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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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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

"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

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

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

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