Electronic Logging Frequently Asked Questions

An electronic logging device (ELD) is a device connected to a commercial motor vehicle to automatically record driving time and facilitate the recording of other duty status information for purposes of compliance with the federal hours-of-service rules. To be considered an ELD, the device must meet specific technology requirements and be listed on the FMCSA’s ELD registration site. As of December 17, 2019, only ELDs listed on the FMCSA's ELD registry are considered compliant electronic logs for use in the United States.

E-Logs or ELogs is a generic term used for any electronic log used to record a commercial driver’s hours of service. An ELog may or may not capture information automatically (such as when the driver is driving). ELogs may be used in place of paper logs but are not an acceptable replacement for electronic logging devices (ELDs) when an ELD is required.

Yes, with some exceptions. As of December 18, 2017, commercial motor vehicle to drivers who are subject to the federal hours-of-service rules and who are required to use standard logs to record their hours of service must use an ELD in place of paper logs in most cases. Exceptions exist for certain short-haul drivers, drivers of pre-2000 vehicles, drivers who must log less than 9 times in 30 days, and drivers engaged in certain types of driveaway-towaway operations. Drivers engaged in intrastate operations within certain states are also exempt.

There are numerous benefits to using electronic logs:

• First and foremost, ELDs 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 ELDs see 50-percent reduction in their roadside hours-of-service violations.
• Besides making compliance easier, ELDs 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.

These devices are not ELDs because they are not either directly or indirectly connected to the engine to automatically collect the required vehicle data (such as movement, engine hours, and speed data). Therefore, they cannot be used to satisfy the ELD mandate. These non-integrated devices are allowed for logging only if the driver has an exemption to use paper logs rather than an 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.

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 email, or locally through a USB 2.0 or 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.

In addition, the driver must provide the inspector with any supporting documents that he or she possesses, upon request.

Drivers who are using an ELD only have to print their logs if the device does not have a display that the officer can view from outside of the vehicle.

If an 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.

Once notified, the carrier has eight days to repair or replace the device. If it cannot be repaired or replaced within eight days, the carrier can ask its local FMCSA office for an extension.

Ensure your drivers understand the regulations surrounding ELD failure and other mandate requirements with ELD and hours of service training.

Yes, records from Global Positioning Systems (GPS) associated with fleet management, communication, and tracking systems may be subject to audit by the FMCSA (whether those systems are a part of an ELD 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.

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.

The Electronic Logging Device (ELD) mandate is the common name for a comprehensive final rule published by the FMCSA on December 16, 2015. These electronic logging device regulations:

• Require the use of electronic logging devices (ELDs) by most commercial drivers who are required to prepare hours-of-service records of duty status.
• Set performance and design standards for ELDs and requires the devices to be registered with the FMCSA.
• Establish which "supporting documents" drivers and carriers are required to keep.
• Prohibit harassment of drivers based on ELD data or connected technology (such as a fleet management system). The rule also provides recourse for drivers who believe they have been harassed.

Carriers subject to the federal ELD mandate had until December 18, 2017, to comply. During a two-year period after that deadline, carriers were allowed to continue using grandfathered automatic on-board recording devices (AOBRDs) if they were installed, before December 18, 2017, The deadline for converting from AOBRDs to ELDs was December 16, 2019. In general, states were allowed to set their own deadlines for compliance with in-state ELD mandates.

The ELD rule applies to commercial motor vehicle drivers who are required to maintain records of duty status (RODS, or “logs”) per 49 CFR 395.8(a) and who do not qualify for any special exemptions.

Specific ELD exemptions exist for:

• Drivers who only have to log 8 days (-or fewer-) in any period of 30 consecutive days
• Drivers operating a driveaway/towaway vehicle that is part of a delivery
• Drivers driving or towing a recreational vehicle in a driveaway/towaway operation
• Drivers operating a vehicle that is older than model year 2000 (1999 or older) or that has an engine that is older than model year 2000
• Drivers operating a rental truck that was rented under the terms of a lease agreement that is 8 days or less in duration

In addition, drivers transporting livestock or who are fully exempt from the HOS rules under one of the exceptions in §390.3, §390.23, or §395.1 are also exempt from using an electronic logging device while operating under the exemption. This includes government employees, drivers transporting agricultural commodities within 150 miles of the source during the state’s planting and harvesting season, drivers operating utility service vehicles, drivers engaged in providing emergency relief, etc.

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 operating while ill or fatigued.

Even if the company is exempt, they may choose, as a good business decision, to use an ELD solution that enables the carrier to:

• Effectively manage complex Hours of Service requirements
• Know where their assets are
• Know how safely the assets are being operated
• Have the ability to estimate time to a job site and time back to the terminal
• Manage productivity (time at a job site, stopped, traveling, out-of-route travel, etc.)
• Document drivers' vehicle inspections
• Track driver qualifications
• Track vehicle maintenance
• Create a performance incentive program based on quantifiable data
• Have a tool that assists with IFTA and IRP compliance

Canada’s electronic logging device (ELD) mandate requires the use of ELogs by federally regulated carriers and their drivers who are required to prepare a record of duty status. The regulations apply to drivers operating the following types of vehicles:

• A truck, tractor, trailer, or any combination of them that has a registered gross vehicle weight in excess of 4,500 kilograms; or
• A bus that is designed and constructed to have a designated seating capacity of more than 10 persons, including the driver.

The mandate also requires devices to be third-party certified by an outside certification body.

The ELD mandate in Canada went into effect on June 12, 2021, with a one-year educational enforcement period.

If you’re a federally regulated carrier based in Canada and are not exempt, then you are required to comply with the Canadian ELD mandate.

U.S.-based carriers operating into Canada are also subject to Canada’s ELD mandate.

U.S.-based carriers must use Canada-certified ELDs when operating into Canada.

The use of ELDs in Canada is not required for drivers of:

• Vehicles operated by a motor carrier under a permit;
• Vehicles operated by a motor carrier who is operating under an exemption issued under the Motor Vehicle Transport Act;
• Vehicles operated under a rental agreement of 30 days or less (and not extended or renewed); or
• Vehicles manufactured before model year 2000.

Drivers operating within the 160-kilometer radius of the home terminal are also not required to use an ELD provided all criteria are met.

Even if you’re not required to use ELogs, there may be good reasons to use them. One area where they may be particularly helpful is for drivers operating within a 160-kilometer radius of the home terminal. These drivers are not required to use an ELD but can do so to help keep track of Canadian hours of service. The ELD is useful if/when the driver is no longer subject to the exemption — for example, the driver operates outside of the 160-kilometer radius and is now required to use an ELD.

The use of ELDs can also help carriers:

• Effectively manage Canada’s hours of service requirements
• Know where their assets are
• Know how safely the assets are being operated
• Have the ability to estimate time to a job site and time back to the terminal
• Manage productivity (time at a job site, stopped, traveling, out-of-route travel, etc.)
• Document driver vehicle inspections
• Track driver qualifications
• Track vehicle maintenance
• Create a performance incentive program based on quantifiable data
• Manage IFTA and IRP compliance