2 ELD-Specific Duty Statuses Personal Conveyance & ELDs – How Does It Work? Professional truck drivers operating their trucks (unladen) for personal reasons while on-the-road, and off-the-clock, is nothing new. In fact, personal use (also called “personal conveyance” or PC by government regulators) has been a common and accepted industry practice for many years. As a result, the Federal Motor Carrier Safety Administration button on the display screen. At this point, when the truck starts (FMCSA) included and accommodated this type of off-duty truck moving, the ELD will automatically capture and place this off-duty use in its ELD mandate rule, and labeled it as one of two “special driving time on line 1 of the ELD record (the off-duty line), and not driving categories,” along with truck moves in a yard. So, while PC on the line 3 driving line. And, under the ELD rule, this off-duty is not new, it’s garnered a fair amount of recent attention in the driving time must look different on the electronic record, that trucking industry since it comes with new procedures under the is, it must be programmed by the supplier to be either a dotted, ELD rule. So, how does this longstanding practice work with ELDs? dashed or shaded line so that it can be easily seen/viewed as off- Is it still considered off-duty time and, if so, how is it reflected on duty PC driving. When a driver is finished using the truck for PC, the driver’s ELD record? And, can PC time be edited by the carrier the driver must deselect PC by again pushing a soft button on the staff if it’s used improperly by a driver? Let’s take each one of these display screen. questions in turn. WHAT NOW? PERSONAL CONVEYANCE & ELD – HOW DO Most drivers and companies will use the PC line as intended and THEY WORK TOGETHER? consistent with FMCSA’s longstanding guidance (i.e., short driving Under the ELD rule, a carrier that allows its drivers to use their distances, driver not under dispatch, has no work responsibilities, trucks as a personal conveyance may configure the ELD to is truly off-duty, and truck is unladen). However, it’s likely there provide this special driving category as an option. This means, in will be occasions when the PC line is used improperly by a driver. most cases with most suppliers, the ELD software will include a When a carrier becomes aware of improper PC use by a driver, functioning PC ‘soft button’ on the display screen to give drivers the an office person with ELD administrative rights will be able (and ability to select this category of driving when they are off-duty, and is encouraged) to propose an edit to the driver, along with the their truck is unladen. Keep in mind that, generally speaking, it’s required annotation. If accepted, the edit will move the PC time the carrier’s choice on whether it will allow use of PC. A carrier may from the off-duty line (line 1) and properly place that time back on also choose to disable the PC button. [Note: this carrier choice gets the driving time line (line 3). This edit will help avoid potential false a little more complicated for carriers with owner-operators (i.e., log violations. independent contractors).] As mentioned, PC is a common and accepted industry practice MEETING FMCSA REQUIREMENTS that will continue under the ELD rules. While the criteria for using When drivers meet the FMCSA criteria (and perhaps additional PC is not clearly spelled out in the ELD rule, FMCSA’s longstanding company criteria) to use the PC category, they must first change PC guidance still applies. That guidance can be found here at their duty status to “off-duty,” and then select PC using the soft Question 26. 6