Electronic Logging Device (ELD) Rules Continue To Be Challenged

GeoSpace Labs released a letter supporting Electronic Logging Devices (ELD) for all commercial transporters. GeoSpace Labs produces ELDs and says they "provide commercial transporters with a legitimate FMCSA Registered ELDs for transporters of agricultural commodities (AG) under 49 CFR  395.1(k)." ( Press Release from GeoSpace Labs - November 4, 2019) 

Dear Senators and Representatives:

Commercial drivers are currently required to use an Electronic Logging Device (ELD) when driving under 49 CFR 395's requirements. The purpose of the device is to record vehicle data alongside driver activities and ensure safety measures including reasonable working hours and taking proper rest breaks.

These ELDs provide an additional layer of safety on public roads and substantially reduce the paperwork burden of commercial drivers.

While the majority of the commercial transportation market uses these ELD devices when required, currently it is argued that there is no product available for drivers hauling livestock or other agricultural commodities that correctly and automatically applies the exemptions available under 395.1(k) to balance driver activities and animal safety.

This means many of the commercial agricultural drivers are still required to use a burdensome and inaccurate paper-based system.

We provide an FMCSA registered ELD with the expanded functionality to correctly track and apply the required data to automate 395.1(k) for drivers hauling agricultural commodities including livestock.

The device has been in the market for over a year and is being used by hundreds of drivers every day, who each benefit from flawless automation and tracking of the 395.1(k) exemptions as applied to regular ELD logs including automated reporting to local and federal law enforcement when needed as required.

A human driver gets just as tired when hauling propane as they do cows, and both drivers should have automated safety tracking technology available to them.

Requiring drivers hauling cows to use a paper system is pointless, onerous, and unsafe when automation exists to their benefit.

Please unify the commercial transporters markets and require all commercial drivers to employ automated safety procedures by requiring all drivers meeting the requirements of 49 CFR 395 to use ELDs.

Exempting a small segment of the market unnecessarily makes the public roads more dangerous and puts all our lives and our families lives in danger.

Thank you for your time.

GeoSpace Labs provides professional Hours of Service Systems covering AOBRD, ELD, IFTA, and DVIR with 49 CFR 395, 396 automation, and includes deep and unique handling of different exemptions offered by the FMCSA, including unassigned driving, 16 Hour Short-Haul Exception 395.1(o), Agriculture Exemption 395.1(k), 100 Air Mile Short-Haul Exemption 395.1(e)(1), and Vehicles used in oil and gas field operations 395.1(d)(2).

For more information please visit the GeoSpace Labs website at or call 877.443.6949.


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