While most interstate drivers of commercial motor vehicles (CMVs) are required to use electronic logging devices (ELDs) to record their hours of service, many states are in the process of updating their intrastate adoptions of the Federal Motor Carrier Safety Regulations (FMCSRs) to include the ELD requirements.
States have three years from the effective date of a regulation to adopt intrastate regulations that are compatible with the federal requirements. If a state’s intrastate regulation is not compatible, the state risks losing millions of dollars in federal assistance directed to its motor carrier enforcement program. Rarely does
a state adopt a regulation that is not compatible.
The following states have adopted the federal ELD requirements for intrastate drivers of property-carrying CMVs. However, the applicability of the requirements, as well as the effective dates can vary from state-to-state:
- Iowa Ohio
- North Carolina
- North Dakota
- South Carolina
- South Dakota
Other states have not yet adopted the ELD requirements for drivers of property-carrying CMVs, including more populous states like California, Florida and New York. However, adoption for intrastate operations is expected in the near future. (Go to JJKeller.com/IntrastateELD for updates.)
When it comes to the issue of whether intrastate operations need ELDs, it isn’t a matter of “if,” but a matter of “when.” If your state hasn’t required ELDs for HOS-regulated intrastate operations yet, it will be coming soon. Being prepared is the best course of action, as a state’s adoption can become effective in a relatively short period of time.
Refer to J. J. Keller’s Intrastate ELD Requirements Compliance Brief for current state adoption
information and explanations of interstate
and intrastate commerce, available at