Luxury Coach & Transportation

August 2018

Magazine for the professional limousine, charter and tour industry.

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Page 45 of 79

REGULATIONS: MOTORCOACHES After April 1, 2018, drivers found out of compliance with electronic logging devices could be ordered out of service. Is your service at risk? By Lexi Tucker, LCT associate editor J oe Guinn and Chris Przybylski of Limo and Bus Compliance presented a webinar for LCT on May 31 that delved deeper into the question of when companies really need to implement ELDs. "ere's a huge push right now for manufacturers who are trying to get as many sales as they can," especially using the prospect of road checks, Guinn told a webinar audience of op- erators, referring to a then-pending June 5-7 inspection. An ELD is an "electronic logging device" truck drivers have been using because they are limited by the number of hours they can legally drive that's considered safe for the motoring public. ELDs plug into a vehicle and report every time it moves. is is used to ensure drivers are not taking liberty with the number of hours they're actually driving. e ELD mandate took effect in December 2017 with a claim of leniency period to allow implementation by carriers. e mandate came out 44 WWW.LCTMAG.COM LUXURY COACH & TRANSPORTATION AUGUST 2018 over two years ago, so this has not been a surprise to ground transportation companies. Do You Need ELDs? If you only run sedans and SUVs, this article is likely not rel- evant to your operation. e Federal Motor Carrier Safety Administration has mandated regulation of any vehicle over nine passengers or more than 10,001 pounds that travels to the airport or leaves the state. "If you have vehicles subject to FMCSA regula- tions, all of the basic things you think of with CDL drivers apply even if you're just operating vans and limos to and from the airport," Przybylski said. "Hours of service records, driver qualification files, vehicle inspections, maintenance plans, records, 45 or 90 days depending where you're at. And then if you're CDLs, drug and alcohol policies. e biggest thing from the DOT perspective is if you don't have it recorded and written down, it doesn't count. So all the policies have to be written out and you must have the things to go with them." ere are two common exemptions to ELDs that ap- ply to limousine and bus companies. e first primar- ily concerns bus companies. If your vehicles are 1999 or older, there are exemptions for that. ose exemp- tions also take into account factors such as engine swaps; older engines that didn't have OBD2 and JBOS, which are the protocols used for ELDs. Obvi- ously for most limo companies, fleets tend to be younger than that. e second is called the 100 air mile exemption. "Basi- cally, an air-mile is a nautical mile in common terms. It's as the crow flies and about 115 miles. It's a radius from your terminal. So if you have multiple offices, it would be from that driver start and your office, which can make a huge difference for companies operating in multiple states," Przybylski said. To qualify for the exemption, operators need to meet two criteria: e driver has to be off duty within 12 hours of going on duty. "It doesn't matter if they had gaps during the day. ey came in at 6 a.m., they have to be gone at 6 p.m.," he clarified. e other is they don't exceed 100 air-miles from their start- ing terminal. Because it's a radius, they can go 80 miles in one direction and then 80 miles in the other direction and still be within the 100 air- miles. To use this exemption for ELDs, ELDs plug into a vehicle and reports every time it moves. This is used to ensure drivers are not taking liberty with the number of hours they're actually driving. (Wikimedia photo by FleetBeat) ELDs: Do You Need Them? Joe Guinn of Limo and Bus Compliance advises operators to carefully check if federal rules require them to install ELDs, since vendors are pushing to get as many sales of the devices as they can.

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