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.
Search FAQs or browse the topics below to find what you are looking for.
No. If the electronic means for transferring data is unavailable or fails, the driver can still be compliant by showing either a printout or the actual ELD display of their RODS.
If there are cellular network limitations that prevent the ELD from transferring data to the Federal Motor Carrier Safety Administration's web services, the safety official will use the ELD's display screen or printout to verify compliance with the U.S. HOS regulations.
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.
"Power data diagnostic events" occur when an ELD is not powered and fully functional within one 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.
"Engine synchronization data diagnostic events" occur when an ELD loses 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.
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.
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.
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.
A "missing required data elements data diagnostic event" occurs when any required data field is missing at the time of its recording.
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.
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.
If an ELD malfunctions, a driver must:
- Note the malfunction of the ELD and provide written notice 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, or electronic logging software, that comply with 49 CFR 395.8, unless the driver already has the records or retrieves them from the ELD; and
- Continue to manually prepare RODS in accordance with 49 CFR 395.8 until the ELD is serviced and back in compliance. The recording of the driver's hours of service on a paper log, or electronic logging software, cannot continue for more than 8 days after the malfunction; a driver that continues to record his or her hours of service on a paper log, or electronic logging software, beyond 8 days risk being placed out of service.
A driver should only use paper logs, or electronic logging software, or other electronic means to record their HOS 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).
If an ELD malfunctions, a motor carrier must:
- Correct, repair, replace, or service the malfunctioning ELD within eight days of discovering the condition or a driver's notification to the motor carrier, whichever occurs first; and
- Require the driver to maintain paper record of duty status (RODS) until the ELD is back in service.
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 395.34.
FMCSA recommends that drivers first certify their RODS before logging off the ELDs and then shutting down their CMVs' engines. If drivers don't follow this recommendation, malfunction codes may occur, such as indicating unaccounted odometer changes and suspicious driving activity.
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. A malfunction is a situation in which an ELD is not working properly. A malfunction affects the integrity of the device and its compliance, and requires the motor carrier to repair, replace, or service the ELD.
An ELD must display a malfunction signal (or indicator) such as a light, symbol, or text on the ELD or on a stand-alone display. The malfunction signal must be visible to the driver and display function status whenever the ELD is powered on. It must also light up to draw attention to an active malfunction.
An ELD must also include a diagnostics indicator to display active diagnostic events. Data diagnostic events note data inconsistencies that a driver can typically resolve by following the motor carrier’s or ELD provider’s recommendations.
Yes. In the event that the driver experiences a malfunction that impairs the 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.
Yes, the reconstructed records of duty status along with ELD data must be presented to a safety official during a roadside inspection in order to satisfy the requirement to display the current day and the previous seven days of duty status.
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 HOS records by fax.
No. The ELD rule requires that the ability to transfer data electronically, and produce the driver's HOS as either an ELD printout or display.
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 395.8, 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 49 CFR 395.8 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 49 C.F.R 395.34 – 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.
ELD user accounts must be set up by a motor carrier for:
- Commercial motor vehicle (CMV) drivers who are employed by the motor carrier and who are required to use the ELD, and
- 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.
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.
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 49 CFR 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 and certify they are true and correct under 49 CFR 395.30. Motor carriers should continue to monitor such short-term diagnostic events and malfunctions to ensure the ELD is operating properly.
Under 126.96.36.199 the engine synchronization compliance monitoring requires the ELD to record an engine synchronization diagnostics event when it cannot acquire values for the ELD parameters within 5 seconds of the need. How are these events recorded during the CMV power up cycle when the ECM connection cannot become fully functional within five seconds of the engine receiving power?
Engine synchronization in 4.2, 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 188.8.131.52, the ELD must be powered and become fully functional within one minute of the vehicle’s engine receiving power and must remain powered for as long as the vehicle’s engine stays powered. Additionally, 184.108.40.206 allows up to one 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 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.