Clients often ask STC how carriers should handle non-regulated individuals who, at times, move their trucks. These are people/drivers who are operating a truck but are not transporting property or passengers in commerce and are therefore not subject to the Federal safety rules, including the ELD mandate. Examples include driver-applicants taking a pre-employment road test being conducted by a carrier, or mechanics test driving a truck before or after repair.

STC posed the following question to FMCSA on behalf of its clients, which FMCSA then answered.

Question: Is it acceptable for a motor carrier to create a single ELD log-on/account to capture movements of a CMV by drivers not subject to the FMCSRs such as CDL driver-applicants taking their road test or mechanics test driving a CMV before or after a repair?
Answer: No, it is not acceptable.  The ELD rule requires that each user of the ELD have a valid active account on the ELD with a unique identifier assigned by the motor carrier.

Carriers were asking whether they could create a single “exempt driver” account that multiple people could use (e.g., multiple mechanics at the same company). These carriers wanted to simplify back-office work by creating a single log-in that would capture the movements of a truck operated by all individuals not subject to the ELD mandate. FMCSA’s response is clear--it is not allowed. Instead, carriers must either (1) create a unique “exempt driver” ELD account for each of these non-regulated ‘drivers’, or, (2) instruct them not to log in to the ELD and then have office staff appropriately annotate the unassigned time/miles captured by the ELD while they were driving or moving the truck.