What Is An ELD?

ELD Background

Since 1938, hours of service (HOS) regulations have been enforced by the federal government. This refers to the maximum length of time that truckers are allowed to drive within a certain window of time without significant rest, as a safety measure to prevent sleepless driving. Up until the recent past, drivers were required to log their hours on paper or optionally via other forms of electronic systems.

Hours of service regulations have undergone several changes over time, but currently in the United States, truckers can drive up to 11 hours per day with a 10-hour reset, or a maximum of 10 hours with an 8-hour reset, in a 14-hour day or 70-hour 8-day week, or 60-hour 7-day week (the 60/70-hour week is then reset by a 34-hour off-duty period). In Canada, hours of service are 13 maximum hours of drive time with a 10-hour reset, and two of the 10 hours can be used as 30-minute breaks elsewhere during the day. Drivers who cross the border add two hours of driving when entering Canada and lose two hours when entering the United States.

As of December 18, 2017, the ELD (Electronic Logging Device, or E-log) mandate was rolled out, requiring all truck drivers to use an ELD in their truck at all times, with some exemptions not applicable to the typical Class-A hauler. The transition began in 2015, when the FMCSA (Federal Motor Carrier Safety Administration) published the ELD rule allowing for carriers to voluntarily implement use of ELDs. Devices implemented during that time and even earlier (AOBRDS- Automatic On-Board Recording Devices, which came about in 1988) are grandfathered as compliant until December 16, 2019, when all devices will have to be self-certified ELDs—in which the device manufacturers certify to the FMCSA that their ELD meets technical specifications and compliance, and is registered with the FMCSA.

View the FMCSA’s list of self-certified and registered ELDs

Demonstration Video: E-logs By Omnitracs

What does the certified ELD do that other logging methods don’t?

The reason that paper logs are out is that drivers could easily falsify them and keep running without sleep, putting themselves and other drivers on the road at greater risk of accidents and fatalities. The FMCSA also states that one purpose of ELDs is to prevent companies from harassing their drivers to run around the clock. The reason AOBRDs and other non-certified ELDs will no longer be accepted is that they lack consistency, can’t transfer data, and current ELDs cannot be falsified, as they show edits and annotations while retaining all original records. Also, uniformity of ELDs should allow for streamlining of roadside DOT inspections, so that inspectors don’t have to adapt to a wide array of different device capabilities.

How do ELDs work?

ELDs automatically record:

• Date
• Time
• Location within a one-mile radius
• Engine hours
• Vehicle miles
• Identification information for the driver, authenticated user, vehicle, and motor carrier

This is the information that they are required to capture, though they may have capability to record more for the carrier’s use. Each action is logged, from the pre-trip to post-trip, sleeper berth time, loading and unloading, fueling, off-duty time, and even adverse driving conditions. The ELD switches automatically into driving mode when the vehicle is moving faster than 5 mph, and if the vehicle is not moving for more than five minutes, the driver is prompted by the ELD to confirm driving status. If not manually responded to within one minute, it will switch to off-duty status. Edits and annotations can be entered for situations such as when a driver forgets to update the e-log’s status or makes a mistake. ELDs use GPS technology and are wired into the truck’s engine and computer, and can be installed by a mechanic who can install a car stereo.

Who is required to use ELDs?

All drivers who are required to keep RODS (records of duty status) logs, which is all truck drivers operating in interstate commerce at a gross vehicle or combination weight of 10,001 pounds or more and passenger transport, are required to use ELDs. This exempts those who use the Short Haul exemption with time cards, agricultural/farm trucks operating entirely within a 150-mile radius, and vehicles with an engine model year older than the year 2000. Consequences for violating E-log rules range from stiff fines and penalties for the carrier or individual, to being curbed or placed out of service and losing hours.

Video: Electronic Logbook Rules/Exemptions/Regulations (FMCSA) DOT Readiness Group

Frequently Asked Questions about ELDs

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

  For six months, a motor carrier must keep both the ELD RODS data, and a back-up copy of that data on a separate device. The carrier must ensure that these records are stored securely to protect driver privacy.

• What electronically transferred data from ELDs will be retained by the FMCSA and other authorized safety officials?

  FMCSA will not retain any ELD data unless there is a violation.

• If a driver is stopped for a roadside inspection after April 1, 2018 and does not have a required ELD or “grandfathered” AOBRD installed and in use in the vehicle being operated, what will happen?

  The inspector will cite the driver for failing to have the proper record of duty status, and will place the driver out of service (OOS) for 10 hours (8 hours for a passenger carrier), in accordance with the Commercial Vehicle Safety Alliance North American Standard Out-of-Service Criteria. At the end of the OOS period, the driver is allowed to complete the current trip to its final destination using paper logs. If the driver is stopped again prior to the final destination, the driver must provide the safety official a copy of the inspection report and evidence (e.g., bill of lading) proving he/she is continuing the original trip. After reaching the final destination, if the driver is dispatched without obtaining a compliant ELD, he/she will again be subject to the OOS procedures. However, a driver may return with an empty CMV to his/her principle place of business or home terminal , as indicated on the roadside inspection report. Violations count against the carrier’s Safety Measurement System (SMS) scores.

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

  Yes. Canada- and Mexico-domiciled drivers must comply with the Federal hours of service rules while operating in the United States. This includes using ELDs compliant with 49 CFR Part 395, unless they qualify for one of the exceptions. A driver operating in multiple jurisdictions will be able to annotate the driver’s record of duty status on the ELD with information on periods of operation outside the United States.

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

  An edit is a change to an electronic logging device (ELD) record that does not overwrite the original record, while an annotation is a note related to a record, update, or edit that a driver or authorized support personnel may input to the ELD. Section 49 CFR 395.30(c)(2) requires that all edits, whether made by a driver or the motor carrier, be annotated to document the reason for the change. For example, an edit showing time being switched from “off duty” to “on-duty not driving” could be annotated by the carrier to note, “Driver logged training time incorrectly as off duty.” This edit and annotation would then be sent to the driver for approval.

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

  Both the driver and authorized carrier staff can make limited edits to an ELD record to correct mistakes or add missing information. All edits must include a note (annotation) to explain the reason for the edit. In addition, the driver must confirm (certify) that any carrier edit is accurate, and resubmit the records. If the driver chooses not to re-certify RODs, this is also reflected in the ELD record. The ELD must keep the original, unedited record, along with the edits. Example: a carrier edits a record to switch a period of time from “off-duty” to “on-duty not driving”, with a note that explains “Driver logged training time incorrectly as off-duty”. The edit and annotation are sent to the driver to verify. The edit is not accepted until the driver confirms it and resubmits the RODS.

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

  Both the driver and authorized carrier staff can make limited edits to an ELD record to correct mistakes or add missing information. All edits must include a note (annotation) to explain the reason for the edit. In addition, the driver must confirm (certify) that any carrier edit is accurate, and resubmit the records. If the driver chooses not to re-certify RODs, this is also reflected in the ELD record. The ELD must keep the original, unedited record, along with the edits. Example: a carrier edits a record to switch a period of time from “off-duty” to “on-duty not driving”, with a note that explains “Driver logged training time incorrectly as off-duty”. The edit and annotation are sent to the driver to verify. The edit is not accepted until the driver confirms it and resubmits the RODS.

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

  In the event of team drivers, the ELD must display the data for both co-drivers who are logged into the system.

• Will the vehicle location information identify street addresses?

  No. Vehicle location information is not sufficiently precise to identify street addresses. For each change in duty status, the ELD must convert automatically captured vehicle position in latitude/longitude coordinates into geo-location information that indicates the approximate distance and direction to an identifiable location corresponding to the name of a nearby city, town, or village, with a State abbreviation.

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

  If an ELD malfunctions, a driver must:

  (1)Note the malfunction of the ELD and provide written notice of the malfunction to the motor carrier within 24 hours; (2) Reconstruct the record of duty status (RODS) for the current 24-hour period and the previous 7 consecutive days, and record the records of duty status on graph-grid paper logs that comply with 49 CFR 395.8, unless the driver already has the records or retrieves them from the ELD; and (3) Continue to manually prepare RODS in accordance with 49 CFR 395.8 until the ELD is serviced and back in compliance. The recording of the driver’s hours of service on a paper log cannot continue for more than 8 days after the malfunction; a driver that continues to record his or her hours of service on a paper log beyond 8 days risk being placed out of service.

See the FMCSA’s exhaustive ELD FAQs

Other resources and ELD guides from the FMCSA

Information for drivers

Enforcement specifics

Challenges and Controversy

In 2017, many truckers organized protests at courts and truck stops, and started a Twitter campaign aimed at President Trump, the ultimatum #ELDorMe, which intended to threaten a driver exodus in an industry already hurting for bodies. For some, ire over the ELD mandate continues now, while others are finding benefits in e-logs. Even for many in the latter camp who support e-logs, some issues remain to be worked out.

Disadvantages of E-logs

For those who are staunchly against e-logs, the prevailing argument is that it loses them money. Using paper logs, it is generally agreed that there was more wiggle room to reasonably accommodate scenarios that come up on a daily basis for drivers, whereas with e-logs, accounting of HOS is more absolute. Even law-abiding drivers have noticed some challenges with e-logs that can be disruptive to their workflow.

For example, the conscientious driver who aimed to follow HOS under paper logs might have been able to pass by one truck stop for their 8- or 10-hour reset if that truck stop was a little too full or in a sketchy area, and run slightly over just to get to the next one. Under e-logs, since your driving hours are recorded in an unforgivingly absolute way, you may have to stop in a less than desirable area, pack into a sardine tin of a truck stop, or even end your day slightly earlier than your allowable driving hours because the distance of the next truck stop would put you over your hours. Many drivers have commented on an increase in parking trouble at truck stops as a result of this. Another scenario that can occur is when a traffic jam puts a driver only slightly short of their customer, but since their clock runs out when their clock runs out and the record is unforgiving, they don’t have “wiggle room” to finish the comparably short distance to make it to the customer on that day, and might have to reschedule their drops.

Benefits of E-logs

Many drivers contend that if you can’t make money under e-logs, then you’re doing it wrong. Hours of Service regulations have not changed as part of the ELD mandate—only the way that time is accounted. Some drivers undoubtedly gamed the system under paper logs, falsifying records and running dangerous hours to take as many loads and miles as possible and make more money. Law-abiding drivers are quick to remind that camp that as long as they already run legally, the only change that e-logs present is to actually free up time that would have otherwise been spent manually doing paper logs.

Overall, while e-logs make it impossible to operate illegally, there is disagreement between truckers and federal regulators on what constitutes reasonable accommodation of extenuating circumstances. As this system is in its early stages and is still in a feedback period, and since ELDs come up at every interface between the government and the industry, the future almost certainly holds promise for change.