ELD guidance

Frequently Asked Questions: Electronic Logging Devices and Hours of Service – Editing and Annotations

Question: Who can edit an electronic logging device (ELD) record?

Guidance: Both a driver and authorized carrier staff can make limited edits to an ELD record to correct mistakes or add missing information. However, under 49 CFR 395.30(d)(2), authorized carrier staff cannot request edits before the records have been submitted by the driver.  Further, under 49 CFR 395.30(d)(1), authorized carrier staff may only request edits.  The driver must then confirm or reject the proposed change and recertify and resubmit the record.  If the driver chooses not to re-certify his or her RODs, this is also reflected in the ELD record. For example, a carrier may request to edit a record to switch a period of time from “off-duty” to “on-duty not driving”, with an annotation that explains “Driver logged training time incorrectly as off-duty”. The edit and annotation are sent to the driver to verify. The edit is not accepted until the driver confirms it and resubmits the RODS.

In accordance with 49 CFR 395.30(c)(2), all edits must include a note (annotation) to explain the reason for the edit.

Further, under 49 CFR 395.30(f), the ELD must keep the original, unedited record, along with the edits.