California regulations requiring the use of electronic logging devices (ELDs) to make record-of-duty statuses for drivers of commercial motor vehicles went into effect on January 1st of this year. The California Highway Patrol website characterizes these regulations as alignments with preexisting federal ELD regulations, and most California motor carriers not previously subject to the federal requirements will probably not be swept in under these new state rules.
The regulations, like the federal ones before them, apply only to motor carriers operating “commercial motor vehicles”. (See 13 CCR § 1213(a)(1)). Federally, this term is defined by a gross vehicle weight rating (GVWR) limit of at least 10,001 pounds, or by carrying hazardous material (see 49 CFR § 390.5), but in California, a “commercial motor vehicle” is one requiring a class A or B driver license, or a class C with a specified endorsement. (See Cal. Veh. Code § 15210(b)(1); 13 CCR §1201(e)). A class C license allows operation of most vehicles up to 26,000 pounds GVWR; this effectively makes the California state limit to qualify as a commercial motor vehicle higher than the federal one, although it must be noted that a three-axle vehicle weighing over 6,000 pounds gross requires a class B. (See DMV table of driver license classes.) Also, as with the federal standards, one of the specified endorsements that will trigger commercial motor vehicle status is hazardous material transportation. (See Cal. Veh. Code § 15278(a)(5).)
For the most part, motor carriers subject to the new California ELD rules will have been subject to the federal ones since they went into effect in late 2017. A motor carrier operating a 3-axle vehicle heavier than 6,000 pounds but below 10,001 would be newly subject to ELD rules, but most last-mile owner/operators do not use such vehicles. Still, this is as good a time as any to double check the GVWRs of the motor vehicles you are using or hiring.
While most SCI clients work exclusively with relatively light vehicles not approaching the federal or state commercial weight limits, many do transport hazardous materials, especially when working with medical clients. Hazmat carriers in California will now have state and federal regulators enforcing their ELD compliance, and it is more important than ever for such owner/operators, and logistics brokers with motor carrier authority, to ensure ELDs are properly installed in their vehicles and those of their employees and subcontractors, if any.