Electronic Logging Device (ELD) FAQs
What is AOBRD?
The term "AOBRD," or "Automatic On-board Recording Device," has been defined since the 1980s as "an electric, electronic, electromechanical, or mechanical device capable of recording driver's duty status information accurately and automatically as required by §395.15. The device must be integrally synchronized with specific operations of the commercial motor vehicle in which it is installed. At a minimum, the device must record engine use, road speed, miles driven, the date, and time of day."
Many of the devices installed prior to December 18, 2017, were AOBRDs. With very few exceptions, AOBRD can no longer be placed into initial service. However, any AOBRD installed and in use before December 18, 2017, can be used as an AOBRD until December 16, 2019. At that time, any remaining AOBRDs will need to be updated to meet the ELD technical specifications.
What is EOBR?
Electronic on-board recorders (EOBRs) were the devices that were originally intended to replace AOBRDs, but the rulemaking to do so was never finalized.
What is ELD?
An electronic logging device (ELD) is the most recent electronic device. Much like AOBRDs, ELDs are capable of recording a driver's driving hours and duty status automatically. However, to be considered an ELD the device must meet specific technology requirements and be listed on the FMCSA ELD registration site. As of December 18, 2017, with very few exceptions, only ELD devices listed on FMCSA's registry can be placed into service.
What is ELog?
E-Logs or ELogs is a generic term used to reference AOBRDs and ELDs.
Is electronic logging required?
The FMCSA published the ELD mandate in the December 16, 2015, Federal Register. Motor carriers had until December 18, 2017, to comply with the ELD mandate, which requires the use of ELDs or grandfathered AOBRDs by most interstate drivers of commercial motor vehicles to record their hours of service. Grandfathered AOBRDs are automatic on-board recording devices that were placed into service before December 18, 2017. These will need to be upgraded to the ELD technical specifications before December 16, 2019.
What benefits come with use of electronic logs?
There are numerous benefits to using electronic logs:
- First and foremost, e-logs 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 AOBRDs and ELDs will see 50 percent fewer hours-of-service roadside inspection violations.
- Besides making compliance easier, electronic logs 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.
Can a carrier install new AOBRDs after 12/18/17?
Generally, devices placed into service after December 18, 2017, need to be ELDs. However, there are some exceptions, including:
- A carrier that had AOBRDs installed and in use prior to December 18, 2017, can install ELD-capable devices operating as AOBRDs until December 16, 2019. As of that date, the devices will need to be switched to ELDs and all new devices entering service must be electronic logging devices operating as ELDs.
- A carrier can move a grandfathered AOBRD (one that was in service prior to December 18, 2017) that was in use in one vehicle into another vehicle.
- A carrier can install a new AOBRD if it is replacing a grandfathered AOBRD that failed while under warranty.
My drivers do their logs on laptops and smartphones. Are those considered a compliant ELog?
These devices are not AOBRDs or ELDs because they are not either directly or indirectly connected to the engine to automatically collect the required vehicle data (such as movement and speed data). Therefore, they cannot be used to satisfy the ELD mandate requirements. These non-integrated devices are allowed for logging only if the driver has an exemption to use paper logs rather than an AOBRD or 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.
What does a driver using an ELD or an AOBRD have to do at a roadside inspection?
First and foremost, the driver needs to identify to the officer what type of electronic log is being used (an ELD or an AOBRD). If the driver misidentifies the device to the officer (such as refers to his/her AOBRD as an ELD), the officer may end up citing the driver when the device cannot do what is required.
If the driver is using an ELD, 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 an email account, or locally through a USB 2.0 or a 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.
Drivers using an AOBRD are only required to be able to show the officer the device display during a roadside inspection. If the officer wants a "hard copy" of the records, the officer is to request them from the driver or carrier. The carrier then must provide them to the officer as soon as possible, but in all cases within 48 hours. The officer will also ask the driver to present instructions explaining how to display the records and enough blank logs to complete the current trip.
In addition, the driver must provide any supporting documents that he or she has in possession to the inspector upon request.
Do drivers using AOBRDs or ELDs ever have to print out logs for an inspector?
Drivers that are using an AOBRD do not need to print logs, as long as the device display meets the requirements found in §395.15(i)(5). If the device cannot display the required information, then the device must be capable of printing the records for the officer.
If the driver is using an ELD, the only time printing is required is if the device cannot provide the records to a roadside inspector via one of the transfer methods due to connectivity issues and the device does not have a display the officer can view outside of the vehicle.
Do AOBRDs have to be able to transfer the driver’s records directly to an inspector?
No. The requirement that the device must be able to transfer records directly to an officer during a roadside inspection is unique to ELDs. If the driver is using an AOBRD, and the officer wants a “hard copy” of the records, the driver or carrier must provide it to the officer as soon as possible, but in all cases within 48 hours, using any communications medium (email, fax, regular mail, etc.). If a carrier receives a violation for an AOBRD not being able to transfer the records to the officer during a roadside inspection, the carrier should file a request for review (challenge) using the DataQs system.
What happens if an AOBRD or ELD stops working?
If an AOBRD or 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.
Ensure your drivers understand the regulations surrounding ELD failure and other mandate requirements with ELD and hours of service training.
Can the FMCSA request our GPS records during an audit?
Yes, records from Global Positioning Systems (GPS) may be subject to audit by the FMCSA (whether those systems are a part of an e-log 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.
What has to be carried on the vehicle in addition to the ELD itself?
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.
A driver using an AOBRD must also carry:
- An instruction sheet with step-by-steps instructions for displaying the hours-of-service records to an authorized safety official; and
- Enough blank paper grid graph logs to complete the current trip to record driver duty status and related information, in case of AOBRD malfunction.