“The insured stated that the third party safety consultant that he uses stated the 2000 model trucks in his fleet had a build date in 1999 and that all the engines had 1999 VIN’s, and these trucks would be exempt from the ELD mandate. He also stated that the 2007 unit that needs a motor replacement would be exempt if he put one of the 1999 engines that he has available. I have read but am not certain if that unit must be designated a glider kit to qualify or if just changing the motor qualifies it for the exemption. I told the insured I would check (with Thorn Valley) to see if that information was accurate and get back with him. Thanks in advance for your help.”
Comments from the field
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Engine data plate would have date of manufacture stamped on it. In fact, I was just told by a Wisconsin FMCSA officer that evidence of the engine year also needs to be in the equipment file. We have started taking photos of that plate for the file.
The year of the engine—not the truck build date or VIN—determines if an ELD is required. From a loss-prevention perspective, I believe the insured (the risk) should be informed that Underwriting is always interested how the insured approaches safety opportunities. Say, for example, the insured does drop in an older engine: what additional measures will the insured take so their future level of safety performance will equal or exceed having an ELD in the truck? How will the risk show their safety due diligence? Why would they want to appear to retrograde their trucks and safety operations? Of course it’s their call how they want to proceed, but sooner than later, the supply of older engines will run out, and they will then need to upgrade anyway. Safety is an investment. Pay now . . . or pay much more later . . .