Electronic On-Board Recorders

NSWMA's comments to the Federal Motor Carrier Safety Administration (FMCSA) about the agency’s proposal to require electronic on-board recorders to verify compliance with hours of service requirements. NSWMA noted that solid waste and recycling collection trucks currently are local routes under the 100 air-mile rule. As a result, they use time cards instead of the more formal record of duty status (“driver logs”) to verify compliance.

The 2012 Federal Transportation Act, “Moving Ahead for Progress in the 21st Century Act” requires FMCSA to promulgate regulations requiring electronic on-board recorders for hours of service compliance for commercial motor vehicle operators. However that law included a specific exemption for all local route vehicles.