Subpart B Appendix A Functional Specifications for All Electronic Logging Devices (ELDs)

Question 1: Can the driver’s license information be omitted or redacted from the printed logs?

Guidance: The driver’s license information cannot be omitted or redacted. Section 395.22(c) lists the information the motor carrier must provide when creating a driver account and sections 4.8.1.3 of 49 CFR part 395, subpart B, Appendix A lists the information that must be present on the ELD display screen or printout. This information includes the driver’s first and last name and driver’s license number and issuing state.

Question 2: In the ELD header, should miles driven reflect miles in the current 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 Appendix A to Part 395.

Question 3: Why is there a reference to the internet in Bluetooth® transfer when it is part of the local transfer option?

Guidance: “Local” in this option is referring to the electronic logging device (ELD), which does not need its own connection to the internet. When using Bluetooth, the inspector will share an internet connection that will be used by the ELD device to submit the output file via web services.

Note: The Bluetooth connection can only be guaranteed to offer connectivity to the FMCSA Web Service, so the connection in this case must come from the device itself as it may not be possible to connect to a back-office system using this connection.

Question 4: Can an electronic logging device (ELD) connect to the electronic control module (ECM) in a manner that relies on internet, Bluetooth® or another method of connectivity?

Guidance: Yes, however, the driver’s record of duty status (RODS) must always be available and current to the last duty status change. Therefore, if the driver is unable to access their RODS for a time period due to operating in an area that has limited coverage, the driver may be cited for violating the hours of service rules or operating without an ELD during that time.

Question 5: What does engine synchronization mean for the purposes of electronic logging device (ELD) compliance?

Guidance: Guidance: An ELD must be integrally synchronized with the engine of the commercial motor vehicle (CMV). Engine synchronization means monitoring engine operation to automatically capture the engine power status, vehicle motion status, miles driven, and engine hours.

Question 6: What are the display requirements for team drivers using the same electronic logging device (ELD) on their commercial motor vehicle (CMV)?

Guidance: In the event of team drivers, the ELD must display the data for both co-drivers who are logged into the system.

Question 7: Are electronic logging devices (ELDs) required to be interoperable?

Guidance: No, the ELD [rule] does not require interoperability—one device does not need to have the capability to transfer data from one ELD to another.

Question 8: May electronic logging device (ELD) providers configure the ELD to identify potential hours of service violations?

Guidance: The minimum functional specification requirements in the ELD rule do not require ELDs to identify hours of service violations; however, some ELD providers have elected to offer this as an add-on feature. If an ELD provider offers this add-on feature but does not update their device to reflect [rule changes], the ELD may inaccurately identify hours of service violations. Motor carriers should contact their ELD providers with specific questions about what information their ELD displays.

Question 9: Is the ELD required to retrieve the CMV position from the device connected to the port, or can this be retrieved by using a smartphone or tablet?

Guidance: Position information is not intended to be collected from the ECM. The ability to retrieve the CMV’s position should be provided by part of the ELD System in compliance with 4.6.1.4 of Appendix A to Part 395.

Question 10: Can the partial VIN value obtained from the controller area network bus be used for reporting?

Guidance:

No, a partial VIN is not permitted under Section 7.5 of Appendix A to Part 395. If the VIN cannot be fully obtained from the ECM, it must be entered manually; however, a partial VIN broadcast can be used to aid the driver in entering a manual VIN. Please note:

• Providers are encouraged to use the VIN check digit calculation to help prevent user entry errors.
• A VIN with any level of manual entry must be prefixed by a ”-“ character in the output file.
• As indicated in 4.3.1.7 of Appendix A to Part 395, manual VIN entry cannot be used when the complete VIN can be obtained from the ECM. A device using manual entry when the complete VIN is in fact available from the ECM would not be in compliance with the rule and would be subject to removal from the list of self-certified and registered ELDs.

Question 11: If the required ELD data from the ECM is private and requires an agreement with the original equipment manufacturer (OEM) to obtain said data, are ELD providers required to enter an agreement with the OEM?

Guidance: The ELD provider is required to use all means necessary to obtain the required ELD data from the ECM; this may include entering into an agreement with the OEM or another third party. Using manual entry when the ECM is available would not be in compliance with the rule and the device would be subject to removal from the list of self-certified and registered ELDs.

Question 12: If the vehicle does not track engine hours, can the record begin with “0?”

Guidance: If it is not possible to obtain the engine hours from the ECM, then the ELD may begin recording engine hours at “0” for the given engine the first time the ELD is used with that engine. After the first use, the ELD must continue to keep and use an aggregate total from the first time it was installed or used with an engine. Ideally, back office systems can share this aggregate total so that any other ELD used with the engine can start at the aggregate total, rather than “0.”

Question 13: Would server‐based events (e.g., edits and assignment of unassigned events) generate a different sequence ID than that generated by the ELD?

Guidance: The sequence ID must be continuous to its source device. In an ELD support system, that system may have its own sequence ID generator. Because events cannot be deleted, it should be possible to observe each component in the ELD system which generates sequence IDs and find a continuous list of events for each sequence number without any gaps.

Question 14: In a portable device platform, should the event identifier sequence number be associated with the portable device or the vehicle’s black box?

Guidance: The ELD Rule requires that the event identifier sequence number be consistently applied. It does not specify if the event identifier sequence number must be associated with the portable device or the vehicle’s black box, this is left to the discretion of the provider.

Question 15: When an existing record becomes inactive and its replacement record becomes active or inactive‐ change‐requested, is it acceptable that the replacement record has the same sequence ID as the record it replaces?

Guidance: No, the replacement record must have its own sequence ID number.

When a driver edits an event or a motor carrier suggests an edit, the new event record should have a new sequence ID number.

Question 16: When creating an ELD file as specified in Section 4.9.2, when a field specifies activities on a per‐CMV basis (such as engine power‐up and shut‐down activities), which records should be included?

Guidance: The ELD file referenced in Section 4.9.2 is specific to the file that the motor carrier must provide to the safety official during an investigation. Therefore, any subset of drivers and vehicles, for a subset 6- months specified by an authorized safety official must be included.

Question 17: In Section 4.6.1.7, the rule requires that “an ELD must verify [data transfer] functionality every seven days.” What does this mean?

Guidance: The ELD must verify that it continues to transfer data using the methods it is designed to support. This verification must happen every seven days, either automatically or requiring a manual step from the driver. The specific means of verification are left up to the provider. If the ELD has transferred data in this timeframe, that would be an acceptable means of verifying connectivity. FMCSA will also make available a verification function for the telematics option that may be used to verify connectivity without actually transferring an ELD file. Check the ELD Provider Website for more information.

Question 18: How will FMCSA ensure that the ELD data is transferred securely?

Guidance: During data transfers, Appendix A requires additional security protocol through encryption, American National Standard for Information Technology, IEEE Standards Association, and others as incorporated by reference in Section 6.

Question 19: Section 4.8.1.3 of 49 CFR part 395, subpart B, Appendix A indicates that location needs to be displayed for login/logout events. However, section 4.5.1.5 lists required data elements for login/logout events and does not indicate that latitude and longitude need to be recorded. Which is accurate?

Guidance: Section 4.5.1.5 of Appendix A is correct, location is not required for display of login/logout events, and it is not included in the data file.

Question 20: Will ELD providers have access to the eRODS view of the extracted ELD data?

Guidance: ELD providers will not have access to the eRODS view of the extracted ELD data.

Question 21: Will the Federal Motor Carrier Safety Administration (FMCSA) collect State enforcement agency data transfer capabilities/preferences?

Guidance: The FMCSA will not collect State enforcement agencies’ data transfer preferences.

Question 22: As specified in section 4.8.2.1.1 of 49 CFR part 395, subpart B, Appendix A, the electronic logging device (ELD) output file must have one line for co-driver information and one line for commercial motor vehicle (CMV) information. How can the ELD account for multiple co-drivers and/or multiple CMVs?

Guidance: For files generated during roadside safety inspections, the active co-driver and CMV, must be reflected. For motor carrier data transfer (for compliance investigations), the ELD output file header should reflect the co-driver and CMV in use at the end of the requested time period.

In either case, the file must contain all administrative users, co-drivers, and CMVs referenced during the requested time period.

Question 23: Must the daily header display “ELD Registration ID” or “ELD Identifier?”

Guidance: The daily header must display the ELD Identifier.

Question 24: If a Canada domiciled driver operates in the U.S., will the ELD need to display accumulated vehicle miles and total vehicle miles in units of whole miles?

Guidance: Yes. When operating in the United States, under 49 CFR Appendix A, Section 7.43, a driver must use an electronic logging device that displays vehicle road miles information in units of whole miles.

Question 25: Is the electronic logging device (ELD) required to encrypt files during a USB electronic data transfer?

Guidance: The USB device will be self-encrypting; it will not rely on the ELD device for encryption.

Question 26: Is the data submission and test certification a one‐time effort?

Guidance: After the initial self-certification, providers will only need to update FMCSA with any major changes to the device.

Question 27: What is the purpose of the authentication value?

Guidance: The purpose of the field is to confirm that a specific file came from a specific ELD in a specific vehicle.

Question 28: Must a provider self-certify electronic logging device (ELD) software and compatible devices, i.e., smartphone, tablet?

Guidance: The ELD solution must be certified and registered with FMCSA. For example, if the ELD solution is using a bring-your-own device platform or a portable device, then the software provider must self-certify and register the software and include a list of compatible operating systems.

Question 29: If a manufacturer offers a white‐label device for sale to others with their logo on it, must all "providers" self‐certify so that their own offering with branding is listed on the self‐certified list?

Guidance: As part of the registration process, three pieces of information are necessary to identify a device: ELD Identifier, ELD public key (both from registering company), and ELD Registration ID (from FMCSA). It is allowable to register multiple devices with the same ELD Identifier and public key, but each registered device will have its own unique ELD Registration ID.

The rule does not require that certification be done by the company manufacturing the device. Branding partners can use the certification performed by the white label company.

Question 30: How many characters should my authentication value be?

Guidance: An authentication value must be greater than or equal to 16 characters. For more information on this update to the technical specifications, see the ELD Interface Control Document and Web Services Development Handbook.

Question 31: When will FMCSA start testing ELDs that have been self‐certified?

Guidance: While FMCSA will not be testing ELDs that are currently listed on the ELD registration list or during the registration process, ELD providers have the option of using the file validator available on the ELD registration page to test that their ELD produces a valid file. The ELD registration page will soon be updated with a data transfer testing environment for providers to test their ELD solution data transfer capabilities.

Question 32: Why does an ELD provider need to submit a public key?

Guidance: Provider certificates, which must include a public key, are vital to completing both the telematics and local transfer options for submitting ELD data. The following is excerpted from the ELD Interface Control Document and Web Services Development Handbook, which is now available in the ELD Provider Portal (you will need to log in with your user account).

Provider Certificates

All providers will need a public/private key pair for their ELDs. The Public/Private Key pair must be compliant with the NIST SP800–32, Introduction to Public Key Technology and the Federal PKI Infrastructure. Key pairs do not have to be unique for individual devices—the same public/private key pair can be used by a provider for all ELD devices. However, each provider must have their own public/private key pair (they may not be shared by providers). Providers must register the public key portion of the public/private key pair registered with their ELD. This is done by submitting a vendor certificate containing the public key. Submitting this certificate is a required step in the ELD registration process (See section 5.2.2).

Providers may purchase a certificate from a certificate authority (CA), or may use a self-signed certificate. When requesting a certificate from a CA or generating a self-signed certificate, providers must make certain the certificate adheres to best practices as detailed in Section 2.2.1 of the ELD Interface Control Document and Web Services Development Handbook.

Providers will use their certificates when:

• Electronically signing emails when submitting ELD data to FMCSA using the email data transfer method (see Section 4.10.1.2).
• Connecting to FMCSA ELD web services to submit ELD data (see Section 4.10.1.1 and 4.10.1.4 (c)). Note: This is a requirement for both web services and Bluetooth data transfer methods.
• Calculating ELD Authentication Values when generating ELD files for all data transfer methods (see Section 5.2.2 and 7.14).

FMCSA will honor the expiration date listed in providers’ certificates. Should an ELD device submit data using an expired certificate, FMCSA will consider the device to be out of compliance with the ELD rule.

To provide your certificate containing your public key to FMCSA:

1) Log into your account.

2) From the left side navigation, select “My ELDs.”

3) Under “Actions,” select “Edit.”

4) Under “Certificate,” select “Choose File” to select and upload your certificate file or files that conform to the best practices as noted in Section 2.2.1 of the ELD Interface Control Document and Web Services Development Handbook.

5) Repeat for each ELD, if necessary.

Question 33: When do electronic logging device (ELD) “power data diagnostic events” and “power compliance malfunctions” occur?

Guidance: “Power data diagnostic events” occur when an ELD is not powered and fully functional within one minute of the vehicle’s engine receiving power and does not remain powered for as long as the vehicle’s engine stays powered. “Power compliance malfunctions” occur when an ELD is not powered for an aggregated in-motion driving time of 30 minutes or more over a 24-hour period across all driver profiles.

Question 34: When do electronic logging device (ELD) “engine synchronization data diagnostic events” and “engine synchronization compliance malfunctions” occur?

Guidance: “Engine synchronization data diagnostic events” occur when an ELD loses ECM connectivity to any of the required data sources (engine power status, vehicle motion status, miles driven, and engine hours) and can no longer acquire updated values for the required ELD parameters within five seconds of the need. “Engine synchronization compliance malfunctions” occur when ECM connectivity to any of the required data sources (engine power status, vehicle motion status, miles driven, and engine hours) is lost for more than 30 minutes during a 24-hour period aggregated across all driver profiles.

Question 35: When does an electronic logging device (ELD) “timing compliance malfunction” occur?

Guidance: A “timing compliance malfunction” occurs when the ELD can no longer meet the underlying compliance requirement to record Coordinated Universal Time (UTC), where ELD time must be synchronized with UTC, not to exceed an absolute deviation of 10 minutes at any time.

Question 36: When does an electronic logging device (ELD) “positioning compliance malfunction” occur?

Guidance: When an ELD fails to acquire a valid position measurement within 5 miles of the commercial motor vehicle moving and 60 minutes has passed, a “position compliance malfunction” will be recorded in the data diagnostic.

Question 37: When does an electronic logging device (ELD) “data recording compliance malfunction” occur?

Guidance: A “data recording compliance malfunction” occurs when an ELD can no longer record or retain required events or retrieve recorded logs that are not kept remotely by the motor carrier.

Question 38: When do electronic logging device (ELD) “data transfer data diagnostic events” and “data transfer compliance malfunctions” occur?

Guidance: A “data transfer data diagnostic event” occurs when the operation of the data transfer mechanism(s) is not confirmed. A “data transfer compliance” malfunction occurs when the ELD stays in the unconfirmed data transfer mode following the next three consecutive monitoring checks.

Question 39: When does an electronic logging device (ELD) “unidentified driving records data diagnostic event” occur?

Guidance: An “unidentified driving records data diagnostic event” occurs when more than 30 minutes of driving time for an unidentified driver is recorded within a 24-hour period.

Question 40: When does an electronic logging device (ELD) “missing required data elements data diagnostic event” occur?

Guidance: A “missing required data elements data diagnostic event” occurs when any required data field is missing at the time of recording.

Question 41: What types of visual indicators must be displayed by an ELD?

Guidance: “Engine synchronization data diagnostic events” occur when an ELD loses electronic control module (ECM) connectivity to any of the required data sources (engine power status, vehicle motion status, miles driven, and engine hours) and can no longer acquire updated values for the required ELD parameters within five seconds of the need. “Engine synchronization compliance malfunctions” occur when ECM connectivity to any of the required data sources (engine power status, vehicle motion status, miles driven, and engine hours) is lost for more than 30 minutes during a 24-hour period aggregated across all driver profiles.

Question 42: In section 4.4.2 of 49 CFR part 395, subpart B, Appendix A, the rule requires that “geo-location information must be derived from a database that contains all cities, towns, and villages with a population of 5,000 or greater and listed in ANSI INCITS 446–2008 (R2013).” What is an example of a database that meets these requirements?

Guidance: USGS maintains the Federal authoritative source of official geographic feature names, known as the Geographic Names Information System (GNIS). Providers can start with the Populated Places dataset, which includes towns and villages of all populations. Therefore, it meets the minimum requirements (locations with populations of 5,000 or greater and listed in ANSI INCITS 446-2008 (R2013). Providers may consider cross-referencing this dataset against another dataset to filter out cities, towns, and villages with a population of less than 5,000. To learn more about the GNIS and the Populated Places dataset, visit https://www.usgs.gov/tools/geographic-names-information-system-gnis.

Question 43: Can a mobile app and the vehicle engine communicate over a cellular network?

Guidance: The ELD rule does not prohibit this type of communication. However, manufacturers should keep in mind that in places without coverage, and without cellular communication, the device may not be able to record or display records of duty status (RODS), which would leave the driver not current to the last duty status change or operating without logs—a violation of the Hours of Service rules.

Question 44: Can the partial vehicle identification number (VIN) value obtained from the controller area network bus be used for reporting?

Guidance: Partial VIN is not permitted. If the VIN cannot be fully obtained from the electronic control module (ECM), it may be entered manually; however, a partial VIN broadcast can be used to aid the driver in entering a manual VIN. Please note:

• Providers are encouraged to use the VIN check digit calculation to help prevent user entry errors.
• A VIN with any level of manual entry must be prefixed by a "-" character in the output file.
• Manual VIN entry cannot be used when the complete VIN can be obtained from the ECM. A device using manual entry when the complete VIN is in fact available from the ECM would not be in compliance with the rule and would be subject to removal from the list of self-certified and registered ELDs.

Question 45: As an electronic logging device (ELD) manufacturer, how can I make sure that my product is compliant?

Guidance: You should review the technical specifications included in 49 CFR part 395, subpart B, Appendix A, along with the FMCSA’s compliance test procedures. You are required to self-certify your device, stating that it is in compliance with all of the technical specifications. The compliance test procedures are designed to assist manufacturers in determining whether their product meets the ELD rule requirements. While ELD manufacturers are not required to use FMCSA’s compliance test procedure, they are required to ensure that their products are compliant with the technical specifications in the ELD rule.

Question 46: When a driver edits an existing electronic logging device (ELD) record, how must the ELD “Event Record Origin” be set?

Guidance: The ELD must set the “Event Record Origin” of the ELD record to “2” (edited or entered by the driver).

Question 47: When a driver manually enters records into an electronic logging device (ELD) how must the ELD “Event Record Origin” be set?

Guidance: The ELD must set the “Event Record Origin” of the ELD record to “2” (edited or entered by the driver).

Question 48: Under section 4.6.1.2 of 49 CFR part 395, subpart B, Appendix A, the engine synchronization compliance monitoring requires the electronic logging device (ELD) to record an engine synchronization diagnostics event when it cannot acquire values for the ELD parameters within 5 seconds of the need. How are these events recorded during the commercial motor vehicle (CMV) power up cycle when the electronic control module (ECM) connection cannot become fully functional within 5 seconds of the engine receiving power?

Guidance: Engine synchronization in section 4.2 of 49 CFR part 395, subpart B, Appendix A, for purposes of ELD compliance, is defined as the monitoring of the vehicle’s engine operation to automatically capture the engine’s power status, vehicle’s motion status, miles driven value, and engine hours value when the CMV’s engine is powered. As described in section 4.3.1.1, the ELD must be powered and become fully functional within one (1) minute of the vehicle’s engine receiving power and must remain powered for as long as the vehicle’s engine stays powered. Additionally, section 4.5.1.6 allows up to one (1) minute for the ELD to establish a link to the ECM or ECM connection and record all the required data elements during the power up event. Therefore, during the power-up cycle, an ELD has one minute to establish the synchronization required by section 4.2 and record the power up event. The specification is designed to capture when the CMV is put into a state where it can be driven. When the engine is not powered, the ELD does not have to capture data. An engine synchronization diagnostic event should not be recorded by the ELD during the power up cycle until one of the following occurs.

• Five seconds elapses after the power up cycle is completed and recorded; or
• Five seconds elapses after the ELD has not established a link to the ECM or ECM connection within one minute of the engine receiving power.

Question 49: Section 4.6.1.6(d) of 49 CFR part 395, subpart B, Appendix A states that “An unidentified driving records data diagnostic event can be cleared by the ELD when driving time logged under the unidentified driver profile for the current 24‐hour period and the previous 7 consecutive days drops to 15 minutes or less.” Does this mean 15 minutes or less in each of the 7 previous days, or does it mean the sum of all unidentified driving time over the previous 7 days totals 15 minutes or less?

Guidance: The aggregate – 15 minutes total. Note that only “unidentified driving records data diagnostic event” can be cleared (in other words, marked inactive). The underlying records that generated the event may not be deleted.

Question 50: What data does the electronic logging device (ELD) need to log when there is an unidentified driver?

Guidance: "When a driver does not log in to the ELD and does not respond to the ELD visual and audible prompts, the ELD must record accumulated driving and On-Duty Not-Driving time in accordance with the ELD defaults (see section 4.4.1 of 49 CFR part 395, subpart B, Appendix A). When more than 30 minutes of driving in a 24-hour period accumulate in the Unidentified Driver profile, the ELD data diagnostic indicator must be turned on across all drivers logged into that ELD for the current day and the following 7 days. Other events that must be associated with the Unidentified Driver profile include the commercial motor vehicle (CMV) engine power up and shut down and power compliance monitoring. The ELD must not allow entry of any information into the ELD other than a response to the login prompt. The Event Log List for the Unidentified Driver Profile may be found in section 4.8.2.1.10."

Question 51: If the unidentified driving time is accepted by the driver, will the electronic logging device (ELD) still show the driving time as unidentified?

Guidance: The original records reflecting unidentified driving will remain, but with an inactive status. When unidentified records are assumed, a new event record(s) for the driver is created using elements of the unidentified driver log(s) and driver input to populate missing elements of the log originally recorded under the unidentified driver profile.

Question 52: Can an electronic logging device (ELD) provider pass the one-minute boot time rule by requiring the driver to power on the device (or an app) prior to starting the engine?

Guidance: Yes. If the ELD is an application on a separate device, the driver must understand that manual power must be on and the ELD application launched prior to starting the vehicle so that the device can recognize the engine start. Failure to start the application would result in the driver operating without an ELD, which would be in violation of the ELD rule.

Question 53: Is it permissible to allow the electronic logging device (ELD) to power up, boot, and accept driver logins before the engine is powered?

Guidance: Yes, this is an acceptable way for ELDs to function. If the ELD is structured such that the device must be powered on and logged in to before the engine is powered to meet the requirements of the ELD rule, this should be made clear to the driver through the device manual and carriers should include this in their driver training.

Question 54: What is a manufacturer required to do when required data is not available from the electronic control module (ECM)?

Guidance: "If the vehicle does not have an ECM or the ECM does not provide all the information required for, it must be acquired using an independent source apart from the positioning services described under sections 4.3.1.6 of 49 CFR part 395, subpart B, Appendix A and must meet accuracy levels laid out in the rule. Global positioning systems (GPS) cannot be used to identify the vehicle’s motion status. Please note that if there is a means for retrieving data from the ECM, the provider is obligated to use that means (for example, using a synthesized odometer or entering into an agreement with an original equipment manufacturer [OEM] to access proprietary information). If the Federal Motor Carrier Safety Administration (FMCSA) is made aware that a provider has chosen not to undertake the effort to secure data from the ECM that is, in fact, retrievable, the device would be considered non-compliant and removed from the self-certified and registered ELDs."

Question 55: If the required electronic logging device (ELD) data from the electronic control module (ECM) is private and requires an agreement with the original equipment manufacturer (OEM) to obtain said data, are ELD providers required to enter an agreement with the OEM?

Guidance: The ELD provider is required to use all means necessary to obtain the required ELD data from the ECM; this may include entering into an agreement with the OEM or another third party. Using manual entry when the ECM is available would not be in compliance with the rule and the device would be subject to removal from the list of self-certified and registered ELDs.

Question 56: If the vehicle does not track engine hours, can the record begin with “0”?

Guidance: If it is not possible to obtain the engine hours from the electronic control module (ECM), then the electronic logging device (ELD) may begin recording engine hours at “0” for the given engine the first time the ELD is used with that engine. After the first use, the ELD must continue to keep and use an aggregate total from the first time it was installed or used with an engine. Ideally, back office systems can share this aggregate total so that any other ELD used with the engine can start at the aggregate total, rather than “0.”

Question 57: Would server-based events (e.g., edits and assignment of unassigned events) generate a different sequence ID than that generated by the electronic logging device (ELD)?

Guidance: The sequence ID must be continuous to its source device. In an ELD support system, that system may have its own sequence ID generator. Because events cannot be deleted, it should be possible to observe each component in the ELD system which generates sequence IDs and find a continuous list of events for each sequence number without any gaps.

Question 58: How should an electronic logging device (ELD) respond to battery issues, such as an ELD battery dying due to high temperatures or when charge power runs out?

Guidance: In cases when the ELD’s battery dies or when the charge power runs out, the ELD must generate a malfunction event. The ELD must set a power compliance malfunction if the power data diagnostics event indicates an aggregated in motion driving time understatement of 30 minutes or more on the ELD over a 24-hour period across all driver profiles, including Unidentified Driver profile.

Question 59: How will FMCSA ensure that the electronic logging device (ELD) data is transferred securely?

Guidance: During data transfers, 49 CFR part 395, subpart B, Appendix A requires additional security protocol through encryption, American National Standard for Information Technology, IEEE Standards Association, and others as incorporated by reference in Appendix A sections 6.

Question 60: In 49 CFR part 395, subpart B, Appendix A Table 6, Event Type 3, it lists “Driver indication for PC, YM, and WT cleared.” What does WT refer to?

Guidance: "WT” refers to “waiting time.” This language is carried over from the draft rule and was included in the final version in error. There are no other references to WT found within the rule.

Question 61: Is there a requirement to indicate odometer or positioning at the beginning and end of a Yard Move category?

Guidance: The position, engine hours, and vehicle miles should be recorded when the yard move starting and ending events are created as specified in sections 4.5.1.3 of 49 CFR part 395, subpart B, Appendix A. (Note: these elements are included by reference as sections 4.5.1.3 indicates all elements defined in sections 4.5.1.1 be included).

Question 62: When creating an electronic logging device (ELD) file as specified in sections 4.9 of 49 CFR part 395, subpart B, Appendix A, which records should be included?

Guidance: Section 4.9.1 of Appendix A requires ELDs to be able to send records for the current 24-hour period and the previous consecutive 7 days for review during a roadside inspection. An ELD must produce a data file or a series of data files of ELD records for a subset of drivers, a subset of vehicles, and for a subset of the 6-month record retention period, to be specified by the safety official—this includes files with 30 days’ worth of records of duty status (RODS). The device user manual should provide instructions on how the driver or carrier can specify the time period for the file being transferred.

Question 63: Is the electronic logging device (ELD) required to retrieve the commercial motor vehicle (CMV) position from the device connected to the port, or can this be retrieved by using a smartphone or tablet?

Guidance: The ELD must have the capability of retrieving and recording position information in compliance with sections 4.6.1.4 of 49 CFR part 395, subpart B, Appendix A. The ELD includes all components required to record, manage, retain, and transfer data so, any component within the ELD may retrieve the location information.

Question 64: In an electronic logging device (ELD) with multiple components, which component must generate the event sequence identifier number?

Guidance: The event sequence identifier number (sequence ID) must be consistently applied as required per section 4.4.4.1 of 49 CFR part 395, subpart B, Appendix A. While the component(s) used to generate the sequence ID is not specified and is left to the discretion of the provider, section 4.4.4.1 requires the sequence ID to be assigned at the time the event is recorded. ELD events must be recorded when they occur, not at a later time using cached data. [Clarification italicized].

Question 65: What duty status change events must be included in the ELD output file for submission to FMCSA during an inspection, investigation, or audit?

Guidance: To provide the required RODS for a roadside inspection, investigation, or audit, the ELD output file must contain the driver’s last duty status change event prior to the requested time period. This will ensure the ELD output file establishes the driver’s duty status at the beginning of the requested period.

For a roadside inspection, section 4.9.1 of 49 CFR part 395, subpart B, Appendix A requires the ELD to produce records for the current 24-hour period and the previous 7 consecutive days in electronic format for review. For a safety investigation or an audit, section 4.9.2 of 49 CFR part 395, subpart B, Appendix A requires the ELD to produce records for any time period within at least the past 6 months at the request of an authorized safety official.

Question 66: Can ELD data be cached to a black box, gateway, or server, and written to an ELD event at a later time?

Guidance: No. Per section 4.3.1.1 of 49 CFR part 395, subpart B, appendix A, an ELD must be powered and become fully functional within one minute of the vehicle’s engine receiving power and must remain powered for as long as the vehicle's engine stays powered. This means that the ELD must be able to record events, including assigning event sequence identifier numbers (sequence IDs) when the events occur. ELD data may not be stored to a black box, gateway, or server and then be written to an ELD event at a later time. If an ELD and all of its required components are not connected and fully functional—including the component that records an ELD event—then those components are no longer in compliance with the requirements outlined in 49 CFR part 395, subpart B, appendix A, because the ELD events would no longer obtain a sequence ID at the time they are recorded.

Question 67: What happens if a registered device listed on FMCSA’s website is later found not to meet the technical specifications in the Electronic Logging Device (ELD) rule?

Guidance: Guidance: The ELD rule includes a procedure to remove a listed registered device from the FMCSA website, to provide additional assurance to motor carriers that ELDs on the vendor registration website are compliant. This procedure also protects an ELD vendor’s interest in its product.

Question 68: How do electronic logging device (ELD) providers register their ELDs with FMCSA?

Guidance: To register and self-certify a device, visit https://eld.fmcsa.dot.gov/Account/Create/Provider.

Question 69: What is the procedure to remove a listed certified electronic logging device (ELD) from FMCSA’s website?

Guidance: FMCSA may initiate removal of an ELD model or version from the list in accordance with section 5.4 in the ELD rule of 49 CFR part 395, subpart B, Appendix A by providing written notice to the ELD provider stating:

1. The reasons the FMCSA proposes to remove the model or version from the FMCSA list; and

2. Any corrective action that the ELD provider must take for the ELD model or version to remain on the list.

Question 70: Why are technical specifications in the Electronic Logging Device (ELD) rule?

Guidance: The technical specifications in the ELD rule ensure that manufactures develop compliant devices and systems for uniform enforcement of hours of service.

Question 71: Will FMCSA allow ELD providers to access the Electronic Record of Duty Status (eRODS) application for use in testing how their electronic logging device’s (ELD) data will display to safety officials?

Guidance: FMCSA has made a web-based version of the eRODS software available for use by motor carriers and ELD providers. Motor carriers and ELD providers may upload an ELD file to see how the hours of service data will be presented to a safety official. Web eRODS is available on the ELD website at https://eld.fmcsa.dot.gov/eRODS.

Question 72: How will the ELD report on-duty not-driving status when the origin of the duty status is automatic instead of driver-input?

Guidance: The ELD will report on-duty not-driving status based on automatic detection, starting from the time the vehicle is no longer in motion.

Question 73: The Event Checksum Calculation describes the individual items to be included in the calculation. Number 9 says “CMV Number.” Is this the CMV VIN or the CMV Power Unit Number?

Guidance: FMCSA showed a CMV number, as an example, in the header output file. The intent was to allow an additional vehicle identification number if an operator had numbered vehicles and chose to add company-assigned numbers to the CMV header data.

Question 74: Is a physical connection between the electronic control module (ECM) and electronic logging device (ELD) required to establish integral synchronization with the engine?

Guidance: No. The ECM and ELD may be connected by serial or Control Area Network communication protocols. Hard wiring to the J1939 plug and Bluetooth® connectivity are examples of methods of receiving the data from the ECM or vehicle data bus.

Question 75: If an electronic logging device (ELD) loses connection to the electronic control module (ECM), how will the device report a system failure?

Guidance: An ELD must use onboard sensors and data record history to identify instances when it may not have complied with the power requirements specified in the ELD rule.

Question 76: Must the manufacturer self-certify and register every version or firmware update to the electronic logging device (ELD)?

Guidance: The manufacture must register each model and version and self-certify that each particular ELD is compliant with the ELD rule. The manufacturer must decide whether a firmware update is sufficiently significant to change the registration information. FMCSA does not specify parameters for version revisions.

Question 77: Are vendors required to update or register each different configuration of hardware, even though the product is the same as an application (app) (e.g., black box and Samsung, black box and iPhone, black box and Nexus)?

Guidance: Vendors should register each device bundle if they have different operating systems (e.g., an iOS-based bundle and an Android-based bundle would be considered two registered devices).

Question 78: Does the registration process require companies to exclusively use FMCSA’s test procedure? Will vendors have access to testing facilities for electronic logging devices (ELDs)?

Guidance: No. ELD manufacturers may use any test procedure they choose and note this in the registration. FMCSA will not provide a third-party testing service. FMCSA will only investigate devices that are suspected of not conforming to specifications, and will conduct testing with the FMCSA compliance test procedure during its investigation.

Question 79: How will commercial motor vehicle (CMV) environmental specifics be tested with the electronic logging device (ELD)—for example, mounting and connections to the electronic control module (ECM)?

Guidance: FMCSA does not specify testing requirements for connectivity with the vehicle. Each ELD provider is responsible for connectivity testing.

Question 80: What is the Event Checksum Calculation?

Guidance: The Event Checksum Calculation is a value associated with each ELD event at the instance of the event record being created. It describes the individual items to be included in the calculation. The individual items included in the calculation are listed in sections 4.4.5.1.1 of 49 CFR part 395, subpart B, Appendix A.