ELD Supporting Documents in Phase 2
The ELD Rule streamlines record keeping, but still requires drivers and carriers to retain supporting documents (in paper or digital format) to verify HOS compliance.
Supporting documents requirements take effect on the ELD rule Compliance Date December 18, 2017.
Drivers must submit all their supporting documents to their motor carriers, and motor carriers must retain not more than eight supporting documents for each 24-hour period that a driver is on duty.
Drivers must submit their RODS and supporting documents to the motor carrier no later than 13 days after receiving them.
There are five categories of documents:
- Bills of lading, itineraries, schedules, or equivalent documents that show the starting and ending location for each trip;
- Dispatch records, trip records, or equivalent documents;
- Expense receipts (meals, lodging, fuel, etc.);
- Fleet management system communication records;
- Payroll records, settlement sheets, or equivalent documents showing payment to a driver.
Drivers using paper RODS must also keep toll receipts – which don’t count toward the eight-document cap.
Each supporting document must contain the following information:
- Driver name (or a carrier-assigned identification number) on the document or on another document that allows the carrier to link the first document to the driver. The vehicle unit number can be used, if that number can be linked to the driver.
- Location (including the name of the nearest city, town, or village).
If a driver has fewer than eight documents with all four information elements, a document that does not include time can also serve as a supporting document.
Editing and Annotating Records of Duty Status
Limited editing is allowed to correct mistakes, enter missing information, and provide notes or explanations (annotation) for ELD records. Driving time and other information that is automatically captured cannot be edited.
Driver edits must be accompanied by an annotation. The ELD prompts the driver to annotate edits.
A carrier can suggest or request edits for accuracy – but the driver must confirm these changes, and then recertify and resubmit the RODS.
All edits, whether made by the driver, or suggested by the carrier, must be annotated (include notes to explain the reason for the change).
Driver Certification of RODS
The driver must certify each RODS. A driver must certify any edits he/she makes; and should certify carrier edits if they are accurate. Certification is intended to protect drivers from unilateral changes to the RODS.
Carrier Retention of ELD Information
Carriers must retain original ELD information (on the device, or on a separate back-up system) for at least six months, along with the associated required supporting documents. Paper copies of documents do not need to be retained if they have been scanned. Carriers must ensure ELD information is stored with appropriate security, to protect driver privacy. Carriers must also provide drivers with access to the records, on request, for a period of six months.
Displaying and Transferring Data
Starting on the compliance date, enforcement officials may request access to RODS through by data transfer.
An ELD must be able to either:
- Transmit data using wireless Web services and email, or
- Transfer data locally using a thumb or flash drive (USB2.0) and Bluetooth®.
Malfunctions and compliance alerts chart
When does it occur?
Data Recording Compliance Malfunction
Occurs when an ELD can no longer record or retain required data or retrieve recorded logs.
Missing Required Data Elements Data Diagnostic
Occurs when any required data element is missing at the time of its recording.
Power Data Diagnostic
Occurs when an ELD is not powered and fully functional within one minute of the vehicle engine power up, and the ELD does not remain powered while the vehicle engine is powered.
Power Compliance Malfunction
Occurs when the ELD is not powered on while the vehicle is in motion for longer than 30 minutes during the 24 hour period. ECM data or ECM connectivity data must be captured when the engine is powered, but the ELD is not prohibited from recording information when the engine is off.
Engine Synchronization Data Diagnostic
Occurs when an ELD loses connection to the ECM and cannot obtain any required data sources (engine power, vehicle motion, miles driven, and engine hours) and their updated values within 5 seconds.
Engine Synchronization Compliance Malfunction
Occurs when an ELD loses connection to the ECM and cannot obtain any required data sources (engine power, vehicle motion, miles driven, and engine hours) for more than 30 minutes during a 24-hour period.
Note: When the engine is not powered, the ELD does not have to capture data. The 30 minutes verifies that additional miles and movement has not taken place in the 24-hour period. The ECM data or ECM connectivity data must only be captured when the engine is powered, but the ELD is not prohibited from recording information, if desired, when the engine is off.
Timing Compliance Malfunction
Occurs when the ELD time is not properly synchronized with Coordinated Universal Time (UTC), so that the time is inaccurate by 10 minutes or more at any time.
Positioning Compliance Malfunction
Occurs when an ELD doesn’t acquire a valid position measurement within 5 miles of the vehicle’s movement during a cumulative 60-minute or greater period over 24 hours.
Note: If this malfunction is due to a change in driver duty status, the ELD will prompt the driver to enter a location. If the driver does not enter the location, and the vehicle is moving, the ELD will record a “missing required data element” diagnostic event for the driver.
Unidentified Driving Records Data Diagnostic
Occurs when an unidentified driver record has been recorded on the ELD for more than 30 minutes of driving in a 24-hour period.