In an electronic logging device (ELD) with multiple components, which component must generate the event identifier sequence number?

NOTE: This guidance was rescinded on July 31, 2023, and is no longer in effect.  Please see revised guidance FMCSA-ELD-395-Q080(2023-07-31).

FMCSA-ELD-395-Q080(2022-03-10)

Question: In an electronic logging device (ELD) with multiple components, which component must generate the event identifier sequence number?

Guidance: The event sequence identifier number be consistently applied as required per sections 4.4.4.1 of 49 CFR part 395, subpart B, Appendix A. It does not specify which component needs to generate the event identified sequence number. This is left to the discretion of the provider. 
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Note: This guidance document does not have the force and effect of law and is not meant to bind the public in any way.  It is intended only to provide information and clarity regarding existing requirements under the law or agency policies.