New ELD Technical Specification FAQs

The following frequently asked questions have been added to the FMCSA website.

1. When a driver edits an existing ELD record, how must the ELD “Event Record Origin” be set?

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

2. When a driver manually enters records into an ELD how must the ELD “Event Record Origin” be set?

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

3. May a user edit or correct driving time that has been erroneously recorded by an ELD because the driver failed to change their duty status before powering off the CMV?

   Yes, 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.

4. What is the responsibility of the carrier and driver pertaining to 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 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.

5. Under 4.6.1.2 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 4.3.1.1, 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, 4.5.1.6 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.

   Read these and more ELD frequently asked questions at https://www.fmcsa.dot.gov/hours-service/elds/faqs.