Electronic Logging Device (ELD) FAQs

Yes, with some exceptions. As of December 18, 2017, commercial motor vehicle to drivers who are subject to the federal hours-of-service rules and who are required to use standard logs to record their hours of service must use an ELD in place of paper logs in most cases. Exceptions exist for certain short-haul drivers, drivers of pre-2000 vehicles, drivers who must log less than 9 times in 30 days, and drivers engaged in certain types of driveaway-towaway operations. Drivers engaged in intrastate operations within certain states are also exempt.

There are numerous benefits to using electronic logs:

• First and foremost, ELDs can greatly simplify compliance by eliminating the need for paper logs. Drivers and carriers see significant time savings from going paperless.
• Some of the most common logging violations can be eliminated. Virtually all “form and manner” log violations go away, drivers always know where they stand on compliance, and drivers always have a current log. Alerts will tell driver when they are approaching an hours-of-service limit. As a result, carriers that use ELDs see 50-percent reduction in their roadside hours-of-service violations.
• Besides making compliance easier, ELDs make auditing easier and faster. The systems typically come with automated auditing built in.
• Roadside inspections can be easier and quicker.
• Scheduling and dispatch become easier because office personnel know the location of the vehicles and how much time drivers have available.
• Location, engine use, speed, and other data captured by the devices can prove valuable during litigation or other legal proceedings, potentially protecting both the driver and company.

These devices are not ELDs because they are not either directly or indirectly connected to the engine to automatically collect the required vehicle data (such as movement, engine hours, and speed data). Therefore, they cannot be used to satisfy the ELD mandate. These non-integrated devices are allowed for logging only if the driver has an exemption to use paper logs rather than an ELD. If the driver is using a non-integrated logging app or program, the driver must be able to produce a compliant paper (printed) log on demand.

The driver must be able to electronically transfer the records for the current day and the previous seven days to an inspector. The primary methods of doing so are either telematically through a web address or email, or locally through a USB 2.0 or Bluetooth® connection. The driver must also be able to display or print the current and previous seven days for the officer. If a display is used, the officer must be able to view it outside of the vehicle. The officer will also ask the driver to present the device’s user manual, data transfer instructions, malfunction instructions, and eight blank paper logs.

In addition, the driver must provide the inspector with any supporting documents that he or she possesses, upon request.

Drivers who are using an ELD only have to print their logs if the device does not have a display that the officer can view from outside of the vehicle.

If an ELD malfunctions (is no longer functioning as a compliant recorder), the driver must:

• Note the failure of the device;
• Reconstruct paper logs for the current day and the previous 7 days, less any days for which the driver has records or that the device can still display;
• Continue to prepare a handwritten log until the device is working again; and
• Notify the carrier in writing within 24 hours of the failure.

Once notified, the carrier has eight days to repair or replace the device. If it cannot be repaired or replaced within eight days, the carrier can ask its local FMCSA office for an extension.

Ensure your drivers understand the regulations surrounding ELD failure and other mandate requirements with ELD and hours of service training.

Yes, records from Global Positioning Systems (GPS) associated with fleet management, communication, and tracking systems may be subject to audit by the FMCSA (whether those systems are a part of an ELD system or not). Such records are considered "supporting documents" for hours-of-service compliance, and must be maintained by the motor carrier for six months. The FMCSA may use GPS records to verify the information contained on drivers' logs, even if the company does not do so.

A driver using an ELD must also carry:

• A user's manual for operating the device;
• An instruction sheet with step-by-steps instructions for transferring hours-of-service records to an authorized safety official;
• An instruction sheet on reporting ELD malfunctions and recordkeeping procedures during malfunctions; and
• At least eight blank paper grid-graph logs to record driver duty status and related information, in case of ELD malfunction.