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Drivers who use the timecard exception are not required to keep records of duty status (ARODS) or use ELDs. Additionally, the following drivers are not required to use ELDs; however they are still bound by the RODS requirements in 49 CFR 395 and must prepare logs on paper, using an Automatic On-Board Recording Device or with a logging software program when required:

  * Drivers who use paper RODS for not more than 8 days out of every 30-day period.

  * Drivers who conduct drive-away-tow-away operations, where the vehicle being driven is the commodity being delivered.