Q1. Can a motor carrier purchase automatic on-board recording devices (AOBRDs) in bulk quantities for installation after December 18, 2017?

A1. No. To be grandfathered, an AOBRD must be installed in a CMV prior to December 18, 2017. If a grandfathered AOBRD subsequently becomes inoperable, then that AOBRD must be replaced by an ELD.

Q2. If a motor carrier adds an owner operator to its fleet after December 18, 2017, and the owner operator operates with a grandfathered AOBRD in their CMV, can the owner operator continue to use its grandfathered AOBRD while employed by the motor carrier?

A2. Yes, an owner operator that operates with a grandfathered AORBD and is hired by a motor carrier after December 18, 2017 may continue to operate with its grandfathered AOBRD while employed by the motor carrier.

Q3. If an AOBRD becomes inoperable after December 18, 2017, can that AOBRD be replaced if it is under warranty?

A3. Yes, if an AOBRD is under warranty and becomes inoperable after December 18, 2017, then that AOBRD can be replaced with another AOBRD within the terms of the manufacturer’s warranty. Motor carriers should note that 49 CFR Part 379 Appendix A requires the motor carrier to maintain records pertaining to replacement of equipment. If the AOBRD is not under warranty and becomes inoperable after December 18, 2017, then that AOBRD must be replaced with an ELD.

Q4. May a motor carrier that installed and required its drivers to use an AOBRD before December 18, 2017, install and use a new ELD-capable device that runs compliant AOBRD software after that date?

A4. Yes, until December 16, 2019.