Last month Joe DeLorenzo, FMCSA’s Director of Enforcement and Compliance, joined EROAD in a webinar to educate customers on the new guidance for personal conveyance recently announced by FMCSA. With Electronic Logging Devices monitoring all drive time by qualified drivers and trucks it’s important to understand how and when personal conveyance can and should be used. Here are some lessons we learned from Joe:
- Personal conveyance is an off-duty drive status designed for the driver to use once he is relieved from work and all responsibility for performing that work. An easy way to understand what qualifies as personal conveyance is to ask two simple questions: (1) Is the driver relieved of duty from the company? Answer must be Yes. (2) Why is the movement taking place? If the movement is purely of personal nature, this can be considered personal conveyance.
- The new guidance focuses on the intent of the movement. If your truck is loaded, you can still move your vehicle. As long as you’ve met the requirements for personal conveyance and are moving the vehicle for personal reasons you can be laden or unladen.
- ELDs are required to have an “authorized personal use” feature for drivers. There are two options for this. (1) The driver may choose personal conveyance status on the device OR (2) the driver doesn’t log in to the device and will have to annotate the unidentified trips automatically created when the vehicle is driven. As a carrier, you get to decide which option you’d like drivers to use.
- Annotations are important. If you mess up – annotate it. This is very helpful to inspectors and can eliminate time at roadside and during audits. Teach your drivers to use annotations regularly to explain exemptions or edits.
- Any time that is captured as personal conveyance is counted as off-duty. This means that any time captured as personal conveyance will not interrupt any off-duty rest breaks or affect on-duty limits.
- Fueling is part of maintenance for vehicles and is typically considered on-duty drive time.
- Fun fact: If you’re driving a float or are in a parade, it’s considered personal time and personal conveyance may be used.