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J. J. Keller protects people and the businesses they run. You can trust our expertise across a wide range of subjects relating to labor, transportation, environmental, and worker safety. Our deep knowledge of federal and state agencies is built on a strong foundation of more than 100 editors and consultants and 70+ years of regulatory compliance experience.

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J. J. Keller protects people and the businesses they run. You can trust our expertise across a wide range of subjects relating to labor, transportation, environmental, and worker safety. Our deep knowledge of federal and state agencies is built on a strong foundation of more than 100 editors and consultants and 70+ years of regulatory compliance experience.

Is your ELD in danger of dying along with 3G?

December 15, 2022

As of January 1, 2023, the 3G cellular network will be completely shut down. If your electronic logging devices (ELDs) rely on this network for required communications or other functions, such as generating a location, you are going to have a problem. The device’s inability to communicate and/or locate itself will cause the device to be considered as malfunctioning. This means you will have eight days to repair or replace the device.

What is impacted?

Required functions that could be impacted if your ELDs rely on 3G include:

  • Capturing the data necessary to create a compliant record of duty status — The ELD must capture accurate record of duty status data (including capturing locations).
  • Submitting records of duty status — The driver must submit the ELD records within 13 days of completion.
  • Transferring ELD records to officers — A driver must be able to provide the ELD records to an officer during an inspection through either a local or telematic transfer (telematics involves webservice or email). If the 3G shutdown impacts any of these functions on your ELDs, the devices will become non-compliant.

Another problem

Another issue that may be impacted is the ELD system's ability to have the driver's ELD records follow the driver when changing vehicles. In some systems, when the driver logs into a new device in a different vehicle, the system sends the previous records through the cellular network to the driver’s new device. If this is how your system functions and the device has lost its 3G access, the new device will not be able to "fetch" the previous records.

What happens when a 3G ELD registers a malfunction?

The Federal Motor Carrier Safety Regulations (FMCSRs) specify that when an ELD malfunctions, it must be repaired or replaced within eight days, per 49 CFR 395.34. Drivers will need to use paper graph-grid paper logs to document hours of service.

Why are mobile carriers shutting down their 3G networks?

Essentially, 3G is an old technology. In order to have the infrastructure needed to support more advanced networks, such as 5G, carriers are sunsetting their 3G networks.

What if your ELD does not rely on 3G?

If the ELD you are currently using relies on 4G or 5G and meets all other FMCSA requirements, the 3G shutdown will not affect you. If you aren’t sure whether your device will be affected by the sunset of 3G, it would be best to contact the tech support group at your vendor.


Publish Date

December 15, 2022

Author

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Type

Industry News

Industries

Transportation

Related Topics

Hours of Service

Electronic logging device (ELD)

Governing Bodies

Federal Motor Carrier Safety Administration (FMCSA), DOT

Citations

r49CFR395.34