ELD Requirements, January 2016

ELD Requirements pursuant to the December 2015 FMCSA announcement absolutely no later than January 1, 2018 (or December 10, 2017, to be safe) with some older devices grandfathered until January 1, 2020 (December 10, 2019).

Is this the final FMCSA ruling on ELD’s?

Yes, this is final, immutable, never to be repealed and written in stone, unless things change.

Does the ELD replace paper DOT/FMCSA HOS (Hours of Service) logbooks?

Pretty much.

What do safety officials need to see in an ELD?

An ELD must be mounted to the dashboard, visible to the driver. It must have an instruction manual, although the manual can be electronic, i.e. the instructions can be read from the device itself. The driver must carry eight (8) days of empty logbook pages in the event of device malfunction.

Transmitting Data to Safety Officials – ELD will transmit in at least one ‘Primary’ and at least two ‘Backup’ formats. Primary include Web services, Bluetooth, Email and ‘Backup’ include USB 2.0, Scannable QR codes, TransferJet.

Email must be sent in a standard RFC 5322 Internet Message Format.

But note, in the real world, many Safety Officials will look at the HOS log on the screen of the device itself.

Safety officials will use every means possible to detect when a driver is lying, fudging or cheating, just as they always have, as is their duty.

Many ELD devices designed and put into service prior to the December 10, 2015 announcement are grandfathered until either December 10, 2017 or December 20, 2019 for the really cool ones (and depending on interpretation), paper logbooks are still legal after December 10, 2019, but only in the event of infrequent need or equipment malfunction.

Why would a really cool, new (but pre-2017) ELD still need to be replaced?

New requirements include specific xml formats, web services formats, formats that talk directly with the FMCSA website and database, logging with embedded GPS positioning data and logging with embedded hash codes that prevent tampering, to name a few, will probably require newer equipment. Anti-tampering kiosks are also a plus. Note that many of the anti-tampering requirements collide head on with the transmission requirements, e.g. USB 2.0.


Timecard or Local Drivers. Short-Hauler, CDL drivers that operate within a 100 air-mile radius of the normal work reporting location or Non-CDL drivers operating within a 150 air-mile radius of their home depot are not required to install an ELD device.

Also, From the FMCSA website – https://www.fmcsa.dot.gov/faq/there-exception-drivers-who-infrequently-use-records-duty-status-rods

Is there an exception to the requirement to use electronic logging devices (ELDs) for drivers who infrequently use records of duty status (RODS)?

An exception was made to provide relief for those drivers who use RODS infrequently (that is, no more than 8 days in any 30-day period). This includes those who only occasionally drive commercial vehicles, and short-haul drivers who use time cards rather than RODS.

What is difficult for the driver in this situation is that he is forced to prove a negative.

Finally, trucks built prior to 2000 may be exempt, partially exempt, or conditionally exempt. Which has nothing to do with RODS, so read the next section.

Data Collected

The ELD should collect some location data, but the FMCSA rule only requires a GPS accuracy of +/- one (1) mile.

Section 395.26 provides that the ELD automatically record the following data elements at certain intervals: date; time; location information; engine hours; vehicle miles; and identification information for the driver, the authenticated user, the vehicle, and the motor carrier. Unless the driver has indicated authorized personal use of the vehicle, those data elements are automatically recorded when the driver indicates a change of duty status or a change to a special driving category. When the driver logs into or out of the ELD, or there is a malfunction or data diagnostic event, the ELD records all the data elements except geographic location. When the engine is powered up or down, the ELD records all the data elements required by ยง395.26. When a CMV is in motion and the driver has not caused some kind of recording in the previous hour, the ELD will automatically record the data elements. However, if a record is made during a period when the driver has indicated authorized personal use, some elements will be left blank and location information will be logged with a resolution of only a single decimal point (approximately 10-mile radius). In addition to the information that the ELD record

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