ELD Annotations: Exemptions

Read this compliance brief for suggested annotations that explain log exemption edits.

Published On: 08/20/2019
Annotations for Exempt log edits
J. J. Keller Industry Consultant Tom Bray

Written by:

Tom Bray

Sr. Industry Business Advisor — J. J. Keller & Associates, Inc.

Regulations governing electronic logging devices (ELDs) require drivers and other motor carrier personnel to enter certain annotations into the ELD record. Annotations — comments added to a driver’s ELD record — are used to explain any special exemptions that apply, any edits that were made, or any other special circumstances that exist.

The trouble is, the hours-of-service regulations offer no guidance on what the annotations should say, and annotations are restricted to just 60 characters. This can make it difficult to decide how to write one.

Why Annotations are Important

Some annotations are mandatory, like when submitting records during a roadside inspection or editing a record. Others simply offer an explanation. An annotation is “regulation speak” for “entering a comment.”

A well written annotation will explain what was going on during a specific occurrence or a driver’s day. Perhaps a driver hit heavy traffic and used the “adverse conditions” exception or forgot to switch to “personal use” when driving to a local restaurant for lunch. Without an annotation, it may appear to anyone reviewing the record that there is a violation or falsification. This makes a properly written annotation vital to compliance.

The following are suggested annotations that drivers and ELD administrators can use to explain exceptions or exemptions. Keep in mind that annotations should be clear, concise, and refer to a regulation whenever possible.



Reason for Exemption

Suggested Annotation

School bus operation (home to school, school to home)School bus operation 390.3(f)(1)
Non-commercial transportation of personal propertyNon-commercial, personal property 390.3
Transporting deceased/sick/injured personsTransporting corpse/sick person/injured person 390.3(f)(4)
Fire truck or rescue vehicle engaged in emergency operationsEngaged in emergency rescue/fire operations 390.3(f)(5)
9- to 15-passenger CMV, not used for direct compensation<16 passenger vehicle, no direct compensation 390.3(f)(6)
Propane winter-heating fuel delivery in response to an emergency conditionEmergency propane heating-fuel delivery 390.3(f)(7)
Pipeline emergency responsePipeline emergency response 390.3(f)(7)



Reason for Exemption

Suggested Annotation

Emergency conditionsEmergency 395.1(b)(2): ________ [enter explanation of the emergency]
Agricultural exemptionAg commodities/Farm supplies, 150-air-mile, 395.1(k)
Utility service vehicle exemptionUtility service vehicle; HOS exempt 395.1(n)
Covered farm vehicle exemptionCovered farm vehicle; HOS exempt 395.1(s)



Reason for Exemption

Suggested Annotation

Adverse driving conditionsAdverse conditions 395.1(b): _________ [enter reason for unexpected delay, and location, such as: Snow, sleet, fog, or other adverse weather or road conditions; Unusual traffic, such as caused by a crash]
Driver-salespersonDriver-salesperson 395.1(c)
Oilfield equipment 24-hour restartOilfield equipment, 24-hr restart 395.1(d)(1)
Oilfield waiting time for specialized equipmentOilfield waiting time 395.1(d)(2)
100-air mile exception100-air mile time record 395.1(e)(1)
150-air mile exception for non-CDL drivers150-air mile time record 395.1(e)(2)
Local retail store deliveries during Christmas season (Dec. 10-25)Retail store deliveries, 100 air mile radius 395.1(f)
Split sleeper-berth optionSplit sleeper-berth 395.1(g)
Split rest break using sleeping accommodation at a natural gas or oil well siteSplit break, slept at oil/gas well location 395.1(g)(2)
Split break for passenger-carrying vehicle with sleeper berthSplit rest in bus sleeper berth, 395.1(g)(3)
Alaska - property-carrying vehicleAlaska HOS 395.1(h)(1)
Alaska - passenger-carrying vehicleAlaska HOS 395.1(h)(2)
Groundwater well drilling 24-hour restartGroundwater well drilling rig 24-hr restart 395.1(l)
Transportation of construction materials and equipment in a 75-air-mile radius, 24-hour restartConstruction materials/equipment 24-hr restart 395.1(l)
Short-haul 16-hour exception allowed once per weekShort-haul 16-hour limit 395.1(o)
TV/movie production exceptionTV/movie HOS 395.1(p)
30-minute break exception for Div. 1.1, 1.2, 1.3 explosives1.1/1.2/1.3 explosives; break may be on duty 395.1(q)
30-minute break exception for ready-mix concreteReady-mix; 30-min break may be on duty 395.1(t)
30-minute break exemption for bee transportationTransporting bees; exempt from 30-min break 395.1(u)
30-minute break exemption for livestock transportationTransporting livestock; exempt from 30-min break 395.1(v)
Hi-rail exception for transportation to/from duty assignmentHi-rail CMV; to/from duty assignment 395.1(w)
Personal conveyance (if “Personal use” driving category is not selected in the ELD)Personal use: __________ [enter a brief explanation of the personal use, to justify its use]



Reason for Exemption

Suggested Annotation

ELD exempt: driver not required to log more than 8 days in 30 consecutive daysELD exempt; logs <8 days in 30 - 395.8(a)(1)(iii)
ELD exempt: driven vehicle is being delivered via driveaway/towaway operationELD exempt: driven unit being delivered 395.8(a)(1)(iii)
ELD exempt: motor home or RV trailer being delivered via driveaway/towaway operationELD exempt: motor home/RV being delivered 395.8(a)(1)(iii)
Covered farm vehicle exemptionCovered farm vehicle; HOS exempt 395.1(s)

Drivers and Annotations

Some ELDs may automatically account for the use of some of these exemptions and may make manual annotations unnecessary. Drivers should check with their safety office for details. When applicable, and as space allows, drivers should also enter a document number for any documentation (e.g., shipment number, BOL number, work order number, etc.) that can support their claim of an exemption.

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