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Frequently Asked Questions (FAQs) - ELD Rule

NOTE: The ELD FAQs are intended to provide plain language information regarding the ELD rule. They do not modify or replace applicable Federal Motor Carrier Safety Administration (FMCSA) regulations or substantive standards.

NOTE 2: For the purposes of this Rule, the term “electronic onboard recorders” or EOBRs is not used due to a change of terminology following MAP-21.

ABOUT ELDS

Why doesn’t the ELD rule use the term “electronic onboard recorders” (EOBRs)?

What is an electronic logging device (ELD)?

How is an ELD different than an AOBRD (Automatic On Board Recording Device)?

What are the benefits of electronic logging devices (ELDs)?

Can a driver use a portable electronic logging device (ELD)?

Can an electronic logging device (ELD) be comprised of a smart phone or other wireless device?

ELD Technical Specifications

Why are technical specifications in the electronic logging device (ELD) rule?

Is an electronic logging device (ELD) required to collect data about vehicle performance?

Do the specifications in the ELD rule include requirements to automatically control the vehicle, such as other safety systems that may automatically reduce acceleration or apply braking?

What is the level of precision for commercial motor vehicle (CMV) location information recorded by an electronic logging device (ELD)?

What does engine synchronization mean for the purposes of electronic logging device (ELD) compliance?

Will GPS-derived data for mileage be allowed as a substitute for data that cannot be readily obtained from a vehicle electronic control module (ECM)?

Why must an electronic logging device (ELD) collect engine hour data?

Can an electronic logging device (ELD) have a feature to warn drivers about approaching hours-of-service (HOS) limits?

ELD Registration and Certification

Who is responsible for certifying and registering electronic logging devices (ELDs)?

Why must electronic logging devices be certified and registered?

When will electronic logging device (ELD) system manufacturers be able to start certifying and registering their ELDs with FMCSA?

ABOUT THE ELD RULE

What does the Electronic Logging Device (ELD) rule address?

Does the electronic logging device (ELD) rule require real-time tracking of commercial motor vehicle (CMVs) with ELDs?

COMPLIANCE

Who Must Comply

Who must use an electronic logging device (ELD)?

Does the electronic logging device (ELD) rule also apply to buses?

Are Canada- and Mexico-domiciled drivers required to use electronic logging devices (ELDs) when they are operating in the United States?

Exceptions to the ELD Rule

What exceptions are allowed by the electronic logging device (ELD) rule?

Is there an exception to the requirement to use electronic logging devices (ELDs) for drivers who infrequently use records of duty status (RODS)?

Can drivers operate commercial motor vehicles (CMVs) equipped with electronic logging devices (ELDs), if they are not required to use them due to an exception?

Compliance Schedule/Deadlines

How soon can electronic logging devices (ELDs) be installed and used – and when must they be used in commercial motor vehicles (CMVs)?

What is a “grandfathered” automatic onboard recording device (AOBRD)?

REQUIRED DOCUMENTATION

ELD User Documentation

What electronic logging device (ELD) user documentation must be onboard a driver’s commercial motor vehicle?

Supporting Documents

When are motor carriers and drivers required to comply with the supporting document requirements?

How many supporting documents must be retained by motor carriers, and when must drivers submit them to the motor carrier?

What are the categories of supporting documents?

What information should be in the supporting documents?

Can a document with fewer than four elements (name/ID, date, location, time) be used as a supporting document?

Can supporting documents be limited to only those acquired at the beginning and end of the workday?

Can drivers provide supporting documents electronically?

What supporting documents must be retained by drivers in their vehicles?

What supporting documents should be retained by a motor carrier if a driver submits more than eight documents to the motor carrier for a single day?

How long must motor carriers retain records of duty status (RODS) and supporting documents?

USING ELDS

Creating Accounts

What electronic logging device (ELD) user accounts must be set up by a motor carrier?

Can a motor carrier create electronic logging device (ELD) accounts on individual ELDs or its support system?

What information is required to create electronic logging device (ELD) user accounts for drivers?

How many electronic logging device (ELD) accounts can be established by a motor carrier for one of its ELD drivers?

Can a driver’s electronic logging device (ELD) user single account be authorized for administrative functions, in addition to its driver-related functions?

Logging In

Under what circumstances can an electronic logging device (ELD) username be edited or reassigned?

What must a driver do with unassigned driving time when he or she logs into the electronic logging device (ELD)?

What must a motor carrier do with unassigned driving records from an electronic logging device (ELD)?

Recording Time & Other Data

Can an electronic logging device (ELD) record be set to record minimum duty status durations, such as 15 minutes?

What information is automatically recorded by an electronic logging device (ELD)?

When will an electronic logging device (ELD) automatically start to record a driving mode or status?

When will an electronic logging device (ELD) automatically change the duty status from driving to the default duty status of on-duty not driving?

When is location data recorded by an electronic logging device (ELD)?

Will an electronic logging device (ELD) record data if there has not been a duty status change?

Will the vehicle location information identify street addresses?

How does a driver use an electronic logging device (ELD) to designate special driving categories?

If a driver is permitted to use a Commercial Motor Vehicle (CMV) for personal reasons, how must the driving time be recorded?

What does the electronic logging device (ELD) record when the personal conveyance status is selected and the commercial motor vehicle (CMV) is driven?

Does the electronic logging device (ELD) automatically switch to an off-duty status at the end of a personal conveyance status?

Can a logged-in co-driver make entries over his or her records using the electronic logging device (ELD) when he or she is not driving?

ELD Edits and Annotations

Who can edit an electronic logging device (ELD) record?

Can a user edit or change driving time that has been recorded by an electronic logging device (ELD) to non-driving time?

Are drivers allowed to edit their records of duty status (RODS) using the electronic logging device (ELD) back office support systems once they leave the commercial motor vehicle (CMV)?

What is the difference between an “edit” and an “annotation”?

Can a driver annotate the electronic logging device (ELD) record?

How can a driver reduce the number of edits and annotations?

Who is responsible for the integrity of records of duty status in regards to the editing and certification rights of drivers and motor carriers?

Retaining Records

Are the original electronic logging device (ELD) records retained after edits are made to them and available for drivers to access them?

How long must a motor carrier retain electronic logging device (ELD) record of duty status (RODS) data?

What electronically transferred data from electronic logging devices (ELDs) will be retained by FMCSA and other authorized safety officials?

Accessing and Transmitting Data

How can drivers access their records of duty status (RODS) from an electronic logging device (ELD)?

What are the display requirements for team drivers using the same electronic logging device (ELD) on their commercial motor vehicle (CMV)?

What procedure should be followed if multiple, compatible electronic logging devices (ELDs) are used to record a driver’s record of duty status (RODS) within a motor carrier’s operation?

How should a driver account for hours-of-service generated on multiple devices, when the data from one or more devices cannot be transferred?

What procedure should be followed if an electronic logging device (ELD) is replaced or reset?

ELD Data Transfer

What are the options for electronic logging devices (ELDs) to electronically transfer data?

What is the process for transferring data via USB2.0?

What is the process for transferring data via Bluetooth?

What is the process for transferring data via email?

What is the process for transferring data via web services?

Would a motor carrier be non-compliant with the ELD rule if the data cannot be sent electronically to an authorized safety official at roadside?

ELD Malfunctions and Data Diagnostic Events

Is an ELD required to monitor its compliance with the ELD technical requirements?

What types of visual malfunction and diagnostic indicators must be displayed by an ELD?

What must a driver do if there is an electronic logging device (ELD) malfunction?

What must a motor carrier do if there is an electronic logging device (ELD) malfunction?

DRIVER HARASSMENT

What is the definition of harassment in the Electronic Logging Device (ELD) rule?

How does the Electronic Logging Device (ELD) rule address harassment of drivers using ELDs?

What are the differences between harassment and coercion?

Where should a driver file a harassment complaint?

What information must be submitted in a harassment complaint?

How much time is allowed for a driver to file a harassment complaint?

What should a driver consider before filing a harassment complaint?

ENFORCEMENT

How can states impose supporting document standards that are different than the Federal standard in the electronic logging device (ELD) rule?

What will be the enforcement procedures for registered electronic logging devices (ELDs) installed and used in commercial motor vehicles (CMVs) prior to the compliance date of the ELD rule?

Will drivers be allowed to continue to use AOBRDs following the compliance date for the ELD rule?

How are drivers and carriers expected to comply with the regulations for electronic logging devices (ELDs) and automatic onboard recording devices (AOBRDs) during the two-year period following the compliance date of the ELD rule?

How will safety officials receive data electronically from the two different types of ELDs with options for different methods of electronic data transfer (“telematics” and “local”)?

Last updated: Thursday, October 29th, 2015