• Responsibility for management of ELD accounts falls on motor carriers, and “ghost driver” accounts with no driver assigned are prohibited.
• Operating an ELD-equipped vehicle without logging in creates an “unidentified driver” event that must be reviewed and either assigned to a driver or explained.

Each driver using an ELD must have their own unique account, and motor carriers must set up and manage these accounts.

Account creation

Motor carriers are required to manage their electronic logging device (ELD) accounts, including creating, deactivating, and updating accounts and ensuring that properly authenticated individuals have ELD accounts with appropriate rights. Each user must have a unique ELD username, and driver accounts must include each driver’s name, license number, and licensing state. If someone operates an ELD-equipped vehicle without logging in, the ELD data collected has to be stored in an “unidentified driver” account.

“Generic” or “ghost driver” accounts are not allowed. These are accounts that do not have an actual driver assigned to them and/or which are shared by several drivers. Prior to ELDs, such accounts were used to address situations where an individual without an account had to drive a vehicle equipped with an electronic logging system. Examples include:

• A “maintenance” account: This account might have been shared by all maintenance and yard personnel to move vehicles in a yard.
• A “road test” account: This account was used by some carriers to road-test new drivers who had not yet been assigned a username.
• A “training” account: This account was used by trainers to instruct new drivers on using the logging system.

Under current rules, the existence of such an account is a violation of the regulations. The reason for this is that drivers may try to use such an account to hide their driving time and exceed the hours-of-service limits. For example, a driver might use their personal login until a limit is reached, and then switch to a ghost-driver account to keep driving. This is considered log falsification. In fact, if a driver is found to be using a ghost account, there are two violations: one for having such an account and one for false logs.

Unassigned driving time

If someone operates an ELD-equipped vehicle without logging in, the driving time will remain “unassigned” and the collected ELD data must be stored in an “unidentified driver” account. When a driver then logs into that ELD, the driver will be prompted to review any unassigned driving time stored on the device and must indicate whether that time belongs to that driver. Motor carriers have to make sure that unidentified driving records are reviewed and must assign the time to the correct driver or add notes to explain why the time is unassigned (why it cannot be assigned to a driver).

To avoid unassigned driving time, a carrier has these choices:

• Assign a driver account to all personnel who might move a vehicle. If a carrier is not willing to do this, unassigned driving time will be unavoidable.
• Have drivers use the special driving categories on the ELD. This way, they will not have to log out when the driving time needs to be on a different duty line, such as off-duty during personal use and on-duty during yard moves.
• Work with the drivers. Counsel and/or retrain drivers when they forget to log in, log out early, or are not logging in for movements for which they mistakenly believe login is not needed, such as personal use and yard moves.

Carriers should also consider having their maintenance and yard personnel keep a register of all vehicles moved and who moved them. This can cut the time spent investigating unassigned driving time. Once an unassigned driving event can be paired to a mechanic or yard driver, a “canned” comment can be added to the unassigned driving time to explain it. While this will not prevent unassigned driving time, it will make managing it much easier.