Electronic Logging Device (ELD) FAQs
What is AOBRD? What is EOBR? What is ELD? What is ELog?
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.
Electronic on-board recorders (EOBRs) were the devices that were originally intended to replace AOBRDs, but the rulemaking to do so was never finalized.
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 Federal Motor Carrier Safety Administration's (FMCSA) ELD registration site. As of December 18, 2017, with very few exceptions, only ELD devices listed on FMCSA's ELD registry can be placed into service.
References to E-Logs or ELogs are generic references to AOBRDs or ELDs.
Is electronic logging required?
The FMCSA published an 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 AOBRDs by interstate drivers of commercial motor vehicles who currently use a driver’s record of duty status (log) to record their hours of service. AOBRDs that were placed into service before December 18, 2017, need to be upgraded to the ELD technical specifications before December 16, 2019.
My drivers do their logs on laptops and smartphones. Are those considered ELogs?
These devices are not AOBRDs, EOBRs, or ELDs unless they are directly or indirectly connected to the engine to automatically collect the required vehicle data (such as movement and speed data). These non-integrated devices are allowed for logging ONLY if the driver is allowed 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 have to do at a roadside inspection?
The ELD mandate requires drivers to electronically transfer the records for the last 7 days and the current day 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 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 must only 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 definitely within 48 hours. The officer will also ask the driver to present the display instructions 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 ELogs (AOBRDs or ELDs) ever have to print out logs for an inspector?
Drivers that are using an AOBRD never need to print logs as long as the device meets the requirements found in §395.15.
Drivers that are using ELDs may need to print their logs if the driver cannot provide the logs to a roadside inspector via one of the transfer methods and the device does not have a display the officer can view outside of the vehicle. As long as the ELD device has a display that can be "brought to the officer," printing is not required.
What benefits come with use of electronic logs?
There are numerous benefits to using electronic logs:
- First and foremost, electronic 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.
- 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.
What happens if an AOBRD stops working?
If an AOBRD fails, the driver must:
- Note the failure of the device;
- Reconstruct his/her logs for the current day and the previous 7 days, less any days for which the driver has records; and
- Continue to prepare a handwritten log until the device is working again.
What happens if an ELD stops working?
If an ELD fails, the driver must:
- Note the failure of the device;
- Reconstruct his/her logs for the current day and the previous 7 days, less any days for which the driver has records;
- 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 ELD;
- 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 ELD malfunctions; and
- A supply of paper grid graphs to record driver duty status and related information for at least 8 days, 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
- A supply of paper grid graphs to record driver duty status and related information for the remainder of the driver's present trip, in case of AOBRD malfunction.
What is the definition of harassment in the ELD mandate?
Harassment is an action taken based on information from an ELD or other technology used in combination with an ELD, that the carrier knew (or should have known) would result in a driver violating the Hours of Service (HOS) rules or a situation where the driver is operating while ill or fatigued.