FMCSA ELD Requirements

Contents:

• 4. FUNCTIONAL REQUIREMENTS
  • 4.1 ELD User Accounts
    • 4.1.1 Account Types
    • 4.1.2 Account Creation
    • 4.1.3 Account Security
    • 4.1.4 Account Management
    • 4.1.5 Non-Authenticated Operation
  • 4.2 ELD-Vehicle Interface
  • 4.3 ELD Inputs
    • 4.3.1 ELD Sensing
    • 4.3.2 Driver’s Manual Entries
    • 4.3.3 Motor Carrier’s Manual Entries
  • 4.4 ELD Processing and Calculations
    • 4.4.1 Conditions for Automatic Setting of Duty Status
    • 4.4.2 Geo-Location Conversions
    • 4.4.3 Date and Time Conversions
    • 4.4.4 Setting of Event Parameters in Records, Edits, and Entries
    • 4.4.5 Data Integrity Check Functions
  • 4.5 ELD Recording
    • 4.5.1 Events and Data to Record
  • 4.6 ELD’s Self-Monitoring of Required Functions
    • Table 4 Standard Coding for Required Compliance Malfunction and Data Diagnostic Event Detection
    • 4.6.1 Compliance Self-Monitoring, Malfunctions and Data Diagnostic Events
    • 4.6.2 ELD Malfunction Status Indicator
    • 4.6.3 ELD Data Diagnostic Status Indicator
  • 4.7 Special Purpose ELD Functions
    • 4.7.1 Driver’s ELD Volume Control
    • 4.7.2 Driver’s Access to Own ELD Records
    • 4.7.3 Privacy Preserving Provision for Use During Personal Uses of a CMV
  • 4.8 Printout or Display
    • 4.8.2 ELD Data File
  • 4.9 Data Transfer Capability Requirements
    • 4.9.1 Data Transfer During Roadside Safety Inspections
    • 4.9.2 Motor Carrier Data Reporting
  • 4.10 Communications Standards for the Transmittal of Data Files
    • 4.10.1 Data Transfer Mechanisms
    • 4.10.2 Motor Carrier Data Transmission
• 5. ELD REGISTRATION AND CERTIFICATION
  • 5.1. ELD Provider’s Registration
    • 5.1.1. Registering Online
    • 5.1.2 Keeping Information Current
    • 5.1.3 Authentication Information Distribution
  • 5.2 Certification of Conformity with FMCSA Standards
    • 5.2.1 Online Certification
    • 5.2.2 Procedure to Validate an ELD’s Authenticity
  • 5.3 Publicly Available Information
  • 5.4 Removal of Listed Certification
    • 5.4.1 Removal Process
    • 5.4.2 Notice
    • 5.4.3 Response
    • 5.4.4 Agency Action
  • 5.4.5 Administrative Review
• 6. REFERENCES
• 7. DATA ELEMENTS DICTIONARY
  • 7.1 24-Hour Period Starting Time
  • 7.2 Carrier Name
  • 7.3 Carrier’s USDOT Number
  • 7.4 CMV Power Unit Number
  • 7.5 CMV VIN
  • 7.6 Comment/Annotation
  • 7.7 Data Diagnostic Event Indicator Status
  • 7.8 Date
  • 7.9 Distance Since Last Valid Coordinates
  • 7.10 Driver’s License Issuing State
    • Table 5 - State and Province Abbreviation Codes
    • AMERICAN POSSESSIONS OR PROTECTORATES
    • CANADA
    • MEXICO
    • OTHER
  • 7.11 Driver’s License Number
  • 7.12 Driver’s Location Description
  • 7.13 ELD Account Type
  • 7.14 ELD Authentication Value
  • 7.15 ELD Identifier
  • 7.16 ELD Provider
  • 7.17 ELD Registration ID
  • 7.18 ELD Username
  • 7.19 Engine Hours
  • 7.20 Event Code
    • Table 6 - “Event Type” Parameter Coding
  • 7.21 Event Data Check Value
  • 7.22 Event Record Origin
    • Table 7 - “Event Record Origin” Parameter Coding
  • 7.23 Event Record Status
    • Table 8 - “Event Record Status” Parameter Coding
  • 7.24 Event Sequence ID Number
  • 7.25 Event Type
    • Table 9 - “Event Type” Parameter Coding
  • 7.26 Exempt Driver Configuration
  • 7.27 File Data Check Value
  • 7.28 First Name
  • 7.29 Geo-Location
    • Table 10 - Conventional Compass Rose Direction Coding To Be Used in the Geo-Location Parameter.
  • 7.30 Last Name
  • 7.31 Latitude
  • 7.32 Line Data Check Value
  • 7.33 Longitude
  • 7.34 Malfunction/Diagnostic Code
  • 7.35 Malfunction Indicator Status
  • 7.36 Multiday Basis Used
  • 7.37 Order Number
  • 7.38 Output File Comment
  • 7.39 Shipping Document Number
  • 7.40 Time
  • 7.41 Time Zone Offset from UTC
  • 7.42 Trailer Number(s)
  • 7.43 Vehicle Miles
• General FAQ’s - 2017 DECEMBER
  • General Information about the ELD Rule
    • 1. What are the key requirements of the Electronic Logging Device (ELD) rule?
    • 2. What is the mandate in the Moving Ahead for Progress in the 21st Century Act (MAP-21) for the Electronic Logging Device (ELD) rule?
    • 3. Who must comply with the electronic logging device (ELD) rule?
    • 4. What electronic logging device (ELD) user documentation must be onboard a driver’s commercial motor vehicle?
    • 5. Can the ELD information packet be in electronic form?
    • 6. Can an electronic logging device (ELD) be on a smartphone or other wireless device?
    • 7. Can a driver use a portable electronic logging device (ELD)?
    • 8. How long must a motor carrier retain electronic logging device (ELD) record of duty status (RODS) data?
    • 9. What electronically transferred data from electronic logging devices (ELDs) will be retained by Federal Motor Carrier Safety Administration (FMCSA) and other authorized safety officials?
    • 10 . What is the carrier’s responsibility in ensuring that they are using a registered device?
    • 11 . How will the ELD display screen or printout reflect special driving categories; yard moves and personal conveyance?
    • 13 . How are motor carriers required to present records of duty status (RODS) from December 11-17, 2017? Will drivers be required to present their records of duty status on electronic logging devices (ELDs)?
    • 15 . How must a driver who is starting to work for a new motor carrier present their prior 7 days’ records of duty status to the new carrier?
  • Electronic Logging Device Exemptions
    • 1. Who is exempt from the ELD rule?
    • 2. What time periods can be used to determine the 8 days in any 30-day period?
    • 3. What information may be requested to support the exemption for drivers not required to use records of duty status (RODS) more than 8 days in any 30-day period?
    • 4. If the vehicle registration for a commercial motor vehicle reflect a model year of 2000 or newer, but the engine plate or documentation from the manufacturer indicates that the engine is older than model year 2000, is the vehicle exempt from the ELD rule?
    • 5. If a motor carrier’s operation is exempt from the requirements of 49 CFR Part 395.8, is the motor carrier also exempt from the ELD rule?
    • 6. Are Canada- and Mexico-domiciled drivers required to use electronic logging devices (ELDs) when they are operating in the United States?
    • 7. How should an ELD record a driver’s hours of service when operating in another country such as Canada?
    • 8. 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?
    • 9. Are motor carriers that meet the agricultural exemption defined in 395.1(k) or the covered farm vehicle 395.1(s) subject to the ELD rule?
    • 10 . Can a driver use an ELD on a commercial motor vehicle with a model year older than 2000?
    • 11 . Are transporters of mobile or modular homes considered Driveaway/Towaway operations under Section 395.8 (a)(1)(iii)(A)(2) or (3) and therefore exempt from the ELD rule?
  • Voluntary Usage and Compliance Phases
    • 1. How soon can electronic logging devices (ELDs) be installed and used in commercial motor vehicles (CMVs)?
    • 2. What are 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?
    • 3. What are the options for carriers and drivers to complete records of duty status (RODS) prior to the Electronic Logging Device (ELD) rule compliance date?
    • 4. What is a “grandfathered” automatic onboard recording device (AOBRD)?
    • 5. When are drivers subject to the ELD rule required to start using electronic logging devices (ELDs)?
    • 6. What will be the enforcement procedures for “grandfathered” automatic onboard recording devices (AOBRDs) and electronic logging devices (ELD) during the two-year period following the compliance date of the ELD rule?
    • 7. According to § 395.8, if a motor carrier “installs and requires a driver to use an AOBRD…before December 18, 2017 they may continue to use the AOBRD until December 16, 2019.” Does this mean I can move an AOBRD from one vehicle to another after December 18, 2017?
  • Supporting Documents
    • 1. When are motor carriers and drivers required to comply with the supporting document requirements?
    • 2. How many supporting documents must be retained by motor carriers, and when must drivers submit them to the motor carrier?
    • 3. How long must motor carriers retain records of duty status (RODS) and supporting documents?
    • 4. What are the categories of supporting documents?
    • 5. Are there specific categories of supporting documents that drivers can provide electronically?
    • 6. Can supporting documents be limited to only those acquired at the beginning and end of the workday?
    • 7. What information should be in the supporting documents?
    • 8. Can a document with fewer than four required elements be used as a supporting document?
    • 9. What supporting documents should a motor carrier retain if a driver submits more than eight documents for a 24-hour period?
    • 10 . Are drivers required to show supporting documents during roadside inspections?
  • Editing and Annotations
    • 1. What is the difference between “paper records of duty status (RODS)” and printouts of RODS from electronic logging devices (ELDs)?
    • 2. What is the difference between an “edit” and an “annotation”?
    • 3. Can a driver annotate the electronic logging device (ELD) record?
    • 4. Who can edit an electronic logging device (ELD) record?
    • 5. Who is responsible for the integrity of records of duty status in regards to the editing and certification rights of drivers and motor carriers?
    • 6. Are the original electronic logging device (ELD) records retained after edits are made, and accessible to drivers?
    • 7. Can a user edit or change driving time that has been recorded by an electronic logging device (ELD) to non-driving time?
    • 8. How can a driver record their on-duty not driving status, such as working in a warehouse, on an ELD, prior to operating a commercial motor vehicle equipped with an ELD?
    • 9. 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)?
    • 10. 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?
    • 11. What procedure should be followed if multiple, incompatible electronic logging devices (ELDs) are used to record a driver’s record of duty status (RODS)?
    • 12 . What procedure should be followed if an electronic logging device (ELD) is replaced or reset?
    • 13 . When a motor carrier discovers a driver in a team driving operation failed to log in and his or her activities were assigned to the co-driver, can the motor carrier reassign the generated data?
    • 14 . What must a driver do with unassigned driving time when he or she logs into the electronic logging device (ELD)?
    • 15 . What must a motor carrier do with unassigned driving records from an electronic logging device (ELD)?
    • 16 . If a driver is permitted to use a Commercial Motor Vehicle (CMV) for personal reasons, how must the driving time be recorded?
  • Harassment
    • 1. What is the definition of harassment in the Electronic Logging Device (ELD) rule?
    • 2. How does the Electronic Logging Device (ELD) rule address harassment of drivers using ELDs?
    • 3. Does the Electronic Logging Device (ELD) rule require real-time tracking of commercial motor vehicle (CMVs) with ELDs?
    • 4. What are the differences between harassment and coercion?
    • 5. What should a driver consider before filing a harassment complaint?
    • 6. How much time is allowed for a driver to file a harassment complaint?
    • 7. Where should a driver file a harassment complaint?
    • 8. What information must be submitted in a harassment complaint?
    • 4. Driver’s signature.
  • ELD Functions
    • 1. What information is automatically recorded by an electronic logging device (ELD)?
    • 2. When is location data recorded by an electronic logging device (ELD)?
    • 3. Will the vehicle location information identify street addresses?
    • 4. Is an electronic logging device (ELD) required to collect data about vehicle performance?
    • 6. What is the level of accuracy for commercial motor vehicle (CMV) location information recorded by an electronic logging device (ELD)?
    • 7. What does engine synchronization mean for the purposes of electronic logging device (ELD) compliance?
    • 8. 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)?
    • 9. Can an electronic logging device (ELD) have a feature to warn drivers about approaching hours of service (HOS) limits?
    • 10 . When will an electronic logging device (ELD) automatically start to record a driving mode or status?
    • 11 . When will an electronic logging device (ELD) automatically change the duty status from driving to the default duty status of on-duty not driving?
    • 12 . How must a driver be able to access records of duty status (RODS) from an electronic logging device (ELD)?
    • 13 . How does the electronic logging device reflect personal conveyance when the personal conveyance status is selected and the commercial motor vehicle (CMV) is driven?
    • 15 . 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?
    • 16 . Can an electronic logging device (ELD) record be set to record minimum duty status durations, such as 15 minutes?
    • 17 . As a motor carrier, how can I be sure an electronic logging device (ELD) is compliant?
    • 18 . May an ELD device be used to track mileage for tax reporting purposes?
  • ELD Data Transfer
    • 1. What are the options for electronic logging devices (ELDs) to electronically transfer data?
    • 2. 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”)?
    • 3. What is the process for transferring data via USB2.0?
    • 4. What is the process for transferring data via email?
    • 5. What is the process for transferring data via Bluetooth?
    • 6. What is the process for transferring data via web services?
    • 7. Would an electronic logging device (ELD) 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
    • 1. Is an ELD required to monitor its compliance with the ELD technical requirements?
    • 3. When do electronic logging device (ELD) “engine synchronization data diagnostic events” and “engine synchronization compliance malfunctions” occur?
    • 4. When does an electronic logging device (ELD) “timing compliance malfunction” occur?
    • 5. When does an electronic logging device (ELD) “positioning compliance malfunction” occur?
    • 6. When does an electronic logging device (ELD) “data recording compliance malfunction” occur?
    • 7. When does an electronic logging device (ELD) “missing required data elements data diagnostic event” occur?
    • 8. When do electronic logging device (ELD) “data transfer data diagnostic events” and “data transfer compliance malfunctions” occur?
    • 9. When does an electronic logging device (ELD) “unidentified driving records data diagnostic event” occur?
    • 10 . What must a driver do if there is an electronic logging device (ELD) malfunction?
    • 11 . What must a motor carrier do if there is an electronic logging device (ELD) malfunction?
    • 12 . When should a driver certify his or her record of duty status (RODS) on the electronic logging device (ELD) to avoid malfunction codes?
    • 13 . What types of visual indicators must be displayed by an ELD?
    • 14 . In the event of a malfunction that requires a driver to reconstruct his/her previous 7 days, can a driver use a printed copy of their previous 7 days, such as a PDF copy, instead of manually recording their previous 7 days?
    • 15 . If an ELD malfunction corrects itself after the driver has reconstructed his or her records of duty status, must the driver present their reconstructed records of duty status during an inspection?
  • ELD Accounts
    • 1. What electronic logging device (ELD) user accounts must be set up by a motor carrier?
    • 2. Can a motor carrier create electronic logging device (ELD) accounts on individual ELDs or its support system?
    • 3. What information is required to create electronic logging device (ELD) user accounts for drivers?
    • 4. How many electronic logging device (ELD) accounts can be established by a motor carrier for one of its ELD drivers?
    • 5. Can a driver’s electronic logging device (ELD) single user account be authorized for administrative functions, in addition to its driver-related functions?
    • 6. Driver accounts must include the CDL number and state. If a driver relocates to another state and obtains a new commercial driver’s license, can the ELD allow for editing the driver profile to change the license number and state or must a new driver account be created? If so, how would the two link together to allow for recording the prior seven days?
    • 7. Can a motor carrier set up a driver account as an “exempt driver” and have another account for the same driver as a regular driver account?
  • ELD Registration and Certification
    • 1. When will electronic logging device (ELD) system suppliers be able to start registering their ELDs with FMCSA?
    • 2. What happens if a registered device listed on FMCSA’s website is later found not to meet the technical specifications in the Electronic Logging Device (ELD) rule?
    • 3. What is the procedure to remove a listed certified electronic logging device (ELD) from FMCSA’s website?
    • 4. Is the electronic logging device (ELD) vendor/manufacturer required to notify motor carriers if a device is removed from FMCSA’s ELD registration list because it was determined to be noncompliant?
    • 5. What happens if an electronic logging device (ELD) is found to be non-compliant after it is in use?
  • Differences between AOBRDs and ELDs
    • 1. What are the differences in the technical specifications in the 1988 automatic onboard recording device (AOBRD) Rule (49 CFR 395.15) and the Electronic Logging Device (ELD) rule?
    • 1- “Telematics”: As a minimum, the ELD
    • 2- “Local Transfer”: As a minimum, the ELD
  • Differences between AOBRDs and Logging Software Programs
    • 1. What are the differences between automatic onboard recording devices (AOBRDs) and devices using logging software programs?
  • Specialty Operations
    • 1. In an operation that involves a tillerman and a driver, what method should the tillerman use to record his or her hours-of-service?
    • 2. Is a driver required to maintain their records of duty status on an ELD while operating a rental vehicle?
    • 3. Are drivers that operate in Canada and Mexico required to use an ELD when driving in the US?
  • ELD Technical Specifications
    • 1. Why are technical specifications in the Electronic Logging Device (ELD) rule?
    • 2. Will FMCSA provide the eRODS application for vendors to test against?
    • 3. Is a physical connection between the ECM and ELD required in order to establish integral synchronization with the engine?
    • 4. If an ELD loses connection to the ECM how will the device report a system failure?
    • 5. Must the manufacturer self-certify and register every version or firmware update to the ELD?
    • 6. Are vendors required to update or register each different configuration of hardware, even though the product is the same as an application (APP) (e.g., black box and Samsung, black box and iPhone, black box and Nexus)?
    • 7. Does the registration process require companies to exclusively use FMCSA’s test procedure? Will vendors have access to testing facilities for ELDs?.
    • 8. How will CMV environmental specifics be tested with the ELD – for example, mounting and connections to the ECM?
    • 9. How will the ELD report on-duty not-driving status when the origin of the duty status is automatic instead of driver-input?
    • 10 . The Event Checksum Calculation describes the individual items to be included in the calculation. Number 9 says “CMV Number.” Is this the CMV VIN or the CMV Power Unit Number?
    • 11 . Are unassigned driving reports required to be available at roadside?
  • ELD Manufacturer Compliance
    • 1. As an electronic logging device (ELD) manufacturer, how can I make sure that my product is compliant?
  • Automatic On-Board Recording Device (AOBRD)
    • 1. Can a motor carrier purchase automatic on-board recording devices (AOBRDs) in bulk quantities for installation after December 18, 2017?
    • 2. If a motor carrier adds an owner operator to its fleet after December 18, 2017, and the owner operator operates with a grandfathered AOBRD in their CMV, can the owner operator continue to use its grandfathered AOBRD while employed by the motor carrier?
    • 3. If an AOBRD becomes inoperable after December 18, 2017, can that AOBRD be replaced if it is under warranty?
• Technical FAQ’s
  • ELD Systems
    • What is an ELD system? What is an ELD support system?
    • How can a driver edit their ELD data after leaving the vehicle?
  • Functional Specifications
  • User Accounts
    • Can a driver have more than one user account?
    • Are ELDs required to be interoperable?
  • Exempt Driving Status
    • Is the ELD required to offer an exempt driver account?
    • Can a driver select exempt driver status?
    • How should the ELD function if the driver is operating under a situation that is exempt from the ELD rule?
  • Unidentified Driver Account
    • Section 4.6.1.6(d) states that “An unidentified driving records data diagnostic event can be cleared by the ELD when driving time logged under the unidentified driver profile for the current 24‐hour period and the previous 7 consecutive days drops to 15 minutes or less.” Does this mean 15 minutes or less in each of the 7 previous days, or does it mean the sum of all unidentified driving time over the previous 7 days totals 15 minutes or less?
    • What data does the ELD need to log when there is an unidentified driver? (added Sept-2017)
    • How can unidentified driving time be assigned? (added Sept-2017)
    • If the unidentified driving time is accepted by the driver, will the ELD still show the driving time as unidentified? (added Sept-2017)
    • If the driver rejects unidentified driving, should that be displayed on the ELD for the roadside inspection view and output file view? (added Sept-2017)
    • How should “odometer jumps,” caused by a driver unplugging the ELD from the ECM be captured? (added Sept-2017)
    • In the case of portable device platforms, if a driver forgets his or her phone or tablet, must unidentified driving time still be collected through an engine tied device or is it considered uninstalled? (added Sept-2017)
    • Can ELD events remain unassigned after a trip is assigned to a driver? (added Sept-2017)
  • Powering On/Sensing
    • Can an ELD provider pass the one-minute boot time rule by requiring the driver to power on the device (or an app) prior to starting the engine?
    • Is it permissible to allow the ELD to power up, boot, and accept driver logins before the engine is powered?
    • Can a mobile app and the vehicle engine communicate over cellular?
    • What is a manufacturer required to do when required data is not available from the ECM?
    • Is the ELD required to retrieve the CMV position from the device connected to the port, or can this be retrieved by using a smartphone or tablet?
    • Can the partial VIN value obtained from the controller area network bus be used for reporting?
    • If the required ELD data from the ECM is private and requires an agreement with the original equipment manufacturer (OEM) to obtain said data, are ELD providers required to enter an agreement with the OEM?
    • How should the ELD handle the dashboard odometer display not matching the odometer value returned by the ECM? For instance, when the engine is replaced and the value is not synced.
  • Data Recording
    • How should the Time Zone Offset from UTC handle daylight savings time?
    • Would server-based events (e.g., edits and assignment of unassigned events) generate a different sequence ID than that generated by the ELD?
    • In a portable device platform, should the event identifier sequence number be associated with the portable device or the vehicle’s black box?
    • When an existing record becomes inactive and its replacement record becomes active or inactive-change-requested, is it acceptable that the replacement record has the same sequence ID as the record it replaces?
    • When creating an ELD file as specified in Section 4.9.2, when a field specifies activities on a per-CMV basis (such as engine power-up and shut-down activities), which records should be included?
  • Malfunctions
    • In Section 4.6.1.7, the rule requires that “an ELD must verify [data transfer] functionality every seven days.” What does this mean?
    • How should an ELD respond to battery issues, such as an ELD battery dying due to high temperatures or when charge power runs out? (added Sept-2017)
    • How will FMCSA ensure that the ELD data is transferred securely? (added Sept-2017)
  • Driver Edits
    • Does the rule require that the driver have editing capabilities?
    • If a driver makes an error, can that record be deleted?
    • Can a carrier make edits to a driver’s logs?
    • Are there any edits that are not permitted?
    • Will hours of service violations notification be eliminated upon an annotation being made by the driver or motor carrier? (added Sept-2017)
    • What is the Commercial Motor Vehicle Power Unit Number?
    • How should CMV Power units be listed if power units are used more than once by the driver within the period set requested?
  • Duty Status Categories
    • How should the duty status categories be displayed? (added Sept-2017)
    • Is the ELD required to automatically change duty status from Sleeper Berth to Driving upon sensing movement?
    • In Table 6, Event Type 3, it lists “Driver indication for PC, YM, and WT cleared.” What does WT refer to?
    • When is the ELD required to automatically change the driver’s duty status to driving? (added Sept-2017)
    • Is the ELD required to automatically change duty status from Sleeper Berth to Driving upon sensing movement? (added Sept-2017)
    • If a driver forgets to indicate the start of Personal Conveyance (PC) or Yard Moves (YM), can they later edit that automatically generated driving event and change that Off Duty to PC or On Duty to YM? (added Sept-2017)
  • Yard Moves
    • How can yard moves be reflected on the ELD? (added Sept-2017)
    • What driver duty status should yard moves be reflected under? (added Sept-2017)
    • Can an ELD use geofencing to automatically change a driver’s duty status to Yard Move?
    • Is there a requirement to indicate odometer or positioning at the beginning and end of a Yard Move category?
    • Can an ELD maintain a Yard Move status after the truck has been turned off?
    • Can a carrier set parameters for yard moves via the technical specifications? (added Sept-2017)
  • Display and Print Requirement
    • Does the rule require that an ELD be able to both display electronically and print?
    • Would a PDF that can be transmitted wirelessly be acceptable in lieu of a print feature?
    • In 4.8.1.2, the rule requires that an ELD without a printer be designed so that “the display may be reasonably viewed by an authorized safety official without entering the commercial motor vehicle.” Can you define “reasonable distance”?
    • The rule indicates that the graph-grid for each day’s records of duty status must be at least 6 inches by 1.5 inches in size. Can you clarify what this means for requirements for screen size?
    • Is the display required to be handed to the inspector outside the truck?
    • Can the driver’s license information be omitted or redacted from the printed logs?
    • Section 4.8.1.3 indicates that location needs to be displayed for login/logout events. However, Section 4.5.1.5 lists required data elements for login/logout events and does not indicate that latitude and longitude need to be recorded. Which is accurate?
    • In the ELD header, should miles driven reflect miles in the current CMV or all CMVs that the driver has operated on the displayed date? What about Start End Odometer and Engine Hours?
    • Will ELD providers have access to the eRODS view of the extracted ELD data?
    • When a driver makes an edit, should the original record be visible in the print or display option? (added Sept-2017)
    • When is the ELD required to display data? (added Sept-2017)
    • What information must be displayed on the ELD or provided on the ELD printout? (added Sept-2017)
    • What information should be displayed on the header for co-driver operations? (added Sept-2017)
  • Data Transfer
    • Would it be acceptable for the data transfer to be initiated by the ELD but relayed through and communicated to FMCSA Service from the provider’s backend?
    • If a multi-function portable device is used for the front end of the ELD Device (i.e., user may be in a GPS application and need to switch back to the ELD application), does this count as a click in the single-step interface requirement?
    • Will FMCSA collect State enforcement agency data transfer capabilities/preferences?
    • Is it necessary for drivers to enter their user credentials before starting the data transfer process? (added Sept-2017)
  • ELD Output File
    • Section 4.8.2.1.1 specifies that the ELD output file must have one line for co-driver information and one line for CMV information. There may be multiple co-drivers and/or multiple CMVs. Should it contain the first co-driver and CMV in the day, or the last one, or is there any other option?
    • If a driver operates with multiple commercial motor vehicles (CMV), which CMV’s records must be included in the ELD file?
    • Must the daily header display “ELD Registration ID” or “ELD Identifier”?
    • During an investigation, how should the header section reflect ELD data?
    • Is it permitted to leave certain fields blank (e.g., sequence id, record origin) for records that were originally obtained from an AOBRD (e.g., operating in a mixed fleet) or will these files be rejected?
    • For ELD Event Annotations or Comments records in Section 4.8.2.1.5 (ELD Data File), what do the <{Event} Date> and <{Event} Time> refer to?
    • Regarding Section 4.8.2.1.9, which Power Up and Power Down events should be included?
  • Data Transfer Methods
    • The rule states an ELD must use option 1 or 2 for data transfer. Can an ELD offer Web Services and USB?
    • Why is there a reference to the internet in Bluetooth transfer when it is part of the local transfer option?
    • Is the ELD required to encrypt files during a USB electronic data transfer?
  • Data Transfer/Connectivity Issues
    • What if there is no internet connectivity to perform telematics data transfer between the ELD and the safety official? (added Sept-2017)
    • Can an ELD connect to the ECM in a manner that relies on internet connectivity? (added Sept-2017)
    • What is the resolution process if the FMCSA data transfer mechanism incorrectly rejects a data file during an electronic data transfer? (added Sept-2017)
  • Registration and Self-Certification
    • Is the data submission and test certification a one-time effort?
    • What is the purpose of the authentication value?
    • Can the required ELD user manual be in digital format?
    • To ensure that the list of self-certified ELDs is current, ELD providers must notify FMCSA of any major changes to their device. What constitutes a major change to an ELD? (added Sept-2017)
    • Will ELD providers be able to provide an updated public key in the event of a security breach? (added Sept-2017)
    • Must a provider self-certify ELD software and compatible devices, i.e., smartphone, tablet? (added Sept-2017)
    • If you are creating an application to be used on a smartphone or tablet, do you have to verify and list all the devices that the application works on? (added Sept-2017)
    • If a manufacturer offers a white-label device for sale to others with their logo on it, must all “providers” self-certify so that their own offering with branding is listed on the self-certified list? (added Sept-2017)
    • In what format should I submit my public key to FMCSA? (added Sept-2017)
    • What is an authentication value? (added Sept-2017)
    • How many characters should my authentication value be? (added Sept-2017)
  • Removal Process
    • When will FMCSA start testing ELDs that have been self-certified? (added Sept-2017)
    • Will FMCSA notify the industry when an ELD is under an investigation? (added Sept-2017)

Indices and tables

• Index
• Module Index
• Search Page