Are you California electronic logbook law compliant?

Following the Federal Motor Carrier Safety Administration’s (FMCSA) passage of the ELD mandate, California now also requires ELD use by intrastate CMV motor carriers and drivers as of January 1, 2024. This mandate affected 366,800 California CMV drivers, with an estimated 54%—or 200,000 vehicles—not previously using ELDs. 

With the right ELD solution, you can stay compliant while gaining notable business benefits. This comprehensive guide covers what you need to know about the federal ELD mandate, as well as how the recent California rule extending the ELD requirement to intrastate carriers and drivers might impact your fleet. You’ll also learn about how an ELD solution can help your fleet improve operational efficiency, reduce costs, and remain compliant.

What is the ELD mandate?

The FMCSA developed federal regulations mandating that drivers of commercial motor vehicles (CMVs) use ELDs to record their record of duty status (RODS). This regulation, referred to as the ELD mandate, is aimed at improving compliance with applicable Hours of Service (HOS) rules, reducing paper logbooks, and preventing data tampering. The ELD mandate also establishes procedures for data transfers to demonstrate compliance and share RODS with safety officials.

All drivers operating CMVs subject to the ELD mandate are required to record their HOS electronically with an ELD that complies with the specifications in Subpart B of 49 CFR § 395.

What are the HOS rules and ELD mandate considerations in California?

Effective January 1, 2024, California now requires ELD use by intrastate CMV carriers and drivers that meet federal requirements to record their RODS. California is one of the last states to adopt the ELD mandate for intrastate drivers. 

While commercial driver’s license (CDL) holders who operate within California state lines have slightly different HOS requirements, they are still required to use an ELD to record a driver’s record of duty status. For both interstate and intrastate travel, drivers are now required to adhere to ELD guidelines. Here are the differences between the two:

• Interstate travel refers to vehicles, cargo, or passengers that cross state or federal lines. Since the passage of the federal ELD mandate, interstate drivers have been required to use an ELD in California. 

• Intrastate travel refers to vehicles, cargo, or passengers traveling exclusively within the state of California. If travel occurs between two places exclusively within California, but the cargo or passengers are part of a trip that began or will end in another state or country, then commerce is still considered interstate. Intrastate drivers must use ELDs in California as well. 

Though California’s HOS rules differ slightly from federal HOS rules, the California intrastate ELD mandate does not change California’s HOS requirements. Here is a summary of the differences between federal and California HOS.

There are a couple other ways in which the California HOS rules align with federal HOS regulations:

• Drivers must have 10 consecutive hours off-duty to reset for a new work period.

• After meeting the maximum hours in an eight-day workweek, drivers must reset to zero after at least 34 consecutive hours off-duty.

Does the ELD mandate apply to your operation?

Drivers who operate a CMV—vehicles that are used for business purposes and travel interstate—could be subject to ELD regulations, and commercial drivers who are required to maintain record of duty status must comply with the ELD mandate. To be considered a CMV, the vehicle must meet one of the following criteria:

• Weigh more than 10,000 pounds

• Have a gross vehicle weight rating or a gross combination weight rating of more than 10,000 pounds

• Is designed to transport 16 or more non-paying passengers, including the on-duty driver

• Is designed to transport 9 or more paying passengers, including the on-duty driver

• Transport enough hazardous materials to legally require warning placards

In general, if you log Hours of Service, you are required to comply with the ELD mandate. There are a few ELD exemptions, such as drivers who:

• Meet one of the short-haul exemptions in 395.1(e)

• Use paper logs for 8 days or less during any 30-day period

• Conduct driveaway-towaway operations where the vehicle is being delivered

• Drive a vehicle with an engine manufactured in or before the year 2000

There are also several exemptions to the ELD mandate for agricultural transportation in 49 CFR § 395.1(k):

• Covered farm vehicles are exempt from HOS and CDL regulations if the vehicle is over 26,000 pounds and operated within a 150 air-mile radius of the farm. Covered farm vehicles under this weight threshold are always exempt, no matter how far they travel.

• Exemptions are granted during the planting and harvesting periods of each state.

Truck drivers who transport bees or livestock for interstate commerce are exempt from the required 30-minute break when there are animals on board.

What happens if I'm not compliant with the ELD mandate?

CMV drivers operating exclusively within the state of California must comply with the California intrastate ELD mandate. If drivers fail to comply, law enforcement may impose hefty penalties, including: 

• Violations and regulatory fines: Failure of roadside DOT inspections—conducted by the California Highway Patrol (CHP)—and HOS violations can lead to costly fines for organizations and their drivers. Effective January 1, 2024, log book violations can range from $1,496 to $14,960 per driver for errors or falsifications in logbooks. For non-record keeping violations, penalties may reach up to $18,170 per violation.

• Service disruptions and Out-of-Service (OOS) Orders: HOS logbook and ELD compliance violations can not only lead to service disruptions and delays, they can also lead to more serious action such as FMCSA-enforced Out-of-Service Orders, which prohibit the organization from operating commercial vehicles until the identified issues are corrected. If a driver is caught operating without a compliant ELD, they may be placed out of service for 10 hours (for first-time offenses). If the violation continues after the OOS period, further penalties can apply, including suspension of operating authority.

• Increased insurance costs: Repeat non-compliance can lead to lower CSA scores and increase insurance premiums if the organization is deemed high-risk due to a history of violations.

Why should you trust Samsara for your ELD needs?

Whether you’re driving interstate or intrastate, Samsara’s ELD compliance solution can help streamline your fleet operations and reduce administrative overhead. With real-time visibility into every driver’s logs, dispatchers can easily take drivers’ status into account when planning routes to avoid HOS violations. Plus, with Samsara’s Compliance Dashboard, you can get at-a-glance visibility into your fleet’s HOS violations, unidentified driving events, and unassigned hours.

Here are a few of the benefits of Samsara’s ELD solution:

• Easy to use: The Samsara solution is designed to be easy to use for drivers, intuitive for dispatchers and fleet managers, and easy to install.

• Cost effective: Samsara Vehicle Gateways include a built-in WiFi hotspot to keep drivers connected while using the Samsara Driver App or other work apps. The Samsara Driver App works on any iOS or Android device, eliminating the need for costly, proprietary in-cab devices. 

• Fully integrated: Samsara’s ELD solution is part of the Connected Operations Cloud, a single platform for Vehicle Telematics, Video-Based Safety, Apps & Driver Workflows, Trailer Tracking, and more. Drivers can use mobile devices to log their Hours of Service, perform vehicle inspections, and digitize paperwork, saving them time while remaining FMCSA-compliant.

Learn how Samsara’s ELD solution can help your fleet mitigate risk and stay compliant with FMCSA regulations.