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Frequently Asked Questions (FAQs) - ELD Rule

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Downloadable version of all ELD FAQs linked above.

NOTE: The ELD FAQs are intended to provide plain language information regarding the ELD rule. They do not modify or replace applicable Federal Motor Carrier Safety Administration (FMCSA) regulations or substantive standards.

For the purposes of this Rule, the term “electronic onboard recorders” or EOBRs is not used due to a change of terminology following MAP-21.

ELD FAQ Categories

General Information about the ELD Rule

  1. What are the key requirements of the Electronic Logging Device (ELD) rule?
  2. What is the mandate in the Moving Ahead for Progress in the 21st Century Act (MAP-21) for the Electronic Logging Device (ELD) rule?
  3. Who must comply with the electronic logging device (ELD) rule?
  4. What electronic logging device (ELD) user documentation must be onboard a driver’s commercial motor vehicle?
  5. Can the ELD information packet be in electronic form?
  6. Can an electronic logging device (ELD) be on a smartphone or other wireless device?
  7. Can a driver use a portable electronic logging device (ELD)?
  8. How long must a motor carrier retain electronic logging device (ELD) record of duty status (RODS) data?
  9. What electronically transferred data from electronic logging devices (ELDs) will be retained by Federal Motor Carrier Safety Administration (FMCSA) and other authorized safety officials?
  10. What is the carrier’s responsibility in ensuring that they are using a registered device? 
  11. How will the ELD display screen or printout reflect special driving categories; yard moves and personal conveyance?
  12. If the vehicle registration for a commercial motor vehicle reflects a model year of 2000 or newer, but the vehicle was manufactured without an engine control module (ECM), is the carrier required to comply with the ELD rule?
  13. How are motor carriers required to present records of duty status (RODS) from December 11-17, 2017? Will drivers be required to present their records of duty status on electronic logging devices (ELDs)?

ELD Exemptions

  1. Who is exempt from the ELD rule?
  2. What time periods can be used to determine the 8 days in any 30-day period?
  3. What information may be requested to support the exemption for drivers not required to use records of duty status (RODS) more than 8 days in any 30-day period?
  4. If the vehicle registration for a commercial motor vehicle reflects a model year of 2000 or newer, but the connections and motor vehicle components (such as the engine) are older than model year 2000, is the vehicle exempt from the ELD rule?
  5. If a motor carrier’s operation is exempt from the requirements of 395.8, is the motor carrier also exempt from the ELD rule?
  6. Are Canada- and Mexico-domiciled drivers required to use electronic logging devices (ELDs) when they are operating in the United States?
  7. How should an ELD record a driver’s hours of service when operating in another country such as Canada?
  8. Can drivers operate commercial motor vehicles (CMVs) equipped with electronic logging devices (ELDs), if they are not required to use them due to an exception?
  9. Are motor carriers that meet the agricultural exemption defined in 395.1(k) or the covered farm vehicle 395.1(s) subject to the ELD rule?
  10. Can a driver use an ELD on a commercial motor vehicle with a model year older than 2000?

Voluntary Usage and Compliance Phases

  1. How soon can electronic logging devices (ELDs) be installed and used in commercial motor vehicles (CMVs)?
  2. What are the enforcement procedures for registered electronic logging devices (ELDs) installed and used in commercial motor vehicles (CMVs) prior to the compliance date of the ELD rule?
  3. What are the options for carriers and drivers to complete records of duty status (RODS) prior to the Electronic Logging Device (ELD) rule compliance date?
  4. What is a “grandfathered” automatic onboard recording device (AOBRD)?
  5. When are drivers subject to the ELD rule required to start using electronic logging devices (ELDs)?
  6. What will be the enforcement procedures for “grandfathered” automatic onboard recording devices (AOBRDs) and electronic logging devices (ELD) during the two-year period following the compliance date of the ELD rule?
  7. According to § 395.8, if a motor carrier “installs and requires a driver to use an AOBRD…before December 18, 2017 they may continue to use the AOBRD until December 16, 2019.” Does this mean I can move an AOBRD from one vehicle to another after December 18, 2017?

Supporting Documents

  1. When are motor carriers and drivers required to comply with the supporting document requirements?
  2. How many supporting documents must be retained by motor carriers, and when must drivers submit them to the motor carrier?
  3. How long must motor carriers retain records of duty status (RODS) and supporting documents?
  4. What are the categories of supporting documents?
  5. Are there specific categories of supporting documents that drivers can provide electronically?
  6. Can supporting documents be limited to only those acquired at the beginning and end of the workday?
  7. What information should be in the supporting documents?
  8. Can a document with fewer than four required elements be used as a supporting document?
  9. What supporting documents should a motor carrier retain if a driver submits more than eight documents for a 24-hour period?
  10. Are drivers required to show supporting documents during roadside inspections?

Editing and Annotations

  1. What is the difference between “paper records of duty status (RODS)” and printouts of RODS from electronic logging devices (ELDs)?
  2. What is the difference between an “edit” and an “annotation”?
  3. Can a driver annotate the electronic logging device (ELD) record?
  4. Who can edit an electronic logging device (ELD) record?
  5. Who is responsible for the integrity of records of duty status in regards to the editing and certification rights of drivers and motor carriers?
  6. Are the original electronic logging device (ELD) records retained after edits are made, and accessible to drivers?
  7. Can a user edit or change driving time that has been recorded by an electronic logging device (ELD) to non-driving time?
  8. How can a driver record their on-duty not driving status, such as working in a warehouse, on an ELD, prior to operating a commercial motor vehicle equipped with an ELD?
  9. Are drivers allowed to edit their records of duty status (RODS) using the electronic logging device (ELD) back office support systems once they leave the commercial motor vehicle (CMV)?
  10. What procedure should be followed if multiple, compatible electronic logging devices (ELDs) are used to record a driver’s record of duty status (RODS) within a motor carrier’s operation?
  11. What procedure should be followed if multiple, incompatible electronic logging devices (ELDs) are used to record a driver’s record of duty status (RODS)?
  12. What procedure should be followed if an electronic logging device (ELD) is replaced or reset?
  13. When a motor carrier discovers a driver in a team driving operation failed to log in and his or her activities were assigned to the co-driver, can the motor carrier reassign the generated data?
  14. What must a driver do with unassigned driving time when he or she logs into the electronic logging device (ELD)?
  15. What must a motor carrier do with unassigned driving records from an electronic logging device (ELD)?
  16. If a driver is permitted to use a Commercial Motor Vehicle (CMV) for personal reasons, how must the driving time be recorded?

Harassment

  1. What is the definition of harassment in the Electronic Logging Device (ELD) rule?
  2. How does the Electronic Logging Device (ELD) rule address harassment of drivers using ELDs?
  3. Does the Electronic Logging Device (ELD) rule require real-time tracking of commercial motor vehicle (CMVs) with ELDs?
  4. What are the differences between harassment and coercion?
  5. What should a driver consider before filing a harassment complaint?
  6. How much time is allowed for a driver to file a harassment complaint?
  7. Where should a driver file a harassment complaint?
  8. What information must be submitted in a harassment complaint?

ELD Functions

  1. What information is automatically recorded by an electronic logging device (ELD)?
  2. When is location data recorded by an electronic logging device (ELD)?
  3. Will the vehicle location information identify street addresses?
  4. Is an electronic logging device (ELD) required to collect data about vehicle performance?
  5. Do the specifications in the ELD rule for electronic logging devices (ELDs) include requirements to automatically control the vehicle, such as other safety systems that may automatically reduce acceleration or apply braking?
  6. What is the level of accuracy for commercial motor vehicle (CMV) location information recorded by an electronic logging device (ELD)?
  7. What does engine synchronization mean for the purposes of electronic logging device (ELD) compliance?
  8. Will GPS-derived data for mileage be allowed as a substitute for data that cannot be readily obtained from a vehicle electronic control module (ECM)?
  9. Can an electronic logging device (ELD) have a feature to warn drivers about approaching hours of service (HOS) limits?
  10. When will an electronic logging device (ELD) automatically start to record a driving mode or status?
  11. When will an electronic logging device (ELD) automatically change the duty status from driving to the default duty status of on-duty not driving?
  12. How must a driver be able to access records of duty status (RODS) from an electronic logging device (ELD)?
  13. How does the electronic logging device reflect personal conveyance when the personal conveyance status is selected and the commercial motor vehicle (CMV) is driven?
  14. What are the display requirements for team drivers using the same electronic logging device (ELD) on their commercial motor vehicle (CMV)?
  15. Can a logged-in co-driver make entries over his or her records using the electronic logging device (ELD) when he or she is not driving?
  16. Can an electronic logging device (ELD) record be set to record minimum duty status durations, such as 15 minutes?
  17. As a motor carrier, how can I be sure an electronic logging device (ELD) is compliant?

ELD Data Transfer

  1. What are the options for electronic logging devices (ELDs) to electronically transfer data?
  2. How will safety officials receive data electronically from the two different types of ELDs with options for different methods of electronic data transfer (“telematics” and “local”)?
  3. What is the process for transferring data via USB2.0?
  4. What is the process for transferring data via email?
  5. What is the process for transferring data via Bluetooth?
  6. What is the process for transferring data via web services?
  7. Would an electronic logging device (ELD) be non-compliant with the ELD rule if the data cannot be sent electronically to an authorized safety official at roadside?

ELD Malfunctions and Data Diagnostic Events

  1. Is an ELD required to monitor its compliance with the ELD technical requirements?
  2. When do electronic logging device (ELD) “power data diagnostic events” and “power compliance malfunctions” occur?
  3. When do electronic logging device (ELD) “engine synchronization data diagnostic events” and “engine synchronization compliance malfunctions” occur?
  4. When does an electronic logging device (ELD) “timing compliance malfunction” occur?
  5. When does an electronic logging device (ELD) “positioning compliance malfunction” occur?
  6. When does an electronic logging device (ELD) “data recording compliance malfunction” occur?
  7. When does an electronic logging device (ELD) “missing required data elements data diagnostic event” occur?
  8. When do electronic logging device (ELD) “data transfer data diagnostic events” and “data transfer compliance malfunctions” occur?
  9. When does an electronic logging device (ELD) “unidentified driving records data diagnostic event” occur?
  10. What must a driver do if there is an electronic logging device (ELD) malfunction?
  11. What must a motor carrier do if there is an electronic logging device (ELD) malfunction?
  12. When should a driver certify his or her record of duty status (RODS) on the electronic logging device (ELD) to avoid malfunction codes?
  13. What types of visual indicators must be displayed by an ELD?

ELD Accounts

  1. What electronic logging device (ELD) user accounts must be set up by a motor carrier?
  2. Can a motor carrier create electronic logging device (ELD) accounts on individual ELDs or its support system?
  3. What information is required to create electronic logging device (ELD) user accounts for drivers?
  4. How many electronic logging device (ELD) accounts can be established by a motor carrier for one of its ELD drivers?
  5. Can a driver’s electronic logging device (ELD) single user account be authorized for administrative functions, in addition to its driver-related functions?
  6. Driver accounts must include the CDL number and state. If a driver relocates to another state and obtains a new commercial driver’s license, can the ELD allow for editing the driver profile to change the license number and state or must a new driver account be created? If so, how would the two link together to allow for recording the prior seven days?
  7. Can a motor carrier set up a driver account as an “exempt driver” and have another account for the same driver as a regular driver account?  

ELD Registration and Certification

  1. When will electronic logging device (ELD) system suppliers be able to start registering their ELDs with FMCSA?
  2. What happens if a registered device listed on FMCSA’s website is later found not to meet the technical specifications in the Electronic Logging Device (ELD) rule?
  3. What is the procedure to remove a listed certified electronic logging device (ELD) from FMCSA’s website?
  4. Is the electronic logging device (ELD) vendor/manufacturer required to notify motor carriers if a device is removed from FMCSA’s ELD registration list because it was determined to be non-compliant?
  5. What happens if an electronic logging device (ELD) is found to be non-compliant after it is in use?

Differences between AOBRDs and ELDs

  1. What are the differences in the technical specifications in the 1988 automatic onboard recording device (AOBRD) Rule (49 CFR 395.15) and the Electronic Logging Device (ELD) rule?

Differences between AOBRDs and Logging Software Programs

  1. What are the differences between automatic onboard recording devices (AOBRDs) and devices using logging software programs?

ELD Technical Specifications

  1. Why are technical specifications in the Electronic Logging Device (ELD) rule?
  2. Will FMCSA provide the eRODS application for vendors to test against?
  3. Is a physical connection between the ECM and ELD required in order to establish integral synchronization with the engine?
  4. If an ELD loses connection to the ECM how will the device report a system failure?
  5. Must the manufacturer self-certify and register every version or firmware update to the ELD?
  6. Are vendors required to update or register each different configuration of hardware, even though the product is the same as an application (APP) (e.g., black box and Samsung, black box and iPhone, black box and Nexus)?
  7. Does the registration process require companies to exclusively use FMCSA’s test procedure?  Will vendors have access to testing facilities for ELDs?
  8. How will CMV environmental specifics be tested with the ELD – for example, mounting and connections to the ECM?
  9. How will the ELD report on-duty not-driving status when the origin of the duty status is automatic instead of driver-input?
  10. The Event Checksum Calculation describes the individual items to be included in the calculation. Number 9 says "CMV Number."  Is this the CMV VIN or the CMV Power Unit Number?
  11. Are unassigned driving reports required to be available at roadside?

ELD Manufacturer Compliance

  1. As an electronic logging device (ELD) manufacturer, how can I make sure that my product is compliant?

Automatic On-Board Recording Device (AOBRD)

  1. Can a motor carrier purchase automatic on-board recording devices (AOBRDs) in bulk quantities for installation after December 18, 2017?
  2. 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?
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