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Question 1: Does the Electronic Logging Device (ELD) rule require real-time tracking of commercial motor vehicle (CMVs) with ELDs?
Guidance: No. Real-time tracking of CMVs is not required in the ELD rule. However, a motor carrier may use technology to track its CMVs in real time for business purposes. A motor carrier is free to use this data as long as it does not engage in harassment as defined in 49 CFR 390.36 or violate other provisions of the Federal Motor Carrier Safety Regulations (FMCSRs).
Question 2: What information should be displayed on the header for co-driver operations?
Guidance: The header should contain the information of the current co-driver. If there is no active co-driver at the time of inspection, then this field should be left blank. If a co-driver has been active during the record retention selection, the co-driver will be listed in the user list of the data transfer file. For the back-up print or display, providers may list the co-driver active for that day in the daily header.
Question 3: When is location data recorded by an electronic logging device (ELD)?
Guidance: Location data must be recorded by an ELD at 60-minute intervals when the vehicle is in motion, and when the driver powers up and shuts down the engine, changes duty status, and indicates personal use or yard moves.
Question 4: When will an electronic logging device (ELD) automatically start to record a driving mode or status?
Guidance: An ELD must automatically switch to driving mode once the commercial motor vehicle (CMV) is moving up to a set speed threshold of 5 miles per hour. As a result, the in-motion state must not be configured greater than 5 miles per hour. The vehicle will be considered stopped once its speed falls to zero (0) miles per hour and stays at zero (0) miles per hour for 3 consecutive seconds.
Question 5: When will an electronic logging device (ELD) automatically change the duty status from Driving to the default duty status of On-Duty Not Driving?
Guidance: When the duty status is set to Driving, and the commercial motor vehicle (CMV) has not been in motion for 5 consecutive minutes, the ELD must prompt the driver to confirm a continued driving status or enter the proper duty status. If the driver does not respond to the ELD prompt within 1 minute, the ELD must automatically switch the duty status to On-Duty Not Driving.
Question 6: Can an electronic logging device (ELD) record be set to record minimum duty status durations, such as 15 minutes?
Guidance: No. The ELD will capture all entered duty statuses, and there is no minimum amount of time that these statuses must or should be engaged. While longstanding industry and enforcement practices may have relied upon minimum intervals of 15 minutes in handwritten record of duty status (RODS), an ELD provides a more accurate accounting of drivers’ time. This should not be construed to indicate that the activities electronically recorded as less than 15 minutes are suspect, only that the time actually required to complete the task may be less than what had been traditionally noted in the paper RODS.
Question 7: How should the electronic logging device (ELD) handle the dashboard odometer display not matching the odometer value returned by the electronic control module (ECM)? For instance, when the engine is replaced and the value is not synced.
Guidance: If the dashboard odometer display does not match the odometer value returned by the ECM, the ECM odometer value must be identified as the valid value.
Question 8: When is the electronic logging device (ELD) required to automatically change the driver’s duty status to Driving?
Guidance: The “Driving” duty status must be automatically recorded by the ELD when the operated vehicle meets the configured threshold; not to exceed 5 mph. See sections 4.4.1 of 49 CFR part 395, subpart B, Appendix A.
Question 9: In the ELD header, should miles driven reflect miles in the current commercial motor vehicle (CMV) or all CMVs that the driver has operated on the displayed date? What about Start End Odometer and Engine Hours?
Guidance: The ELD header must reflect data for the current CMV. See sections 4.3.1.3 and 4.3.1.4 of 49 CFR part 395, subpart B, Appendix A.
Question 10: Is an electronic logging device (ELD) required to collect data about vehicle performance?
Guidance: No. ELDs are not required to collect data on vehicle speed, braking action, steering function, or other vehicle performance parameters. ELDs are only required to collect data to determine compliance with hours of service (HOS) regulations.
Question 11: Do the specifications in the electronic logging device (ELD) rule for ELDs include requirements to automatically control the vehicle, such as other safety systems that may or apply braking?
Guidance: No. The specifications for ELDs do not include requirements to control the vehicle. An ELD is a recording device that records vehicle parameters through its synchronization to the vehicle’s engine, and allows for entries related to a driver’s record of duty status (RODS).
Question 12: What is the level of accuracy for commercial motor vehicle (CMV) location information recorded by an electronic logging device (ELD)?
Guidance: During on-duty driving periods, the location accuracy is approximately within a 1-mile radius. When a driver operates a commercial motor vehicle (CMV) for personal use, the position reporting accuracy would be approximately within a 10-mile radius.
Question 13: Will GPS-derived data for mileage be allowed as a substitute for data that cannot be readily obtained from a vehicle electronic control module (ECM)?
Guidance: No, the electronic logging device (ELD) must be able to monitor engine operation to automatically capture required data. A global positioning system (GPS) is not integrally synchronized with a vehicle’s engine and cannot be a substitute for required ECM data to comply with the ELD rule.
Question 14: May an electronic logging device (ELD) be used to track mileage for tax reporting purposes?
Guidance: The device manufacturer may offer that service as part of a fleet management package but mileage tracking for tax reporting purposes is not part of the ELD data established in 49 CFR part 395.
Question 15: How should the electronic logging device (ELD) handle the dashboard odometer display not matching the odometer value returned by the electronic control module (ECM)? For instance, when the engine is replaced and the value is not synced.
Guidance: If the dashboard odometer display does not match the odometer value returned by the ECM, the ECM odometer value must be identified as the valid value.
Question 16: Is the ELD required to automatically change duty status from Sleeper Berth to Driving upon sensing movement?
Guidance: The ELD is required to automatically change a driver’s duty status to Driving when the vehicle is in motion, set at 5 mph threshold or less, after being in the Sleeper Berth duty status unless the driver is in a team operation and the inactive driver logged in the ELD. However, while the vehicle is in motion, intermediate recordings will be included on the inactive driver’s logs during the sleeper berth period.
Question 17: Will the vehicle location information identify street addresses?
Guidance: No. Vehicle location information is not sufficiently precise to identify street addresses. For each change in duty status, the electronic logging device (ELD) must convert automatically captured vehicle position in latitude/longitude coordinates into geo-location information that indicates the approximate distance and direction to an identifiable location corresponding to the name of a nearby city, town, or village, with a State abbreviation.
Question 18: How should the electronic logging device (ELD) handle the dashboard odometer display not matching the odometer value returned by the electronic control module (ECM)? For instance, when the engine is replaced and the value is not synchronized.
Guidance: The ELD is required to obtain and display the ECM value at all times. Safety officials will use the odometer value reported on the ELD. Note that documentation of engine changes is required by 49 CFR part 379 Appendix A to be maintained at the carrier’s place of business.
Question 19: Is an ELD required to monitor its compliance with the ELD technical requirements?
Guidance: Yes. An ELD must monitor its compliance with the ELD technical requirements and detect malfunctions and data inconsistencies related to power, data synchronization, missing data, timing, positioning, data recording, data transfer, and unidentified driver records requirements. The ELD output will identify these data diagnostic and malfunction events and their status as either “detected” or “cleared.” Typically, a driver can follow the ELD provider’s and the motor carrier’s recommendations to resolve the data inconsistencies that generate an ELD data diagnostic event, while a motor carrier must correct a malfunction.
Question 20: When an event is recorded by an electronic logging device (ELD) component not connected to a powered-on power unit, is the information pertaining to the power unit required?
Guidance: If the driver logs into an ELD component that is not connected to a power unit, information pertaining to a power unit is not required. Other data elements required to be recorded by the ELD that will not be available when entering duty status changes such as vehicle identification number (VIN), engine hours, and vehicle miles are only required when the commercial motor vehicle’s (CMV’s) engine is powered.