application use the latest in GPS technology to establish an extremely accurate geofence once the AG exemption is activated? Does the ELD app provide the driver with the ability to set the origin location based on the current location or by typing in an address of the origin? Once the AG exemption is activated and the radius is established does exemption remain in effect until it is deactivated? Or does the ELD application leave it to the driver to determine the appropriate 150 air-mile radius on his own? Either by using a separate application or the old school approach of a paper map and string to draw out the circles. Was that air miles or statute miles? Where do you get a copy of an actual map today?
An ELD application with a fully integrated GPS mapping function to create an AG exemption geofence that shows the driver where the driver is located and when he crosses the boundary is the best solution.
The 150-air mile AG exemption boundary represents either exemption from HOS rules inside the boundary or following the FMCSA HOS guidelines outside it. Does the ELD application automatically manage your duty status and monitor your working and driving hours based on the driver’s current GPS determined location? Does the app automatically change the appropriate duty statuses and start or stop the driver’s 14-hour duty and 11-hour driving clocks when crossing the AG exemption boundary? Or does the ELD application require a series of manual duty status changes, making annotations to explain the movement is exempt per the agricultural exemption, or even go so far as to unplug the ELD device while the driver is within the 150 air-mile radius to be managed using the Unidentified Driver records process? An ELD application that requires constant manual status changes, interactions, and monitoring puts the driver at risk from distraction from his primary focus of driving.
An ELD application that provides automatic status changes and management of duty and driving hours both inside and outside the 150 air-mile radius allows the driver to focus on safely operating the truck without unnecessary distractions.
Being compliant with the FMCSA’s Agricultural Commodity exemption is a complicated business. To clarify these guidelines, they provide Agriculture Exemption Diagrams, at https://www.fmcsa.dot.gov/hours-service/elds/agriculture-exemption-diagrams which explains five different scenarios a driver might encounter both inside and outside the AG exemption zone.
Each of these scenarios,
1. Moving from outside to inside
2. Inside to outside
3. Inside to outside to inside
4. Inside one zone to outside to inside another zone, or several pickups inside to one delivery outside
All require different duty status changes and HOS management. Giving this additional responsibility to a driver to complete manually will be both frustrating, unproductive, and possibly error-prone. Activating the AG exemption using a fully automated ELD application makes it easy to keep track of ALL the driver’s activities both inside and outside of the AG exemption zone.
While AG Haulers are not required to use an ELD while operating within the 150 air-mile radius AG exemption zone and it is often viewed by truckers as a pain in the neck, what better way to PROVE you are within FMCSA compliance with an ELD system with fully integrated AG exemption functionality.
If you are an AG Hauler operating inside and outside the 150 air-mile radius exemption zone it makes perfect sense to capitalize on the most automated ELD solution on the market to keep track of ALL of your driving and duty hours.