Help Your Customers
Enter the Output File
Comment

What is the “output file comment”?

Per 49 CFR § 395.24, there are several data elements that drivers are responsible for entering in the ELD. One of these is referred to as the “output file comment.” The rule indicates that the driver will receive direction from the safety official regarding the specific comment that must be entered (see § 395.24(c)(iii)).

In the technical specifications (appendix), this output file comment is explained in section 4.3.2.5:

An ELD must accommodate the entry of an output file comment up to 60 characters long. If an authorized safety official provides a key phrase or code during an inspection to be included in the output file comment, it must be entered and embedded in the electronic ELD records in the exchanged dataset as specified in section 4.8.2.1.1 of this appendix. The default value for the output file comment must be blank. This output file comment must be used only for the creation of the related data files for the intended time, place, and ELD user.

How does FMCSA use the output file comment?

For data transfers via a telematics method or Bluetooth®, the output file comment allows FMCSA to track which safety official requested the ELD output file. It also allows the Agency to tie files to a specific inspector or investigation. In communications with safety officials, FMCSA refers to this as the “safety official code” or “ELD investigation code.” A safety official may use that code, input as an output file comment, to locate the specific ELD file they need to review, either during a roadside inspection or an investigation.

This safety official/investigation code is an important feature for FMCSA enforcement personnel. If a driver or motor carrier fails to include this code upon request of the safety official, they should be cited.

How can you help your customers?

You can help your customers avoid being cited by making the feature in your ELD to enter this code easy to locate and use. You may consider the following recommendations:

• Labeling the field for this output file comment as “Safety Official/Investigation Code” or similar, making it easier for users to understand where to enter it.
• Adding a confirmation screen if a driver or motor carrier attempts to transfer an ELD output file via a telematics method or Bluetooth® without entering the code in this field.
• Ensuring instructions for using this feature are covered in your device manual.

If you have any questions about the output file comment, or any of the other requirements in the technical specifications of the ELD rule, don’t hesitate to contact the ELD Technical Team at ELDTech@dot.gov.