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FAQ Get answers to ELD-related questions

FMCSA provides answers to frequently asked questions about ELDs. Consult these FAQs when you have an ELD-related question, as the answer may already be at your fingertips.

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USGS maintains the Federal authoritative source of official geographic feature names, known as the Geographic Names Information System (GNIS). Providers can start with the Populated Places dataset, which includes towns and villages of all populations. Therefore, it meets the minimum requirements (locations with populations of 5,000 or greater and listed in ANSI INCITS 446-2008 (R2013). Providers may consider cross-referencing this dataset against another dataset to filter out cities, towns, and villages with a population of less than 5,000. To learn more about the GNIS and the Populated Places dataset, visit https://www.usgs.gov/tools/geographic-names-information-system-gnis

Last Updated : March 10, 2022

No. A provider may provide an AOBRD for drivers exempt from using an ELD per 49 CFR 395.8(a)(1)(iii), but the AOBRD must be a standalone application on a device, with its own driver account and login, separate from a registered, self-certified ELD operating system.

Last Updated : March 10, 2022

The minimum functional specification requirements in the ELD rule do not require ELDs to identify hours of service violations; however, some ELD providers have elected to offer this as an add-on feature. If an ELD provider offers this add-on feature but does not update their device to reflect the 2020 changes to the new hours of service rules, the ELD may inaccurately identify hours of service violations. Motor carriers should contact their ELD providers with specific questions about what information their ELD displays.

Last Updated : March 10, 2022
  1. The driver must inform their carrier of the malfunction within 24 hours.
  2. The motor carrier has 8 days to repair, service, or replace the ELD. If the malfunction precludes the device from accurately recording hours of service (HOS) data and presenting that HOS data to a safety official, the driver must user paper logs or another system for recording their HOS during this time.
  3. Under 49 CFR 395.34, a motor carrier seeking to extend the time permitted for repair, replacement, or service of one or more ELDs may request an extension. ELD malfunction extensions can be requested by email to ELD-Extension@dot.gov. You may also contact the field office directly. For more information, see https://eld.fmcsa.dot.gov/support.
Last Updated : March 10, 2022

No. A driver cannot change their status to exempt; this account setting must be configured by the motor carrier.

For example, if a driver is transporting an agricultural commodity and is eligible for the agricultural exemption, the driver has three options for recording this time:

  1. A driver can operate within the 150-air mile radius without logging into the ELD, and then log into the ELD once the vehicle reaches the 150-air mile radius limit. Driving time within the 150-air mile radius will be identified on the ELD as "unidentified driving" time. The driver will reject the unidentified driving time on the ELD and the motor carrier must annotate the ELD data to explain that the "unidentified driving" time occurred while operating under an agricultural HOS exemption.
  2. The driver can log into the ELD when coming on duty and identify the time operating within the 150-air mile radius with an ELD annotation stating that the vehicle was operating under an agricultural HOS exemption.
  3. If authorized by the motor carrier, the driver can log into the ELD when coming on duty and identify the time operating within the 150 air-mile radius as authorized personal use (personal conveyance). A driver operating a CMV under the authorized personal conveyance provision must select on the ELD the personal conveyance driving category before the start of the status and deselect when the indicated status ends.

Last Updated : March 10, 2022

There is no separate exempt driver account; rather, the ELD must allow for a driver account to be configured as exempt by the carrier. The ELD must prompt the carrier to add an annotation justifying the exemption. The default setting for a new driver account must be “no exemption.”

Last Updated : March 10, 2022

There are two ways authorized personal use (personal conveyance, or "PC") can be recorded using an electronic logging device (ELD):

  1. If the motor carrier has configured the driver user account to authorize personal use in accordance with 49 CFR 395.28(a), then the driver may use the personal conveyance special driving category to record that time.
  2. If the motor carrier has not configured the device to authorize personal conveyance, the driver may switch to Off Duty and annotate the beginning of personal conveyance period. Once the personal conveyance period has ended, the driver annotates the end event, as well as any events that occurred during that time period.

Last Updated : March 10, 2022

Under sections 4.3.2.8.2(b) of 49 CFR part 395, subpart B, Appendix A, automatically recorded drive time when the commercial motor vehicle (CMV) is in motion cannot be edited or changed to non-driving time.

Edits to automatically recorded driving time are acceptable in the following instances:

  1. For team drivers, a driver may edit and reassign driving time records erroneously recorded to their account (see section 4.3.2.8.2(b)(2) of Appendix A). The drivers must have indicated each other as co-drivers in their record of duty status (RODS). Each co-driver must confirm the change for the edit to take effect.
  2. A driver may edit or correct driving time erroneously recorded due to failing to change his or her duty status before powering off the CMV, but only if the driving time was recorded by the ELD while the vehicle was powered off and the vehicle was not in motion during the period that is being edited or corrected. The driver edit limitation found in section 4.3.2.8.2(b) prohibits the editing of automatically recorded driving time. The intent of the specification that requires automatic recording of driving time is to ensure all movement of the CMV is captured. A CMV cannot be driven while powered off. The driving time following the power off cycle of a CMV not in motion, is not recorded to the specifications required by 4.3.1.2 and 4.4.1.1 and therefore may be edited to the correct duty status.
  3. Driving time assumed from the unidentified driver profile in error may be returned to the unidentified driver profile so that it can be assumed by the correct driver (see section 4.2.3.8.2(b)(1) of Appendix A).
  4. Drivers may assume a subset of driving time from the unidentified driver profile. The amount of automatically recorded drive time may not change, but can be split between the driver and the unidentified driver profile so that the remaining time can be assumed by the correct driver.
  5. Drivers may assume driving time from the unidentified driving profile and convert it to Off-Duty (PC) or On-Duty Not Driving (YM) if this is that status that should have been in effect (see section 4.3.2.2.2 of Appendix A).
Last Updated : March 10, 2022

Records from the engine installer, engine dealer, or engine manufacturer that confirm the engine year and the date when the engine was replaced.

Last Updated : March 10, 2022

Yes. The user's manual, instruction sheet, malfunction instruction sheet, and supply of blank driver's records of duty status (RODS) graph grid can be in electronic form. A logging software app would meet the requirement for supply of blank RODS. This is in accordance with the FMCSA rule titled Electronic Document and Signatures published April 16, 2018 (83 FR 16210). For more information, see 49 CFR 390.32(b).

Last Updated : March 10, 2022

A driver operating in the U.S must have evidence of the hours worked for the current 24-hour period and the previous 7 days.

A driver operating in the U.S. who is subject to the ELD rule must record all time operating in the U.S. on the ELD.

A driver operating in the U.S. may record time operating in Canada/Mexico using one of the following methods:

  • Records of duty status (RODS), on paper or an electronic form, for time operating in Canada/ Mexico during the current day, and during the previous 7 days,
  • An AOBRD display or printout of RODS status, or
  • ELD data transfer that displays the driver's RODS for any operations both inside and outside the US.
Last Updated : March 10, 2022

"Paper RODS" means RODS that are not kept on an ELD or automatic onboard recording device (AOBRD), but that are either recorded manually (in accordance with 49 CFR 395.8(f)) or on a computer not synchronized with the vehicle or that is otherwise not used as an ELD or AOBRD.

Printouts of RODS from ELDs refer to the reports that ELDs must be able to generate upon request from an authorized safety official, either printout or display, per section 4.8.1 of 49 CFR part 395, subpart B, Appendix A.

Last Updated : March 10, 2022

FMCSA has made a web-based version of the eRODS software available for use by motor carriers and ELD providers. Motor carriers and ELD providers may upload an ELD file to see how the hours of service data will be presented to a safety official. Web eRODS is available on the ELD website at https://eld.fmcsa.dot.gov/eRODS.

Last Updated : March 10, 2022

The ELD solution must be certified and registered with FMCSA. For example, if the ELD solution is using a bring-your-own device platform or a portable device, then the software provider must self-certify and register the software and include a list of compatible operating systems.

Last Updated : March 10, 2022

The Event Checksum Calculation is a value associated with each ELD event at the instance of the event record being created. It describes the individual items to be included in the calculation. The individual items included in the calculation are listed in sections 4.4.5.1.1 of 49 CFR part 395, subpart B, Appendix A.

Last Updated : March 10, 2022

The ELD header must reflect data for the current CMV. See sections 4.3.1.3 and 4.3.1.4 of 49 CFR part 395, subpart B, Appendix A.

Note: The Example of print/display daily header found in Appendix A section 4.8 is for example only. If a driver operates multiple vehicles during the requested time period, the provider has flexibility to come up with a different layout as long as it contains the fields required by section 4.8.1.

Last Updated : March 10, 2022

Section 4.9.1 of Appendix A requires ELDs to be able to send records for the current 24-hour period and the previous consecutive 7 days for review during a roadside inspection. An ELD must produce a data file or a series of data files of ELD records for a subset of drivers, a subset of vehicles, and for a subset of the 6-month record retention period, to be specified by the safety official—this includes files with 30 days' worth of records of duty status (RODS). The device user manual should provide instructions on how the driver or carrier can specify the time period for the file being transferred.

Last Updated : March 10, 2022

The ELD is required to automatically change a driver’s duty status to Driving when the vehicle is in motion, set at 5 mph threshold or less, after being in the Sleeper Berth duty status unless the driver is in a team operation and the inactive driver logged in the ELD. However, while the vehicle is in motion, intermediate recordings will be included on the inactive driver’s logs during the sleeper berth period.

Last Updated : March 10, 2022

Yes, the driver must manually indicate the On-Duty Not Driving status, unless he or she is operating under the exemption, which expires October 20, 2022.

Last Updated : March 10, 2022

The header should contain the information of the current co-driver. If there is no active co-driver at the time of inspection, then this field should be left blank. If a co-driver has been active during the record retention selection, the co-driver will be listed in the user list of the data transfer file. For the back-up print or display, providers may list the co-driver active for that day in the daily header.

Last Updated : March 10, 2022

The data transfer process does not require a driver to re-enter user credentials to activate the data transfer process. However, a driver must be logged in an electronic logging device (ELD) to access data recorded and stored on the system.

Last Updated : March 10, 2022

For files generated during roadside safety inspections, the active co-driver and CMV, must be reflected. For motor carrier data transfer (for compliance investigations), the ELD output file header should reflect the co-driver and CMV in use at the end of the requested time period.

In either case, the file must contain all administrative users, co-drivers, and CMVs referenced during the requested time period.

Last Updated : March 10, 2022

Records from all CMVs should be included in this time period unless the records were recorded by a non-interoperable ELD.

Regardless of whether the current day and previous 7 days are available in the in-use ELD, the driver is responsible for providing a record of duty status (RODS) for the previous 7 days upon request from a safety official.

Last Updated : March 10, 2022

Yes, however, the driver’s record of duty status (RODS) must always be available and current to the last duty status change. Therefore, if the driver is unable to access their RODS for a time period due to operating in an area that has limited coverage, the driver may be cited for violating the hours of service rules or operating without an ELD during that time.

Last Updated : March 10, 2022

As a minimal requirement, each driver would need to have printed ELD records with them to reflect their previous seven days or manually add the hours of service records from the previous seven days. Regardless of how the data was recorded, a motor carrier must retain ELD record of duty status (RODS) data and back-up data for six months.

Last Updated : March 10, 2022

The ELD must have the capability of retrieving and recording position information in compliance with sections 4.6.1.4 of 49 CFR part 395, subpart B, Appendix A. The ELD includes all components required to record, manage, retain, and transfer data so any component within the ELD may retrieve the location information.

Last Updated : March 10, 2022

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.

Last Updated : March 10, 2022

The inspector will cite the driver for failing to have a required electronic record of duty status (RODS), and will place the driver out of service (OOS) for 10 hours (8 hours for a passenger carrier), in accordance with the Commercial Vehicle Safety Alliance (CVSA) North American Standard Out-of-Service (OOS) Criteria. At the end of the OOS period, the driver is allowed to complete the current trip to his or her final destination using paper logs. If the driver is stopped again prior to the final destination, the driver will be asked to provide the safety official a copy of the inspection report and evidence (e.g., bill of lading) proving he/she is continuing the original trip. After reaching the final destination, if the driver is dispatched without obtaining a compliant ELD, he/she will again be subject to the OOS procedures. However, a driver may return with an empty commercial motor vehicle (CMV) to his/her principal place of business or home terminal, as indicated on the roadside inspection report.

Last Updated : March 10, 2022

No. The ELD rule does not allow driving time to be shortened for correcting special driving category selection. If a driver forgets to select special driving categories (Personal Conveyance or Yard Move) at the beginning or end of the special driving category, then the driver can make an annotation in the ELD record identifying the start and end of the special driving category.

Last Updated : March 10, 2022

If an ELD malfunctions, a motor carrier must:

  1. Correct, repair, replace, or service the malfunctioning ELD within 8 days of discovering the condition or a driver's notification to the motor carrier, whichever occurs first; and
  2. Ensure its driver complies with 49 CFR 34(a)(2) and (3) by requiring its driver to maintain paper record of duty status (RODS), if the malfunction hinders the accurate recording of the driver's hours of service data, until the ELD is back in service.

Note: A motor carrier may file an ELD malfunction extension request via email, by submitting the extension request toELD-Extension@dot.gov or the FMCSA Division Administrator for the State of the motor carrier's principal place of business. The request must include the information required by §  395.34(d)(2).

Last Updated : March 10, 2022

If an ELD malfunction prevents the driver from presenting HOS to a safety official, the driver must:

  • Note the malfunction of the ELD and provide written or electronic notification of the malfunction to the motor carrier within 24 hours;
  • Reconstruct the record of duty status (RODS) for the current 24-hour period and the previous 7 consecutive days, and record the RODS on graph-grid paper logs that comply with 49 CFR 8, unless the driver already has the records or the records are retrievable from the ELD; and
  • Continue to prepare RODS on paper a paper log in accordance with §  8, if the malfunction hinders the accurate recording of the driver's hours of service data, until the ELD is back in compliance.
    • Recording RODS on a paper log cannot continue for more than 8 days after the malfunction unless an extension is given in accordance with §  34 – ELD Malfunctions and Data Diagnostic Events.
    • A driver who records hours of service on a paper log for more than 8 days without proof of an extension from the Federal Motor Carrier Safety Administration may be placed out of service.
Last Updated : March 10, 2022

When a driver edits a manually entered Special Driving Category to a manual Drive event, the driver may edit the location, but not the odometer value. Odometer information may not be entered manually and must be left blank. Manually entered location information, entered in the manual special driving category event, may be edited. An automatically captured location may not be edited and must retain the geo-coordinates from the original manually entered event.

Last Updated : March 10, 2022

While not required, the motor carrier can include an ELD support system that allows drivers to make edits to ELD data when away from the ELD.

Last Updated : March 10, 2022

Edits which reduce the total amount of driving time automatically recorded by the ELD are not allowed. Unidentified driving time may be transferred to a driver and driving time may be transferred between drivers in a team driving scenario, but driving time may not otherwise be re-assigned and may never be cumulatively changed. Per 49 CFR 395.30(f), the ELD must keep the original, unedited record, along with the edits. See sections 4.3.2.8.2 of 49 CFR part 395, subpart B, Appendix A for more information on editing limitations.

Events of type 2 (intermediate log), 5 (login/logout), 6 (CMV power-up/shut-down) or 7 (malfunction/diagnostic) may not be edited in any way. This includes assumption of logs from the unidentified driving profile. If unidentified driving time gets assumed by a driver, the automatically generated change in duty status events would be associated with the driver, but any intermediate logs would not. Since the ELD rule does not allow for intermediate events assumed by the driver to be made inactive, the ELD provider may program the ELD to annotate the events with "assumed by driver [name of driver]".

Last Updated : March 10, 2022

If both the safety official and the driver are experiencing internet connectivity issues, then the safety official will use the ELD display screen or a printout from the ELD to review the ELD data. However, if the internet connectivity issue is only being experienced by the ELD, the device may be identified as a potentially non-compliant device. The safety official will use the display screen or printout to review the ELD data if the data cannot be transferred, regardless of the reason.

For web services and email, the device must be capable of independently connecting to the internet in a reliable manner whenever a roadside inspection occurs. An implementation that depends on Wi-Fi being present at the roadside or that only offers an extremely limited coverage area may not meet the requirements of an ELD.

Last Updated : March 10, 2022

A driver using an ELD must have an ELD information packet onboard the CMV containing the following items:

  1. A user's manual for the driver describing how to operate the ELD;
  2. An instruction sheet describing the data transfer mechanisms supported by the ELD and step-by-step instructions to produce and transfer the driver's hours-of-service records to an authorized safety official;
  3. An instruction sheet for the driver describing ELD malfunction reporting requirements and recordkeeping procedures during ELD malfunctions; and
  4. A supply of blank driver's record of duty status (RODS) graph-grids sufficient to record the driver's duty status and other related information for a minimum of 8 days.
Last Updated : March 10, 2022

The electronic logging device (ELD) must use the email address available to vendors via the ELD Provider Portal (login required).

Last Updated : March 10, 2022

Yes. If the United States (U.S.) destination is within a 150 air-mile radius of a Canada/Mexico-domiciled motor carrier’s driver’s normal work reporting location and the driver returns to that location and is released from work within 12 hours, then the driver is not required to keep a paper log or use an electronic logging device (ELD) during the U.S. portion of the trip.

Last Updated : March 10, 2022

Canada and Mexico-domiciled motor carriers that are not subject to the electronic logging device (ELD) rule may operate in the United States (U.S.) with an AOBRD that meets the definition of an AOBRD in 49 CFR 395.15 . A motor carrier domiciled in Canada or Mexico that is subject to the ELD rule must use an ELD when operating in the U.S.

Last Updated : March 10, 2022

Yes, the rule does allow for the use of a mobile device (commonly called a portable or handheld unit). A portable ELD must be mounted in a fixed position during commercial motor vehicle (CMV) operation and visible to the driver from a normal seated driving position. This information can be found in the 49 CFR 395.22(g).

Apps are allowed to be ELDs as long as they are integrally connected to the electronic control module (ECM) bus for the required data and meet all the technical specs.

If more than one component is required to ensure the ELD is compliant with 49 CFR part 395, subpart B, Appendix A, all components must be present and available to the officer to be reasonably viewed at the roadside for the driver to be considered operating with an ELD when an ELD is required.

Last Updated : March 10, 2022

A motor carrier must retain ELD RODS data and supporting documents for six months. For more information, see 49 CFR 395.8(k)(1). Additionally, a back-up copy of ELD records must be maintained on a device separate from that where original data was stored for six months. Additionally, a motor carrier must retain a driver's ELD records in a manner that protects driver privacy. For more information, see § 395.22(i).

Last Updated : March 10, 2022

The motor carrier is responsible for checking that their device is registered, as established in 49 CFR 395.22. Motor carriers should only purchase an ELD that is self-certified by the manufacturer to be compliant and that is registered and listed on the FMCSA website.

The list of registered ELDs can be found at https://eld.fmcsa.dot.gov/List. Motor carriers should also familiarize themselves with the ELD checklist and the ELD rule.

In the event that an ELD is removed from the registration list, FMCSA will place the removed device on FMCSA's Revoked ELDs List.

Last Updated : March 10, 2022

While not required, if the motor carrier configured the driver user account to authorize a special driving category, then the graph-grid will overlay periods using a different style line (such as dashed, dotted line, or shading) in accordance with section 4.8.1.3(c)(2) of 49 CFR part 395, subpart B, Appendix A. The appropriate abbreviation must also be indicated on the graph-grid.

If the motor carrier does not configure the driver user account to authorize special driving categories, then the driver must annotate the beginning and end of the applicable special driving category.

Last Updated : March 10, 2022

Yes, a motor carrier operating a vehicle with a manufactured model year of 2000 or newer and without an ECM is subject to the ELD rule, as established by 49 CFR 395.8(a)(1)(iii). If the currently installed engine does not support an ECM and is unable to obtain or estimate the required vehicle parameters, then the operator must use an ELD that does not rely on ECM connectivity, but nevertheless meets the accuracy requirements of the ELD rule. See sections 4.2 and 4.3.1 of 49 CFR part 395, subpart B, Appendix A for accuracy requirements.

Last Updated : March 10, 2022

Section 395.8(j)(2) provides that "Motor carriers, when using a driver for the first time or intermittently, shall obtain from the driver a signed statement giving the total time on duty during the immediately preceding 7 days and the time at which the driver was last relieved from duty prior to beginning work for the motor carriers." In the alternative, the driver may present copies of the previous 7 days' RODS status or a print-out of the preceding 7 days from the previous carrier's ELD system.

Last Updated : March 10, 2022

The 30-day period is not restricted to a single month, but applies to any 30-day period. For example, June 15 to July 14 is considered a 30-day period.

Last Updated : March 10, 2022

If a driver operates in the U.S. and is required to use a record of duty status (RODS) for more than 8 days out of any 30-day period, the driver is subject to the ELD rule unless another ELD exception applies.

Last Updated : March 10, 2022

An edit is a change to an electronic logging device (ELD) record that does not overwrite the original record, while an annotation is a note related to a record, update, or edit that a driver or an authorized support personnel may input to the ELD. Section 49 CFR 395.30(c)(2) requires that all edits, whether made by a driver or the motor carrier, be annotated to document the reason for the change. For example, an edit showing time being switched from "Off Duty" to "On-Duty Not Driving" could be annotated by the carrier to note, "Driver logged training time incorrectly as off-duty." This edit and annotation would then be sent to the driver for approval in accordance with §  395.30.

Last Updated : March 10, 2022

For a reset or replaced ELD, under 49 CFR 395.8(k), data or documents showing the driver's record of duty status (RODS) for the current 24-hour period and the previous 7 days must still be retained. These can either be uploaded into the "new" ELD or retained in paper format.

Last Updated : March 10, 2022

Under 49 CFR 395.30(c)(3), the driver account associated with the driving time records may be edited and reassigned between the team drivers, if there was a mistake resulting in a mismatch between the actual driver and the driver recorded by the ELD, and if both team drivers were indicated in one another's records as a co-driver. Each co-driver must confirm the change for the corrective action to take effect.

Last Updated : March 10, 2022

In 49 CFR 390.36(a), FMCSA defines harassment as an action by a motor carrier toward one of its drivers that the motor carrier knew, or should have known, would result in the driver violating hours of service (HOS) rules in part 395 or §  392.3. These rules prohibit carriers from requiring drivers to drive when their ability or alertness is impaired due to fatigue, illness, or other causes that compromise safety. To be considered harassment, the action must involve information available to the motor carrier through an ELD or other technology used in combination with an ELD. In §  390.36(b), FMCSA explicitly prohibits a motor carrier from harassing a driver.

Last Updated : March 10, 2022

The ELD rule has provisions to prevent the use of ELDs to harass drivers. Under 49 CFR 390.36, FMCSA explicitly prohibits a motor carrier from harassing a driver, and provides that a driver may file a written complaint under §  386.12(b) if the driver was subject to harassment. Technical provisions that address harassment include a mute function to ensure that a driver is not interrupted in the sleeper berth. Furthermore, the design of the ELD allows only limited edits of an ELD record by both the driver and the motor carrier's agents, and in either case, the original ELD record cannot be changed. As a result, motor carriers will be limited in forcing drivers to violate the hours of service (HOS) rules without leaving an electronic trail that would point to the original and revised records. The driver certification is also intended, in part, to protect drivers from unilateral changes—a factor that drivers identified as contributing to harassment.

Harassment will be considered in cases of alleged HOS violations; therefore, the penalty for harassment is in addition to the underlying violation under §  392.3 or part 395. An underlying HOS violation must be found for a harassment penalty to be assessed.

Last Updated : March 10, 2022

No. Real-time tracking of CMVs is not required in the ELD rule. However, a motor carrier may use technology to track its CMVs in real time for business purposes. A motor carrier is free to use this data as long as it does not engage in harassment as defined in 49 CFR 390.36 or violate other provisions of the Federal Motor Carrier Safety Regulations (FMCSRs).

Last Updated : March 10, 2022

No. ELDs are not required to collect data on vehicle speed, braking action, steering function, or other vehicle performance parameters. ELDs are only required to collect data to determine compliance with hours of service (HOS) regulations.

Last Updated : March 10, 2022

No. The ELD will capture all entered duty statuses, and there is no minimum amount of time that these statuses must or should be engaged. While longstanding industry and enforcement practices may have relied upon minimum intervals of 15 minutes in handwritten record of duty status (RODS), an ELD provides a more accurate accounting of drivers’ time. This should not be construed to indicate that the activities electronically recorded as less than 15 minutes are suspect, only that the time actually required to complete the task may be less than what had been traditionally noted in the paper RODS.

Last Updated : March 10, 2022

The device manufacturer may offer that service as part of a fleet management package but mileage tracking for tax reporting purposes is not part of the ELD data established in 49 CFR part 395.

Last Updated : March 10, 2022

If the driver is using a “telematics” electronic logging device (ELD) with email capabilities, the authorized safety official may request that the electronic data transfer file be sent as an attachment to an email. This email address is preprogramed in the ELD by the vendor. The safety official will provide the driver with a routing code to reference in the email.

Last Updated : March 10, 2022

A “missing required data elements data diagnostic event” occurs when any required data field is missing at the time of recording.

Last Updated : March 10, 2022

Yes. A motor carrier may file an ELD malfunction extension request via email by submitting the extension request to ELD-Extension@dot.gov. Include the legal name, principal place of business address and USDOT Number of the motor carrier. The extension request must include the following information:

  • The name, address, and telephone number of the motor carrier representative who will file the request;
  • The make, model, and serial number of each ELD;
  • The date and location of each ELD malfunction as reported by the driver to the carrier; and
  • A concise statement describing actions taken by the motor carrier to make a good faith effort to repair, replace, or service the ELD units, including why the carrier needs additional time beyond the 8 days provided by 49 CFR part 34.

To request an extension from the FMCSA Division Administrator in the Field Office in your state, you may contact the office directly. FMCSA Division Administrator contact information can be found at https://www.fmcsa.dot.gov/mission/field-offices#Field-Offices.

Last Updated : March 10, 2022

FMCSA recommends that drivers first certify their RODS before logging off the ELD and shutting down the commercial motor vehicle’s (CMV) engines. If drivers don’t follow this recommendation, malfunction codes may occur, such as indicating unaccounted odometer changes and suspicious driving activity.

Last Updated : March 10, 2022

No. The ELD rule requires that the ELD can transfer data electronically, and produce the driver’s hours of service as either an ELD printout or display.

Last Updated : March 10, 2022

The ELD rule does not change any of the current hours of service exemptions. Therefore, motor carriers that meet the exemptions defined in § 395.1 are not subject to part 395, including the ELD rule while they are operating under the terms of the exemption. The duty status of the driver may be noted as either off-duty (with appropriate annotation), or "exempt." Learn more about the agriculture exemption.

Last Updated : March 10, 2022

Yes. When operating in the U.S., a motor carrier must use an ELD that displays vehicle road miles information in units of whole miles.

Last Updated : March 10, 2022

Vendors should register each device bundle if they have different operating systems (e.g., an iOS-based bundle and an Android-based bundle would be considered two registered devices).

Last Updated : March 10, 2022

No, an electronic logging device (ELD) must not allow creation of more than one driver account associated with a driver’s license for a given motor carrier.

In the case of owner-operator, the same person may have two accounts: a driver account for logging hours of service and a supporting personnel account for managing the backend.

Last Updated : March 10, 2022

No, the ELD ruler does not require interoperability—one device does not need to have the capability to transfer data from one ELD to another.

Last Updated : March 10, 2022

The ELD rule does not prohibit this type of communication. However, manufacturers should keep in mind that in places without coverage, and without cellular communication, the device may not be able to record or display records of duty status (RODS), which would leave the driver not current to the last duty status change or operating without logs—a violation of the hours of service rules.

Last Updated : March 10, 2022

Partial VIN is not permitted. If the VIN cannot be fully obtained from the electronic control module (ECM), it may be entered manually; however, a partial VIN broadcast can be used to aid the driver in entering a manual VIN. Please note:

  • Providers are encouraged to use the VIN check digit calculation to help prevent user entry errors.
  • A VIN with any level of manual entry must be prefixed by a "-" character in the output file.
  • Manual VIN entry cannot be used when the complete VIN can be obtained from the ECM. A device using manual entry when the complete VIN is in fact available from the ECM would not be in compliance with the rule and would be subject to removal from the list of self-certified and registered ELDs.
Last Updated : March 10, 2022

The rule calls for storing date/time information using Coordinated Universal Time (UTC) and transmitting data in the data file using the UTC offset in effect at the driver’s home terminal. This means that when daylight saving’s time is in effect at the home terminal, at the time the ELD output file is being generated, it should be included in the UTC offset. It would not be included in the UTC offset if daylight savings time is not in effect at the home terminal.

Last Updated : March 10, 2022

No. The display and print requirement serves as a backup to the data transfer methods. In the event that data transmission fails during a roadside inspection, the safety official must be able to view the required information without entering the commercial motor vehicle (CMV). This can be accomplished via either the ELD screen or a printout from the ELD, whichever is supported by the device. If a provider selects the display requirement as the backup method, the device is not required to meet the print requirement and vice versa.

Last Updated : March 10, 2022

This distance is not specified in order to account for the variety in size of screens. The safety official must be able to read the screen display without having to physically enter the CMV.

Last Updated : March 10, 2022

This size requirement is for print only. It does not apply to the ELD screen display.

Last Updated : March 10, 2022

Under section 4.8.1.2 of 49 CFR part 395, subpart B, Appendix A, if an electronic logging device (ELD) cannot produce a printout for use at roadside inspection, the display must be designed so that it can be reasonably viewed from outside the commercial motor vehicle (CMV). That may require the device to be untethered from its mount or connected in a manner that would allow it to be passed outside of the vehicle for a reasonable distance.

Last Updated : March 10, 2022

The header should be populated with the commercial motor vehicle (CMV) data and co-driver data (if applicable) at the end of the report period. The actual date and location information must be reflected as required in the ELD data.

Last Updated : March 10, 2022

All power up and shut down events for all commercial motor vehicles (CMVs) used by the driver within the time period that is being requested should be included, including those events that belong to another driver (e.g., if the driver was not using that CMV on that day).

Last Updated : March 10, 2022

The manufacturer must select at least one complete option, either telematics (email and web services) or local transfer (USB 2.0 and Bluetooth®). So long as one option, which includes both methods, is met, the ELD is compliant. Manufacturers may offer additional methods if they choose.

Last Updated : March 10, 2022

If a data transfer method fails and another is available, the safety official can elect to try the alternate transfer method, or review the ELD data via display screen or printout. If validation fails and provides an error code, the provider should have a process in place that allows its customers to report the error. FMCSA has a process in place for diagnosing and communicating any issues that arise as a result of technical difficulties experienced by the Agency.

Last Updated : March 10, 2022

If the provider makes a change that would cause any of the registered ELD values to change, an update to the ELD registration must be made; updated information will be reviewed by FMCSA to ensure all required registration information is included. The provider can also determine the best route for making this change—either updating a current listing, or registering a new ELD.

Note: Any change that results in an update to the ELD Identifier or provider public/private key pair must be reflected on the ELD registration website.

Last Updated : March 10, 2022

The ELD provider may tailor the device to its customers’ needs/operations to assist them in accurately monitoring drivers’ hours of service compliance in accordance with the hours of service standards of the country operated in, such as cross-border operations.

Last Updated : March 10, 2022

According to the ELD rule technical specifications, an ELD must support one of two options for electronic data transfer:

  • The first option is a "telematics" transfer type ELD. At a minimum, it must electronically transfer data to an authorized safety official on demand via wireless web services and email.
  • The second option is a "local" transfer type ELD. At a minimum, it must electronically transfer data to an authorized safety official on demand via USB2.0 and Bluetooth®.

 To ensure that law enforcement is always able to receive the hours of service data during a roadside inspection, a driver must be able to provide either the display or a printout when an authorized safety official requests a physical display of the information.

Last Updated : March 10, 2022

When a vehicle is registered, the model year should follow the criteria established by the National Highway Traffic Safety Administration (NHTSA). Generally, the model year is determined by reviewing the vehicle identification number (VIN) on the vehicle registration. If the model year is pre-2000 based on the VIN, an ELD is not required.

However, there may be instances when the model year reflected on the vehicle registration is not the same as the engine model year, most commonly when a vehicle is rebuilt using a "glider kit" or when an engine is swapped from one vehicle to another. Vehicles with engines predating model year 2000 are also accepted and are not required to have an ELD, even if the VIN reported on the registration indicates that the commercial motor vehicle (CMV) is a later model year. While the driver is not required to possess documentation that confirms the vehicle engine model year, 49 CFR part 379 Appendix A requires motor carriers to maintain all documentation on motor and engine changes at the principal place of business.

Last Updated : March 10, 2022

Yes. Motor carriers with operations that are exempt from the requirements of § 395.8 are exempt from the ELD rule.

Last Updated : March 10, 2022

Yes. However, the ELD must comply with the ELD rule's technical specifications. The ELD may use alternative sources to obtain or estimate the required vehicle parameters, in accordance with the accuracy requirements in sections 4.3.1 of 49 CFR part 395, subpart B, Appendix A.

Last Updated : March 10, 2022

No. The transportation of mobile or modular homes does not qualify for an exception under § 395.8(a)(1)(iii)(A)(2) because the vehicle driven in transporting the mobile or modular home is not part of the shipment, nor does the transport qualify under § 395.8(a)(1)(iii)(A)(3) because the shipment is neither a motorhome or recreational vehicle trailer.

Last Updated : March 10, 2022
  • A motor carrier driver operating a rental truck with a rental agreement that exceeds 8 days must comply with the ELD rule unless another ELD exemption applies.
  • If a property-carrying truck is rented for 8 days or less, as indicated in the rental agreement, drivers are not required to use an ELD. To meet this exemption, the driver and motor carrier must maintain the following:
    • A copy of Federal Register Notice (FRN) 82 FR 47306, "Hours of Service of Drivers: Application for Exemptions; Truck Renting and Leasing Association (TRALA)" dated Oct. 11, 2017 or an equivalent signed Federal Motor Carrier Safety Administration (FMCSA) exemption document. This document must be provided to safety officials on request.
    • A copy of the rental agreement. The rental agreement must clearly identify the parties to the agreement, the vehicle, and the dates of the rental period.
    • Copies of the driver's record of duty status (RODS) for the current 24-hour period and the prior 7 days, if RODS are required on those days.
Last Updated : March 10, 2022
  • Drivers qualify for the 100 air-mile radius (short-haul) exception regardless of the number of times they enter the U.S., provided they meet all requirements of the short-haul exception under 49 CFR 395.1(e).
  • If a driver operates in the U.S. for more than 8 days during a 30-day period and does not qualify for the short haul exception after the 8th day, the driver is subject to the ELD rule unless another exemption applies.
Last Updated : March 10, 2022

Under 49 CFR 395.11, motor carriers must retain up to 8 supporting documents for every 24-hour period that a driver is on duty.

If a motor carrier retains more than 8 supporting documents for a driver’s 24-hour period, the motor carrier must maintain the supporting document that has the earliest time indication as well as the one with the latest time indication. Drivers must submit their supporting documents to the motor carrier no later than 13 days after receiving them.

Last Updated : March 10, 2022

Under 49 CFR 395.8(k)(1), motor carriers must retain RODS and supporting documents for six months from the date of receipt.

Last Updated : March 10, 2022

Supporting documents required in the normal course of business are important to verify a driver's records of duty status (RODS). They consist of 5 categories, described in 49 CFR 395.11(c):

  • Bills of lading, itineraries, schedules, or equivalent documents that indicate the origin and destination of each trip;
  • Dispatch records, trip records, or equivalent documents;
  • Expense receipts related to any on-duty not-driving time;
  • Electronic mobile communication records, reflecting communications transmitted through a fleet management system; and
  • Payroll records, settlement sheets, or equivalent documents that indicate what and how a driver was paid.

If a driver keeps paper RODS under §  395.8(a)(1)(iii), the carrier must also retain toll receipts. For drivers using paper RODS, toll receipts do not count toward the eight-document cap.

Last Updated : March 10, 2022

Two categories of supporting documents—electronic mobile communications and payroll records—are not documents a driver would have to physically retain. These types of documents may be part of a larger record that the carrier retains electronically or physically at the dispatch location or principal place of business. Under 49 CFR 395.11(d)(2), all information in an electronic mobile communication record will be counted as one document per duty day.

Last Updated : March 10, 2022

No. Documents acquired throughout the day are to verify drivers' compliance with the hours of service regulations. 49 CFR 395.11 contains more specific information on the requirements for supporting documents.

Last Updated : March 10, 2022

Under 49 CFR 395.11(c)(2)(i), a supporting document must contain the following elements:

  • Driver name or carrier-assigned identification number, either on the document or on another document enabling the carrier to link the document to the driver. The vehicle unit number can also be used if it can be linked to the driver;
  • Date;
  • Location (including name of nearest city, town, or village); and
  • Time

However, under §  395.11(c)(2)(ii), if a driver has fewer than 8 supporting documents containing these four data elements for a 24-hour period, a document containing all of the elements except time is considered a supporting document.

Last Updated : March 10, 2022

Under 49 CFR 395.11(c)(2)(ii), if a driver has fewer than 8 documents for a 24-hour period that include all 4 elements identified in §  395.11(2)(i)–link to driver, date, location, and time–a document that contains all of the elements except “time” is considered a supporting document.

Last Updated : March 10, 2022

Under 49 CFR 395.11(d)(3), if a motor carrier has more than 8 supporting documents for a 24-hour period, the motor carrier must retain the supporting documents containing the earliest and latest time indications and 6 other supporting documents. If the motor carrier has fewer than 8 documents, the motor carrier must keep each document.

Last Updated : March 10, 2022

Under 49 CFR 395.11(g), upon request during a roadside inspection, a driver must provide any supporting document in the driver's possession for an authorized safety official's review. A driver need not produce the supporting document in a format other than that in which the driver possesses it.

Last Updated : March 10, 2022

Yes. A driver can use annotations to indicate the beginning and end of a period of authorized personal commercial vehicle use, or yard moves, as well as other special driving categories, such as adverse driving conditions (49 CFR 395.1(b)) or oilfield operations (§395.1(d)). Additionally, under§ 395.30(c)(2), drivers or support personnel are required to annotate every change or addition to an ELD record.

Last Updated : March 10, 2022

Yes. In accordance with 49 CFR 395.30(f), the original ELD records are retained even when allowed edits and annotations are made. If the driver cannot independently access the records from the ELD, the motor carrier must provide access on request. However, the right to access is limited to a six-month period, consistent with the period during which a motor carrier must retain drivers' records of duty status (RODS).

Last Updated : March 10, 2022

All of the driver’s hours of service must be accounted for when subject to the hours of service rules. A driver can manually add any on-duty not driving time accrued prior to operating a commercial motor vehicle.

Last Updated : March 10, 2022

Yes. Drivers may edit their RODS using ELD back office support systems. While these edits or corrections are allowed to ensure an accurate record of the driver's duty status, under 49 CFR 395.30(f) and the technical specifications in 49 CFR part 395, subpart B, Appendix A, the electronic record must retain what was originally recorded, as well as the date, time, and identity of the individual entering the corrections or edits.

Last Updated : March 10, 2022

If multiple, compatible ELDs are used to record a driver's RODS within a motor carrier's operation, the ELD in the vehicle the driver is operating must be able to produce a complete ELD report for that driver, on demand, for the current 24-hour period and the previous 7 consecutive days as required by 49 CFR 395.8(k).

Last Updated : March 10, 2022

The motor carrier and the driver are responsible for ensuring that the driver is able to produce a complete ELD report for the current 24-hour period and the previous 7 consecutive days as required by 49 CFR 395.8(k). If the driver uses multiple ELDs that are not compatible (e.g., the data file from one system cannot be uploaded into the other system), the driver must either manually enter the missing duty status information or provide a printout from the other system(s) so that an accurate accounting of the duty status for the current and previous seven days is available for the authorized safety official.

Last Updated : March 10, 2022

Under 49 CFR 395.32(b), when prompted by the ELD, a driver must review any unassigned driving time when he or she logs into the ELD. If the unassigned records do not belong to the driver, the driver must indicate that in the ELD record. If driving time logged under this unassigned account belongs to the driver, the driver must add that driving time to his or her own record.

Last Updated : March 10, 2022

Under 49 CFR 395.32(c), a motor carrier must either annotate the record and explain why the time is unassigned or assign the time to the appropriate driver. The motor carrier must retain unidentified driving records for at least 6 months from the date of receipt as a part of its hours of service ELD records and make them available to authorized safety officials.

Last Updated : March 10, 2022

Yes, a driver can be assigned unidentified driver records recorded under the Unidentified Driver profile and indicate a special driving category. However, under section 4.3.2.8.2(b) of 49 CFR part 395, subpart B, Appendix A, an electronic logging device (ELD) must not allow automatically recorded driving time for a driver to be shortened.

Last Updated : March 10, 2022

Yes, a driver can edit their record after erroneously accepting a driving event that was originally recorded under the Unidentified Driver profile. The ELD must prompt the driver to annotate edits. In addition, in accordance with 49 CFR 395.32(c), the carrier can suggest the edit which can be routed to the driver for confirmation.

Last Updated : March 10, 2022

As defined in 49 CFR 390.36, a motor carrier can only be found to have committed harassment if the driver commits a specified underlying hours of service violation based on the carrier's actions and there is a connection to the electronic logging device (ELD). Adverse action against the driver is not required, because the driver complied with the carrier's instructions.

In contrast, coercion, as defined in §  390.5T, is much broader in terms of entities covered, and addresses the threat to withhold work from or take adverse employment action against a driver in order to induce the driver to violate a broader range of regulatory provisions or to take adverse action to punish a driver for the driver's refusal to operate a commercial motor vehicle (CMV) in violation of the specified regulations. Unlike harassment, coercion does not have to result in the driver being in violation of the regulations and does not have to involve the use of an ELD.

Last Updated : March 10, 2022

FMCSA encourages any driver who feels that he or she was the subject of harassment to also consider FMCSA's coercion rule, 49 CFR 390.6, and the Department of Labor's whistleblower law, enacted as part of the Surface Transportation Assistance Act (49 U.S.C. 31105), which provides retaliation protection.

Last Updated : March 10, 2022

A driver must file a written harassment complaint no later than 90 days after the event in accordance with 49 CFR 386.12(b).

Last Updated : March 10, 2022

In accordance with 49 CFR 390.36(c) and 386.12(b),the driver must file a written complaint with the National Consumer Complaint Database at http://nccdb.fmcsa.dot.gov or with the FMCSA Division Administrator for the State where the driver is employed (http://www.fmcsa.dot.gov/mission/field-offices).

Last Updated : March 10, 2022

Under 49 CFR 390.36 and 386.12(b), the following information must be submitted in writing:

  1. Driver's name, address, and telephone number;
  2. Name and address of the motor carrier allegedly harassing the driver; and
  3. Statement of the facts to prove each allegation of harassment, including:
    1. How the electronic logging device (ELD) or other technology used with the ELD contributed to harassment.
    2. The date of the alleged action.
    3. How the motor carrier's action violated either §  3 or 395.
    4. Driver's signature.

Any supporting evidence that will assist FMCSA in the investigation of the complaint should also be included along with the complaint.

Last Updated : March 10, 2022

No. Vehicle location information is not sufficiently precise to identify street addresses. For each change in duty status, the electronic logging device (ELD) must convert automatically captured vehicle position in latitude/longitude coordinates into geo-location information that indicates the approximate distance and direction to an identifiable location corresponding to the name of a nearby city, town, or village, with a State abbreviation.

Last Updated : March 10, 2022

No. The specifications for ELDs do not include requirements to control the vehicle. An ELD is a recording device that records vehicle parameters through its synchronization to the vehicle's engine and allows for entries related to a driver's record of duty status (RODS).

Last Updated : March 10, 2022

During on-duty driving periods, the location accuracy is approximately within a 1-mile radius. When a driver operates a commercial motor vehicle (CMV) for personal use, the position reporting accuracy would be approximately within a 10-mile radius.

Last Updated : March 10, 2022

No, the electronic logging device (ELD) must be able to monitor engine operation to automatically capture required data. A global positioning system (GPS) is not integrally synchronized with a vehicle's engine, and cannot be a substitute for required ECM data to comply with the ELD rule.

Last Updated : March 10, 2022

Yes. FMCSA allows, but does not require, warning or notification to drivers when they are nearing their hours of service limits.

Last Updated : March 10, 2022

An ELD must automatically switch to driving mode once the commercial motor vehicle (CMV) is moving up to a set speed threshold of 5 miles per hour. As a result, the in-motion state must not be configured greater than 5 miles per hour. The vehicle will be considered stopped once its speed falls to zero (0) miles per hour and stays at zero (0) miles per hour for 3 consecutive seconds.

Last Updated : March 10, 2022

When the duty status is set to Driving, and the commercial motor vehicle (CMV) has not been in motion for 5 consecutive minutes, the ELD must prompt the driver to confirm a continued driving status or enter the proper duty status. If the driver does not respond to the ELD prompt within 1 minute, the ELD must automatically switch the duty status to On-Duty Not Driving (ODND).

Last Updated : March 10, 2022

Authorized safety officials who conduct roadside enforcement activities (i.e., traffic enforcement and inspections) or compliance safety investigations will have the option of choosing a minimum of one electronic data transfer method (web services or email) and one "local" electronic data transfer method (USB 2.0 or Bluetooth®) for the electronic transfer of ELD data, depending on the type of ELD.

Last Updated : March 10, 2022

If a driver is using a "local" electronic logging device (ELD) with USB 2.0 capabilities, an authorized safety official will provide a secure USB device to allow the driver to electronically transfer data from the ELD to the official. The driver will return the USB device to the safety official, who will transfer the data to a computing device.

Last Updated : March 10, 2022

While the local Bluetooth® requires the use of web services, local Bluetooth® data transfer requires only the safety official to have internet connectivity and not the electronic logging device (ELD). The driver's/motor carrier's ELD will use the safety official's internet connection to transfer data. The internet connection between the ELD and the safety official will be limited and can only be used for the purpose of transferring the ELD data via the web service. During Bluetooth® data transfer, the driver/motor carrier must make the ELD discoverable. Once the ELD detects the safety official's laptop, the safety official will provide the driver/motor carrier with a Bluetooth® code to enter into the ELD and confirm Bluetooth® connectivity between the safety official's laptop and the ELD. Once the connection between the safety official's laptop and the ELD has been confirmed, the safety official will provide the driver/motor carrier with the safety official's unique code, and the driver/motor carrier will transfer the ELD data to web services for the safety official to retrieve.

Last Updated : March 10, 2022

If the driver is using a "telematics" electronic logging device (ELD) with wireless web services capabilities, the authorized safety official will give the driver a routing code to assist the official in locating the data once transmitted, and the driver will initiate a web transfer to an FMCSA server to be retrieved by the safety official's software.

Last Updated : March 10, 2022

If there are cellular network limitations that prevent the ELD from transferring data to the Federal Motor Carrier Safety Administration's (FMCSA) web services, the safety official will use the ELD's display screen or printout to verify compliance with the U.S. hours of service regulations.

Last Updated : March 10, 2022

Yes. An ELD must monitor its compliance with the ELD technical requirements and detect malfunctions and data inconsistencies related to power, data synchronization, missing data, timing, positioning, data recording, data transfer, and unidentified driver records requirements. The ELD output will identify these data diagnostic and malfunction events and their status as either "detected" or "cleared." Typically, a driver can follow the ELD provider's and the motor carrier's recommendations to resolve the data inconsistencies that generate an ELD data diagnostic event, while a motor carrier must correct a malfunction.

Last Updated : March 10, 2022

"Power data diagnostic events" occur when an ELD is not powered and fully functional within 1 minute of the vehicle's engine receiving power and does not remain powered for as long as the vehicle's engine stays powered.

"Power compliance malfunctions" occur when an ELD is not powered for an aggregated in-motion driving time of 30 minutes or more over a 24-hour period across all driver profiles.

Last Updated : March 10, 2022

"Engine synchronization data diagnostic events" occur when an ELD loses electronic control module (ECM) connectivity to any of the required data sources (engine power status, vehicle motion status, miles driven, and engine hours) and can no longer acquire updated values for the required ELD parameters within five seconds of the need.

"Engine synchronization compliance malfunctions" occur when ECM connectivity to any of the required data sources (engine power status, vehicle motion status, miles driven, and engine hours) is lost for more than 30 minutes during a 24-hour period aggregated across all driver profiles.

Last Updated : March 10, 2022

A driver should only use paper logs, electronic logging software, or other electronic means to record their hours of service if the ELD malfunction hinders the accurate recording of the driver's hours of service data (i.e., 10/11, 14/15, 60/70 hours; or 30 minute).

Last Updated : March 10, 2022

The driver should switch to another means of recording hours of service data, such as paper RODS, only if the technical issue precludes the device from accurately recording hours of service data and presenting that hours of service data to a safety official. 

Last Updated : March 10, 2022

An ELD must display a single visual malfunction indicator on the ELD's display or on a stand-alone indicator for all drivers using the ELD. The visual signal must be visible to the driver, be continuously communicated to the driver when the ELD is powered, and clearly illuminate an active malfunction. An ELD must also display a single visual data diagnostics indicator, apart from the malfunction indicator, for active data diagnostics events. The ELD may also provide an audible signal for the data diagnostics indicator.

Last Updated : March 10, 2022

Yes. In the event that the driver experiences a malfunction that impairs the electronic logging device (ELD) ability to present the driver's previous 7 days, the driver may present their previous 7 days by way of any printed copy, or in an electronic form, such as a PDF.

Last Updated : March 10, 2022

Yes, the reconstructed RODS, along with ELD data, must be presented to a safety official during a roadside inspection to satisfy the requirement to display the current day and the previous 7 days of duty status.

Last Updated : March 10, 2022

If an ELD malfunctions, the safety official can decide what methods of record retrieval not specified in the ELD rule are acceptable. This includes options like accepting hours of service records by fax.

Last Updated : March 10, 2022

As stated in 49 CFR 395.22(b)(2)(i) , a motor carrier must manage ELD accounts. Therefore, the driver’s license information must be updated in the ELD. If the data files from an individual’s old and new driver's license files cannot be merged, the driver must either manually enter the previous duty status information or provide a printout from the older hours of service to provide an accurate accounting of the duty status for the current and previous seven days for authorized safety officials.

Last Updated : March 10, 2022

No. Section 4.1.2(c) of 49 CFR part 395, subpart B, Appendix A prohibits multiple driver accounts for one driver. The motor carrier must proactively change the driver's status to and from exempt and non-exempt.

Last Updated : March 10, 2022

FMCSA may initiate removal of an ELD model or version from the list in accordance with section 5.4 of 49 CFR part 395, subpart B, Appendix A, by providing written notice to the ELD provider stating:

  1. The reasons the FMCSA proposes to remove the model or version from the FMCSA list; and
  2. Any corrective action that the ELD provider must take for the ELD model or version to remain on the list.
Last Updated : March 10, 2022

The table below compares the technical specifications in the AOBRD rule (§ 395.15) and the ELD rule.

Feature/Function

1988 AOBRD Rule

ELD Rule

Integral Synchronization

Integral synchronization required, but term not defined in the Federal Motor Carrier Safety Regulations (FMCSRs).

Integral synchronization interfacing with the CMV engine electronic control module (ECM), to automatically capture engine power status, vehicle motion status, miles driven, engine hours. (CMVs older than model year 2000 exempted.)

Recording Location Information of Commercial Motor Vehicle (CMV)

Required at each change of duty status. Manual or automated.

Requires automated entry at each change of duty status, at 60-minute intervals while CMV is in motion, at engine-on and engine- off instances, and at beginning and end of personal use and yard moves.

Graph Grid Display

Not required – "time and sequence of duty status changes."

An ELD must be able to present a graph grid of driver's daily duty status changes either on a display or on a printout.

Hours of Service (HOS) Driver Advisory Messages

Not addressed.

HOS limits notification is not required.

"Unassigned driving time/miles" warning must be provided upon login.

Device "Default" Duty Status

Not addressed.

On-duty not driving status, when CMV has not been in-motion for five consecutive minutes, and driver has not responded to an ELD prompt within one minute. No other non-driver-initiated status change is allowed.

Clock Time Drift

Not addressed.

ELD time must be synchronized to Universal Coordinated Time (UTC); absolute deviation must not exceed 10 minutes at any time.

Communications Methods

Not addressed – focused on interface between AOBRD support systems and printers.

Two Options:

"Telematics": As a minimum, the ELD must transfer data via both wireless Web services and wireless e-mail.

"Local Transfer": As a minimum, the ELD must transfer data via both USB 2.0 and Bluetooth.

Both types of ELDs must be capable of displaying a standardized ELD data set to authorized safety officials via display or printout.

Resistance to Tampering

AOBRD and support systems must be tamperproof, to the maximum extent practical.

An ELD must not permit alteration or erasure of the original information collected concerning the driver's ELD records or alteration of the source data streams used to provide that information. ELD must support data integrity check functions.

Identification of Sensor Failures and Edited Data

AOBRD must identify sensor failures and edited data.

An ELD must have the capability to monitor its compliance (engine connectivity, timing, positioning, etc.) for detectable malfunctions and data inconsistencies. An ELD must record these occurrences.

Last Updated : March 10, 2022

Yes. The driver can add the VIN manually if the ELD cannot retrieve the VIN from the vehicle engine data.

Last Updated : March 10, 2022

Yes. A driver may use a portable handheld ELD, smartphone, or other wireless device if the device meets the ELD rule's technical specifications and is on the Registered ELD list on FMCSA's website.

While operating in the U.S., under 49 CFR 395.22(g), the portable ELD unit, smartphone or other wireless device must be mounted in a fixed position during the vehicle operation and must be visible to the driver from a normal seated position.

Last Updated : March 10, 2022

Yes, vehicles operated by the Canadian Armed Forces in the U.S. are not subject to the FMCSRs.

U.S. Federal, State and local enforcement personnel should not conduct driver/vehicle inspections on vehicles operated by Canadian Armed Forces provided:

  • The driver possesses an appropriate military personal identity card issued by Canada,
  • The driver possesses an individual or collective movement order,
  • The vehicle carries a registration number, and
  • The vehicle contains the distinctive nationality mark of Canada.

Note that the exemption described above applies only to Canadian Armed Forces and not to contractor drivers or vehicles used by the Canadian Armed Forces.

Last Updated : March 10, 2022

Yes. In this case, the 150 air-mile radius from the source of the agricultural commodity in Canada/Mexico would extend up to 100 air-miles within the U.S. The driver would therefore qualify for the hours of service exemption for agricultural operations while remaining within the U.S. portion of that 150 air-mile radius, provided the trip occurs during the planting and harvesting periods, as determined by the U.S. State or States.

Last Updated : March 10, 2022

No. The definition of "covered farm vehicle" in § 390.5 includes, among other things, the requirement that the vehicle be "Registered in a State with a license plate or other designation issued by the State of registration that allows law enforcement officials to identify it as a farm vehicle." Because the term "State" means one of the 50 U.S. States and the District of Columbia, motor carriers domiciled in Canada/Mexico are not eligible for the covered farm vehicle exemption, including the hours of service and ELD elements of that exemption.

Last Updated : March 10, 2022

No. The ECM and ELD may be connected by serial or Control Area Network communication protocols. Hard wiring to the J1939 plug and Bluetooth® connectivity are examples of methods of receiving the data from the ECM or vehicle data bus.

Last Updated : March 10, 2022

An ELD must use onboard sensors and data record history to identify instances when it may not have complied with the power requirements specified in the ELD rule.

Last Updated : March 10, 2022

The manufacture must register each model and version and self-certify that each particular ELD is compliant with the ELD rule. The manufacturer must decide whether a firmware update is sufficiently significant to change the registration information. FMCSA does not specify parameters for version revisions.

Last Updated : March 10, 2022

No. ELD manufacturers may use any test procedure they choose and note this in the registration. FMCSA will not provide a third-party testing service. FMCSA will only investigate devices that are suspected of not conforming to specifications, and will conduct testing with the FMCSA compliance test procedure during its investigation.

Last Updated : March 10, 2022

FMCSA does not specify testing requirements for connectivity with the vehicle. Each ELD provider is responsible for connectivity testing.

Last Updated : March 10, 2022

Yes. Section 4.8.1.3 of 49 CFR part 395, subpart B, Appendix A requires the inspected driver's profile and the Unidentified Driver (UD) profile to be available as separate reports at roadside either by printout or display. If there are no unidentified driver records existing on the electronic logging device (ELD) for the current 24-hour period or for any of the previous 7 consecutive days, an ELD does not need to print or display unidentified driver records for the authorized safety official. Otherwise, both reports must be printed or displayed and provided to the authorized safety official.

Last Updated : March 10, 2022

The ELD is required to obtain and display the ECM value at all times. Safety officials will use the odometer value reported on the ELD. Note that documentation of engine changes is required by 49 CFR part 379 Appendix A to be maintained at the carrier's place of business.

Last Updated : March 10, 2022

You should review the technical specifications included in 49 CFR part 395, subpart B, Appendix A, along with the FMCSA's compliance test procedures. You are required to self-certify your device, stating that it is in compliance with all of the technical specifications. The compliance test procedures are designed to assist manufacturers in determining whether their product meets the ELD rule requirements. While ELD manufacturers are not required to use FMCSA's compliance test procedure, they are required to ensure that their products are compliant with the technical specifications in the ELD rule.

Last Updated : March 10, 2022

The ELD must set the "Event Record Origin" of the ELD record to "2" (edited or entered by the driver).

Last Updated : March 10, 2022

The ELD must set the "Event Record Origin" of the ELD record to "2" (edited or entered by the driver).

Last Updated : March 10, 2022

If the malfunction and/or event does not hinder the ELD's accurate recording of the hours of service, the ELD rule does not require a documentation process. Under 49 CFR 395.34 drivers are still required to report a malfunction to a carrier within 24 hours and the motor carrier is required to repair or replace the malfunctioning ELD within 8 days. However, if the event does not affect hours of service and has been cleared by the ELD itself, the additional reporting requirements under § 395.34 do not apply. In addition, drivers are required to follow any motor carrier instructions for diagnostic events and must review their records of duty status (RODS) and certify they are true and correct under § 395.30. Motor carriers should continue to monitor such short-term diagnostic events and malfunctions to ensure the ELD is operating properly.

Last Updated : March 10, 2022

Engine synchronization in section 4.2 of 49 CFR part 395, subpart B, Appendix A, for purposes of ELD compliance, is defined as the monitoring of the vehicle's engine operation to automatically capture the engine's power status, vehicle's motion status, miles driven value, and engine hours value when the CMV's engine is powered. As described in section 4.3.1.1, the ELD must be powered and become fully functional within one (1) minute of the vehicle's engine receiving power and must remain powered for as long as the vehicle's engine stays powered. Additionally, section 4.5.1.6 allows up to one (1) minute for the ELD to establish a link to the ECM or ECM connection and record all the required data elements during the power up event. Therefore, during the power-up cycle, an ELD has one minute to establish the synchronization required by section 4.2 and record the power up event. The specification is designed to capture when the CMV is put into a state where it can be driven. When the engine is not powered, the ELD does not have to capture data. An engine synchronization diagnostic event should not be recorded by the ELD during the power up cycle until one of the following occurs.

  • Five seconds elapses after the power up cycle is completed and recorded; or
  • Five seconds elapses after the ELD has not established a link to the ECM or ECM connection within one minute of the engine receiving power.
Last Updated : March 10, 2022

When a driver does not log in to the ELD and does not respond to the ELD visual and audible prompts, the ELD must record accumulated driving and On-Duty Not-Driving time in accordance with the ELD defaults (see section 4.4.1 of 49 CFR part 395, subpart B, Appendix A). When more than 30 minutes of driving in a 24-hour period accumulate in the Unidentified Driver (UD) profile, the ELD data diagnostic indicator must be turned on across all drivers logged into that ELD for the current day and the following 7 days. Other events that must be associated with the Unidentified Driver (UD) profile include the commercial motor vehicle (CMV) engine power up and shut down and power compliance monitoring. The ELD must not allow entry of any information into the ELD other than a response to the login prompt.

The Event Log List for the Unidentified Driver Profile may be found in section 4.8.2.1.10.

Last Updated : March 10, 2022

The original records reflecting unidentified driving will remain, but with an inactive status. When unidentified records are assumed, a new event record(s) for the driver is created using elements of the unidentified driver log(s) and driver input to populate missing elements of the log originally recorded under the unidentified driver profile.

Last Updated : March 10, 2022

The rejected unidentified driving events must remain available for review at roadside for 8 days and should be included in the output file.

Last Updated : March 10, 2022

If the driver unplugs an ELD from the ECM and later plugs the ELD back into the ECM, the ELD must identify any odometer jump in between as a malfunction (see Table 4 of 49 CFR part 395, subpart B, Appendix A). In addition, if the ECM is not disconnected, however connectivity is lost for more than 30 minutes in a 24-hour period, an engine synchronization malfunction must be recorded.

Last Updated : March 10, 2022

Yes. Once the unassigned driving time has been reviewed and only certain records were attributable to and assumed by a driver, in accordance with 49 CFR 395.32, it is expected that some events will remain associated with the unidentified driving profile. These event types include intermediate logs, power-up/shut-down, and malfunction/diagnostic, which cannot be edited.

Last Updated : March 10, 2022

Yes. If the ELD is an application on a separate device, the driver must understand that manual power must be on and the ELD application launched prior to starting the vehicle so that the device can recognize the engine start. Failure to start the application would result in the driver operating without an ELD, which would be in violation of the ELD rule.

Last Updated : March 10, 2022

Yes, this is an acceptable way for ELDs to function. If the ELD is structured such that the device must be powered on and logged in to before the engine is powered to meet the requirements of the ELD rule, this should be made clear to the driver through the device manual and carriers should include this in their driver training.

Last Updated : March 10, 2022

If the vehicle does not have an ECM or the ECM does not provide all the information required for, it must be acquired using an independent source apart from the positioning services described under sections 4.3.1.6 of 49 CFR part 395, subpart B, Appendix A and must meet accuracy levels laid out in the rule. Global positioning systems (GPS) cannot be used to identify the vehicle's motion status.

Please note that if there is a means for retrieving data from the ECM, the provider is obligated to use that means (for example, using a synthesized odometer or entering into an agreement with an original equipment manufacturer [OEM] to access proprietary information). If the Federal Motor Carrier Safety Administration (FMCSA) is made aware that a provider has chosen not to undertake the effort to secure data from the ECM that is, in fact, retrievable, the device would be considered non-compliant and removed from the self-certified and registered ELDs.

Last Updated : March 10, 2022

The ELD provider is required to use all means necessary to obtain the required ELD data from the ECM; this may include entering into an agreement with the OEM or another third party. Using manual entry when the ECM is available would not be in compliance with the rule and the device would be subject to removal from the list of self-certified and registered ELDs.

Last Updated : March 10, 2022

If the dashboard odometer display does not match the odometer value returned by the ECM, the ECM odometer value must be identified as the valid value.

Last Updated : March 10, 2022

If it is not possible to obtain the engine hours from the electronic control module (ECM), then the electronic logging device (ELD) may begin recording engine hours at "0" for the given engine the first time the ELD is used with that engine. After the first use, the ELD must continue to keep and use an aggregate total from the first time it was installed or used with an engine. Ideally, back office systems can share this aggregate total so that any other ELD used with the engine can start at the aggregate total, rather than "0."

Last Updated : March 10, 2022

The sequence ID must be continuous to its source device. In an ELD support system, that system may have its own sequence ID generator. Because events cannot be deleted, it should be possible to observe each component in the ELD system which generates sequence IDs and find a continuous list of events for each sequence number without any gaps.

Last Updated : March 10, 2022

In cases when the ELD's battery dies or when the charge power runs out, the ELD must generate a malfunction event. The ELD must set a power compliance malfunction if the power data diagnostics event indicates an aggregated in motion driving time understatement of 30 minutes or more on the ELD over a 24-hour period across all driver profiles, including Unidentified Driver (UD) profile.

Last Updated : March 10, 2022

During data transfers, 49 CFR part 395, subpart B, Appendix A requires additional security protocol through encryption, American National Standard for Information Technology, IEEE Standards Association, and others as incorporated by reference in Appendix A sections 6.

Last Updated : March 10, 2022

Yes, the ELD must allow the driver to review, edit, and annotate their ELD records to account for errors and omissions, as specified in sections 4.3.2.8 of 49 CFR part 395, subpart B, Appendix A.

Last Updated : March 10, 2022

Deleting records is not permitted. To correct errors, drivers must be able to edit, enter missing information into, and annotate the electronic logging device (ELD) records. The original record must be retained and receive an inactive status.

Last Updated : March 10, 2022

The Electronic Logging Device (ELD) rule allows for carriers, using the support personnel account, to propose changes to a driver's ELD data. To protect the driver's logs from manipulation, edits requested by anyone or any system other than the driver must require the driver's electronic confirmation or rejection.

Last Updated : March 10, 2022

If the driver logs into an ELD component that is not connected to a power unit, information pertaining to a power unit is not required. Other data elements required to be recorded by the ELD that will not be available when entering duty status changes such as vehicle identification number (VIN), engine hours, and vehicle miles are only required when the commercial motor vehicle's (CMV's) engine is powered.

Last Updated : March 10, 2022

"WT" refers to "waiting time." This language is carried over from the draft rule and was included in the final version in error. There are no other references to WT found within the rule.

Last Updated : March 10, 2022

The "Driving" duty status must be automatically recorded by the ELD when the operated vehicle meets the configured threshold; not to exceed 5 mph. See sections 4.4.1 of 49 CFR part 395, subpart B, Appendix A.

Last Updated : March 10, 2022

The ELD must provide an option to preconfigure drivers' accounts with yard moves. Should the motor carrier opt to preconfigure a driver's account with yard moves, the driver must select the beginning and end of the yard move period. The graph-grid must overlay periods of driver's indications of yard moves using a different style line (such as dashed or dotted line) or shading. The appropriate abbreviation must also be indicated on the graph-grid.

Last Updated : March 10, 2022

The driver's license information cannot be omitted or redacted. Section 395.22(c) lists the information the motor carrier must provide when creating a driver account and sections 4.8.1.3 of 49 CFR part 395, subpart B, Appendix A lists the information that must be present on the ELD display screen or printout. This information includes the driver's first and last name and driver's license number and issuing state.

Last Updated : March 10, 2022

There should be an annotation on the new record indicating the edit occurred and the old record must be retained, accessible, and included in electronic logging device (ELD) outputs.  

Last Updated : March 10, 2022

The ELD must be able to retrieve and display current data via display screen of the ELD or from a printout from the ELD at the request of a safety official.

Last Updated : March 10, 2022

The ELD must show the following information via the display of the ELD or printout:

Last Updated : March 10, 2022

Yes. As long as the file is being transferred to FMCSA through one of the acceptable data transfer methods and is being triggered by the action at roadside or a compliance investigation.

Last Updated : March 10, 2022

The single-step interface requirement refers to compiling of the driver's records and initiating the data transfer from within the ELD application. This step would take place once logged into the ELD application.

Last Updated : March 10, 2022

The FMCSA will not collect State enforcement agencies' data transfer preferences.

Last Updated : March 10, 2022

"Local" in this option is referring to the electronic logging device (ELD), which does not need its own connection to the internet. When using Bluetooth®, the inspector will share an internet connection that will be used by the ELD device to submit the output file via web services.

Note: The Bluetooth® connection can only be guaranteed to offer connectivity to the FMCSA Web Service, so the connection in this case must come from the device itself as it may not be possible to connect to a back-office system using this connection.

Last Updated : March 10, 2022

The USB device will be self-encrypting; it will not rely on the ELD device for encryption.

Last Updated : March 10, 2022

Yes. The public key is required to be kept updated as part of the self-certification process. Public key updates will be vetted by the Federal Motor Carrier Safety Administration (FMCSA). Additional time will be needed to propagate the update into FMCSA's systems.

Last Updated : March 10, 2022

No. For an app, it is not required that the vendor verify every single device the app will work on, but the registration must include the entire platform (i.e., Android or iPhone). The device that allows connection to the electronic control module (ECM), the phone/tablet OS with version range, and the app together can be certified.

If the electronic logging device (ELD) only works on certain models, the provider will need to specify (e.g., a 64-bit iPhone model with iOS 7 and above).

Note: There should be separate registrations for each platform (i.e., "ELD for Apple" and "ELD for Android" would be registered separately).

Last Updated : March 10, 2022

Public keys should be submitted as a public key certificate. This certificate may be self-signed. The certificate must conform to the specifications outlined in sections 2.2.1 of the ELD Interface Control Document and Web Services Development Handbook.

Last Updated : March 10, 2022

The purpose of the authentication value is to provide a mechanism for cross-checking a transmitted electronic logging device (ELD) file's authenticity. Below is one example of a pseudo-algorithm that could serve as the basis for generating an ELD authentication value:

  1. Extract some subject of the final ELD output file. This could be as little as a few fields or as much as the entire file (minus the ELD Authentication Value). Including the ELD Registration ID would satisfy the requirement that the ELD Authentication Value verify the ELD that generated the value.
  2. Use a standard signing algorithm. Generate a signature for this content using one of the certificates submitted during ELD registration.
  3. Convert this binary signature to a string using a string encoding algorithm that does not use any of the ELD reserved characters (comma—ASCII 44 and carriage return—ASCII 13).
Last Updated : March 10, 2022

Because the electronic control module (ECM) will not support two electronic logging devices (ELDs) and only one driver can be logged into the ELD, the driver in the front cab must log into the ELD and make an annotation that he or she is operating with a tillerman.

The tillerman has the option of manually adding their hours of service to the ELD under their ELD driver account or keep the previous 7 days of their record of duty status (RODS) in their possession for roadside inspections. The same options apply to the motor carrier maintaining the tillerman's (RODS) for 6 months.

Last Updated : March 10, 2022

The Federal Motor Carrier Safety Administration (FMCSA) issued a limited exemption to motor carriers that operate with a rented commercial motor vehicle for 8 days or less. This limited exemption provides that all drivers of property-carrying commercial motor vehicles rented for 8 days or less, regardless of reason, are not required to use an ELD in the vehicle. To meet this exemption, the driver and the motor carrier must maintain the following:

For additional information see FRN 82 FR 47306 Hours of Service of Drivers: Application for Exemption; Truck Renting and Leasing Association (TRALA), published on October 11, 2017.

Last Updated : March 10, 2022

The power unit number is the identifier the motor carrier uses to identify the power unit.

Last Updated : March 10, 2022

The position, engine hours, and vehicle miles should be recorded when the yard move starting and ending events are created as specified in sections 4.5.1.3 of 49 CFR part 395, subpart B, Appendix A. (Note: these elements are included by reference as sections 4.5.1.3 indicates all elements defined in sections 4.5.1.1 be included.).

Last Updated : March 10, 2022

Yes, while the yard move status must be selected by the driver, the electronic logging device (ELD) may allow the carrier to configure scenarios in which the driver can and cannot select the yard move.

Last Updated : March 10, 2022

The <{Event} Date> and <{Event} Time> refers to the date and time of the event in the ELD Event List corresponding with the annotation or comment.

Last Updated : March 10, 2022

Yes, the required ELD manuals listed in 49 CFR 395.22(h) can be in digital format.

Last Updated : March 10, 2022

No. Consistent with its approach to other investigations, FMCSA will not publicize ELD investigations. Should an ELD investigation result in a device being deemed a noncompliant device, then that device will be listed on the ELD revoked list.

Last Updated : March 10, 2022

Yes. Drivers can drive CMVs equipped with ELDs and still use their exception. A motor carrier may configure an ELD to show the exception for drivers exempt from using the ELD, or use the ELD annotation to record the status.

Last Updated : March 22, 2017

Authorized safety officials may inspect and copy motor carrier records and request any records needed to perform their duties.

Last Updated : March 22, 2017

Although the ELD reflects the driver's RODS, the driver and carrier share responsibility for the accuracy of the records. The driver certification is intended, in part, to protect drivers from unilateral changes.

However, if the driver is unavailable or unwilling to recertify the record, the carrier's proposed edit and annotation would remain part of the record.

Last Updated : March 28, 2017

An ELD automatically records the following data elements at certain intervals: date; time; location information; engine hours; vehicle miles; and identification information for the driver, authenticated user, vehicle, and motor carrier.

Last Updated : April 06, 2017

Location data must be recorded by an ELD at 60-minute intervals when the vehicle is in motion, and when the driver powers up and shuts down the engine, changes duty status, and indicates personal use or yard moves.

Last Updated : April 06, 2017

An ELD must be integrally synchronized with the engine of the commercial motor vehicle (CMV). Engine synchronization means monitoring engine operation to automatically capture the engine power status, vehicle motion status, miles driven, and engine hours.

Last Updated : April 06, 2017

Since all ELD data file output will be a standard comma-delimited file, a driver may import the data output file into Microsoft Excel, Word, Notepad, or other common tools. A driver will be able to access ELD records through a screen display or a printout, depending on the ELD design.

Last Updated : April 10, 2017

When the personal conveyance status is selected (as allowed and configured by the motor carrier), the CMV's location is recorded with a lower level of precision (i.e., an approximate 10-mile radius). Personal conveyance will be reflected on the ELD using a different style line (such as dashed or dotted line).

Last Updated : July 12, 2017

In the event of team drivers, the ELD must display the data for both co-drivers who are logged into the system.

Last Updated : April 12, 2017

Yes. The driver who is not operating the vehicle may make entries over his or her own records when the vehicle is in motion. However, co-drivers cannot switch driving roles on the ELD when the vehicle is in motion.

Last Updated : April 17, 2017

A "timing compliance malfunction" occurs when the ELD can no longer meet the underlying compliance requirement to record Coordinated Universal Time (UTC), where ELD time must be synchronized with UTC, not to exceed an absolute deviation of 10 minutes at any time.

Last Updated : April 18, 2017

When an ELD fails to acquire a valid position measurement within 5 miles of the commercial motor vehicle moving and 60 minutes has passed, a "position compliance malfunction" will be recorded in the data diagnostic.

Last Updated : April 18, 2017

A "data recording compliance malfunction" occurs when an ELD can no longer record or retain required events or retrieve recorded logs that are not kept remotely by the motor carrier.

Last Updated : April 18, 2017

A "data transfer data diagnostic event" occurs when the operation of the data transfer mechanism(s) is not confirmed.

A "data transfer compliance malfunction" occurs when the ELD stays in the unconfirmed data transfer mode following the next three consecutive monitoring checks.

Last Updated : April 18, 2017

An "unidentified driving records data diagnostic event" occurs when more than 30 minutes of driving time for an unidentified driver is recorded within a 24-hour period.

Last Updated : April 18, 2017

ELD user accounts must be set up by a motor carrier for:

  1. Commercial motor vehicle (CMV) drivers who are employed by the motor carrier and who are required to use the ELD, and
  2. Support personnel who have been authorized by the motor carrier to create, remove, and manage user accounts; configure allowed ELD parameters; and access, review, and manage drivers' ELD records on behalf of the motor carrier.
Last Updated : April 18, 2017

Yes. ELD user accounts can be created on individual ELDs or the ELD support system.

Last Updated : April 21, 2017

Each driver account must be created by entering the driver's license number and the State of jurisdiction that issued the driver's license. The driver's license information is only required to set up the driver's user account and verify his or her identity; it is not used as part of the daily process for entering duty status information.

Last Updated : April 21, 2017

A motor carrier must assign only one ELD driver account for each of its drivers required to use an ELD. An ELD must not allow the creation of more than one driver account associated with a driver's license for a given motor carrier. The motor carrier is also responsible for establishing requirements for unique user identifications and passwords.

Last Updated : April 21, 2017

No. Each driver should have one account that allows him or her to log in and perform driver-related functions. All other administrative functions should be based on the discretion of each company or its provider. This means a driver who is also the owner of the company would have a single account authorizing entries as a driver, and a separate account for administrative functions. Accounts can be created on the ELD or the ELD support system.

Last Updated : April 21, 2017

The ELD rule includes a procedure to remove a listed registered device from the FMCSA website, to provide additional assurance to motor carriers that ELDs on the vendor registration website are compliant. This procedure also protects an ELD vendor's interest in its product.

Last Updated : April 21, 2017

The technical specifications in the ELD rule ensure that manufacturers develop compliant devices and systems for uniform enforcement of hours of service.

Last Updated : April 21, 2017

Unidentified driving time can be assigned in two ways. The driver can claim the driving time when prompted by the ELD, or the motor carrier can later assign the unidentified driving time to the appropriate driver, which must be accepted by the driver.

Last Updated : March 10, 2022

In displaying the duty status, the full name of the duty status should be used (i.e., Off Duty, Sleeper Berth, Driving, or On-Duty Not-Driving).

Last Updated : March 10, 2022

Yard moves must be reflected as an On-Duty Not-Driving duty status.

Last Updated : March 10, 2022

No. A PDF print transmitted wirelessly would not satisfy the requirement, as print serves as a backup to data transfer.

Last Updated : March 10, 2022

As part of the registration process, three pieces of information are necessary to identify a device: ELD Identifier, ELD public key (both from registering company), and ELD Registration ID (from FMCSA). It is allowable to register multiple devices with the same ELD Identifier and public key, but each registered device will have its own unique ELD Registration ID.

The rule does not require that certification be done by the company manufacturing the device. Branding partners can use the certification performed by the white label company.

Last Updated : March 10, 2022

An authentication value must be greater than or equal to 16 characters. For more information on this update to the technical specifications, see the ELD Interface Control Document and Web Services Development Handbook.

Last Updated : March 10, 2022

No, the replacement record must have its own sequence ID number. When a driver edits an event or a motor carrier suggests an edit, the new event record should have a new sequence ID number.

Last Updated : March 10, 2022

After the initial self-certification, providers will only need to update FMCSA with any major changes to the device.

Last Updated : March 10, 2022