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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If an ELD malfunctions, a motor carrier must:
- 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
- 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).
What must a Canada/Mexico-domiciled motor carrier’s driver do if an electronic logging device (ELD) malfunction prevents presenting hours of service (HOS) to a safety official at roadside by electronic data transfer, display screen or printout?
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.
When does an electronic logging device (ELD) “missing required data elements data diagnostic event” occur?
A “missing required data elements data diagnostic event” occurs when any required data field is missing at the time of recording.
May a motor carrier seeking to extend the period of time permitted for repair, replacement, or service of one or more electronic logging devices (ELDs) request an extension?
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.
When should a driver certify his or her record of duty status (RODS) on the electronic logging device (ELD) to avoid malfunction codes?
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.
Must a Canada/Mexico-domiciled motor carrier’s driver using an electronic logging device (ELD) in the United States (U.S.) have a printer in the commercial motor vehicle (CMV)?
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.
What happens if cellular network limitations prevent an electronic logging device (ELD) from transferring data during a United States (U.S.) roadside inspection for a Canada/Mexico-domiciled motor carrier’s driver?
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.
Is an electronic logging device (ELD) required to monitor its compliance with the ELD technical requirements?
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.
When do electronic logging device (ELD) “power data diagnostic events” and “power compliance malfunctions” occur?
"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.
When do electronic logging device (ELD) “engine synchronization data diagnostic events” and “engine synchronization compliance malfunctions” occur?
"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.
When should a driver use paper logs or electronic logging software if an electronic logging device (ELD) malfunction occurs?
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).
When should a driver who has experienced an electronic logging device (ELD) malfunction switch to paper record of duty status (RODS)?
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.
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.
In the event of a malfunction that requires a driver to reconstruct his/her previous 7 days, can a driver use a printed copy of their previous 7 days, such as a PDF copy, instead of manually recording their previous 7 days?
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.
If an electronic logging device (ELD) malfunction corrects itself after the driver has reconstructed his or her record of duty status (RODS), must the driver present their reconstructed RODS during an inspection?
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.
Can Canada/Mexico-domiciled motor carrier’s drivers fax their hours of service records during a roadside inspection if an electronic logging device (ELD) malfunction prevents electronic transfer or display through the ELD screen or printout?
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.
If an electronic logging device (ELD) loses connection to the electronic control module (ECM) how will the device report a system failure?
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.
What is the responsibility of the carrier and driver pertaining to electronic logging device (ELD) diagnostic events or malfunctions that do not interfere with the accurate recording of hours of service? What would the documentation requirements be in those cases?
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.
Under section 188.8.131.52 of 49 CFR part 395, subpart B, Appendix A, the engine synchronization compliance monitoring requires the electronic logging device (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 commercial motor vehicle (CMV) power up cycle when the electronic control module (ECM) connection cannot become fully functional within 5 seconds of the engine receiving power?
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 184.108.40.206, 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 220.127.116.11 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.
How should an electronic logging device (ELD) respond to battery issues, such as an ELD battery dying due to high temperatures or when charge power runs out?
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.
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.
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.
When do electronic logging device (ELD) “data transfer data diagnostic events” and “data transfer compliance malfunctions” occur?
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.
When does an electronic logging device (ELD) “unidentified driving records data diagnostic event” occur?
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.