There is some confusion among motor carriers regarding commercial vehicle rentals. The Federal Motor Carrier Safety Administration (FMCSA) exempts short-term rentals from needing to use Electronic Logging Devices (ELDs) due to the duration of usage. Drivers who fall under this exemption may continue to use paper records of duty status (RODS) in lieu of an ELD; however, there are some limitations.
Updates to the TRALA Exemption
Some motor carriers are under the impression that the exemption applies to rentals for up to 30 days. This is incorrect. In March of this year, the 30-day exemption for short-term rentals expired. While the Truck Rental And Leasing Association (TRALA) petitioned FMSCA to extend the 30-day exemption through the end of 2018, FMCSA denied the request and an 8-day exemption went into effect.
Terms and Conditions of the Exemption
FMCSA provides some basic guidelines for commercial motor vehicle (CMV) rentals.
- The exemption applies to CMV rentals for eight days or less. Attempts to release the same CMV after eight days is a violation of the exemption.
- Rental drivers need a copy of the exemption letter while operating the CMV.
- Drivers must carry a copy of their rental agreement clearly stating who is renting the vehicle and the dates of the rental.
- Drivers must keep copies of their RODS for the current day and any preceding days during the applicable eight-day period.
- All other FMCSA regulations apply during the rental.
Another provision of the rental exemption is the carrier renting the CMVs must report any accident to FMCSA within five business days. When notifying FMCSA of the incident, motor carriers need to provide the following information:
- Provide the exemption explanation (TRALA)
- Date of the accident
- Location of the accident
- Name and license number of the driver and co-driver
- Number and state license number for the vehicle
- Number of people injured
- Number of fatalities
- The cause of the accident as reported by the police
- Any citations issued to the driver
- Total time the driver spent operating the vehicle as well as their on-duty time leading up to the accident
Carriers need to submit this information via email to MCPSD@dot.gov. Failing to comply with the above provisions can lead to FMCSA revoking exemption privileges. To learn more about this exemption, other safety provisions, and truck insurance solutions, contact the experts at Interstate Motor Carriers.