A. You should seek expert guidance on whether you are exempt from the electronic logging device (ELD) mandate, but it’s possible given the facts you described. Typically, operations that are not already required to keep paper logs will not have to comply with the new ELD rules to track hours of service.
That being said, you should consult with your legal counsel and/or the Federal Motor Carrier Safety Administration (FMCSA) to verify that you are, indeed, not required to comply with the ELD mandate.
Drivers and fleets that are found not to be in compliance with the ELD rule will face citations, fines, being placed out of service, and possible audits.