ELDs or "electronic logging devices" are devices that are required for most commercial motor vehicle drivers to keep their records of duty status (RODS) electronically for their hours-of-service (HOS) logbooks. The FMCSA published the ELD mandate back in December 2017 with strict guidelines on how electronic logging devices have operate in order to be certified for industry use. This guide will help you understand what ELD providers must do under the ELD mandate to be compliant with the FMCSA.
What data is collected from the truck?
An electronic logging device must be connected to the truck and must collect 5 pieces of information for the vehicle to be considered compliant. Using just ELD apps on your phone will not be compliant if it cannot get these 5 items from the vehicle. The 5 items are:
- VIN# of the truck
- Wheel speed (to tell if the truck is moving)
- RPM (to tell if the truck is on/off)
- Engine hours
- Odometer
If the devices that is plugged into the truck is not able to get any of these data items the ELD will have to throw a “missing required data elements data diagnostic" event to let the user know that one or more of the required data items was not able to be collected for a log entry.
These items are used in every entry on your HOS logbook. These items let DOT know if the logs are correct and accurate or have been manipulated or cheated in any way.
Every RODS entry will contain the following data.
- Date/time
- Location
- Event/status
- Odometer reading
- Engine hours
- Origin
- Notes
When the DOT performs a roadside inspection this information will allow them to see how long the driver has been working and if everything falls inside of the HOS laws.
Automatic logging entries
There are a few entries that the ELD has to make automatically to ensure that the time the vehicle is in motion time is being added to the logbook.
When a vehicle goes over 5 mph an automatic driving event will be added to the logbook. The ELD will be disabled to prevent distraction to the driver while the vehicle is in motion.
While the vehicle is in motion an "intermediate" log entry is made at least once per hour to indicate that the vehicle was still in motion at the time of entry.
When the vehicle has stopped moving for 5 minutes the ELD has to ask the driver if they are still driving and move them to the "On Duty Not Driving" (ODND) line when they say "no". If the driver does not answer the prompt after 1 minute then the ELD must move the driver to the ODND line automatically to prevent wasting driving hours.
Position and location entries
ELDs are required to get GPS position and use the GPS data to make a location entry in the logbook. The location is not an exact location. The GPS only has to be accurate with in 1 miles from the drivers actual location when preforming work and with in 10 miles when used for personal conveyance to keep privacy.
The location entries used are based off of a Census map and is required to give a cardinal direction and distance for a city with a population over 5,000 people. Common position entries will look like:
10 mi NW WV Huntington
Many users believe that the location has to be exact but this is a common misconception.
Editing and removing logbook entries
Many logbook entries can be edited to account for user errors. Carriers and drivers can edit logs to better reflect what might have happened and fix any mistakes made by users in error. The only drive time that can legally be edited is manually added drive time by the user. Once the truck is in motion the ELD makes a new entry indicating an automatically recorded driving event. These type of driving events CANNOT be edited and a note must be made why this event may be misunderstood.
Any edit that is made must be notated with at least 3+ characters on why the edit was made. These notes are available at roadside inspections for DOT to review so the more detailed the note the more the DOT will be able to understand what was going on around the event.
None of the data is actually deleted in the logbook. If a logbook entry is removed from the logbook the entry still exist in the ELD's database and all of the data is made available for DOT during roadside inspections.
If a carrier has made any changes to a drivers logbook the driver must be notified of the change next time they log into their account and must accept the change before it is entered. The driver always has the final say as to what goes into their logbook. Once the change is accepted the logbook for that day must be certified.
Data transmission to DOT
Data must be able to be transmitted in 2 out of 4 ways. ELD providers can choose which ways they prefer to transmit logbook data to DOT. The 4 ways are
- Transfer to the FMCSAs server using web services
- Data transfer through a USB drive
- Email to an FMCSA specified email address
- Transfer using bluetooth
The most popular method by DOT is submitting the HOS logs through email to an FMCSA specified email address.
Unidentified drive time
Whenever a truck is moving but there is not a driver logged into a registered account the system must log all moving events as an "Unidentified driving" event. When a user logs into the a device that is connected to a vehicle that has had unidentified driving events the system will ask the user if the recorded events belong in their log book. If they say yes the events will be inserted into the drivers log and can be certified. If the driver rejects the unidentified events they will remain on the system as unidentified.
If a carrier knows which driver the event belong to they can assign the events to the correct drivers log and when the driver logs into the system next time can approve the entries into their log and certify.
Occasionally, unidentified events are created when a trucking's maintenance team moves trucks around the yard for maintenance and service. Maintenance employees should also have accounts with the ELD system so that these events can be accounted for and someones records.
If unidentified events are not assigned to a user this can cause problems during a DOT inspection or DOT audit and may lead to more serious consequences.
Personal Conveyance and Yard Moves
Driving events can be logged in 1 of 3 ways depending on the nature of the driving event.
If the vehicle is being driven to advance or pick up a load it must be logged as driving and shown on the drive line in the HOS logbook.
If the driving event is for moving the vehicle around the yard, site, or travel center it can be logged as a "Yard Move" and must show on the "On Duty Not Driving" line of the logbook with a unique line indicating that driving has happened.
If the vehicle is being used by the driver to take care of their personal errands or task then any drive time can be logged as "Personal Use". These events show in the "Off Duty" line of the HOS logbook with a unique line to indicate that driving has taken place.
Personal conveyance and Yard move events are set by the carrier and they have the ability to turn these features on or off for their fleet.
Driver and Roadside Inspection cards
Every ELD provider must provide driver cards and roadside inspection cards. These tell the drivers and DOT how to navigate the ELD to perform the necessary events at roadside to provide log books to the DOT. These cards must be available in the truck and can be a violation if they are missing.
