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New and updated ELD FAQs published

On March 10, 2022, to provide additional guidance on the ELD regulations, FMCSA published the following frequently asked questions. To view any of the FAQs below, along with previously published FAQs, visit

New FAQs

Can an electronic logging device (ELD) allow for a user to switch between ELD mode and automatic onboard recording device (AOBRD mode)?

No. A provider may provide an AOBRD for drivers exempt from using an ELD per 49 CFR 395.8(a)(1)(iii), but the AOBRD must be a standalone application on a device, with its own driver account and login, separate from a registered, self-certified ELD operating system.

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

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 the 2020 changes to the new hours of services rules, 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.

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?

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

Updated FAQs

Also on March 10, 2022, FMCSA revised several FAQs. The updated FAQs are below.

What steps must the driver and carrier take if an ELD malfunctions?

  1. The driver must inform their carrier of the malfunction within 24 hours.
  2. The motor carrier has 8 days to repair, service, or replace the ELD. If the malfunction precludes the device from accurately recording hours of service (HOS) data and presenting that HOS data to a safety official, the driver must user paper logs or another system for recording their HOS during this time.
  3. Under 49 CFR 395.34, a motor carrier seeking to extend the time permitted for repair, replacement, or service of one or more ELDs may request an extension. ELD malfunction extensions can be requested by email to You may also contact the field office directly. For more information, see

If a driver is permitted to use a commercial motor vehicle (CMV) for personal reasons, how must the driving time be recorded?

There are two ways authorized personal use (personal conveyance, or “PC”) can be recorded using an electronic logging device (ELD):

  1. If the motor carrier has configured the driver user account to authorize personal use in accordance with 49 CFR 395.28(a), then the driver may use the personal conveyance special driving category to record that time.
  2. If the motor carrier has not configured the device to authorize personal conveyance, the driver may switch to Off Duty and annotate the beginning of personal conveyance period. Once the personal conveyance period has ended, the driver annotates the end event, as well as any events that occurred during that time period.

Can a user edit or change automatically recorded driving time that has been recorded by an electronic logging device (ELD) to non-driving time?

Under sections of 49 CFR part 395, subpart B, Appendix A, automatically recorded drive time when the commercial motor vehicle (CMV) is in motion cannot be edited or changed to non-driving time.

Edits to automatically recorded driving time are acceptable in the following instances:

  1. For team drivers, a driver may edit and reassign driving time records erroneously recorded to their account (see section of Appendix A). The drivers must have indicated each other as co-drivers in their record of duty status (RODS). Each co-driver must confirm the change for the edit to take effect.
  2. A driver may edit or correct driving time erroneously recorded due to failing to change his or her duty status before powering off the CMV, but only if the driving time was recorded by the ELD while the vehicle was powered off and the vehicle was not in motion during the period that is being edited or corrected. The driver edit limitation found in section prohibits the editing of automatically recorded driving time. The intent of the specification that requires automatic recording of driving time is to ensure all movement of the CMV is captured. A CMV cannot be driven while powered off. The driving time following the power off cycle of a CMV not in motion, is not recorded to the specifications required by and and therefore may be edited to the correct duty status.
  3. Driving time assumed from the unidentified driver profile in error may be returned to the unidentified driver profile so that it can be assumed by the correct driver (see section of Appendix A).
  4. Drivers may assume a subset of driving time from the unidentified driver profile. The amount of automatically recorded drive time may not change, but can be split between the driver and the unidentified driver profile so that the remaining time can be assumed by the correct driver.
  5. Drivers may assume driving time from the unidentified driving profile and convert it to Off-Duty (PC) or On-Duty Not Driving (YM) if this is that status that should have been in effect (see section of Appendix A).

As a motor carrier, how can I be sure an electronic logging device (ELD) is compliant?

The motor carrier is responsible for checking that their device is registered, as established in 49 CFR 395.22. Motor carriers should only purchase an ELD that is self-certified by the manufacturer to be compliant and that is registered and listed on the FMCSA website.

The list of registered ELDs can be found at Motor carriers should also familiarize themselves with the ELD checklist and the ELD rule.

In the event that an ELD is removed from the registration list, FMCSA will place the removed device on FMCSA’s Revoked ELDs List.

What procedure should be followed if an electronic logging device (ELD) is replaced or reset?

For a reset or replaced ELD, under 49 CFR 395.8(k), data or documents showing the driver’s record of duty status (RODS) for the current 24-hour period and the previous 7 days must still be retained. These can either be uploaded into the “new” ELD or retained in paper format.

During an investigation, how should the header section reflect electronic logging device (ELD) data?

The header should be populated with the commercial motor vehicle (CMV) data and co-driver data (if applicable) at the end of the report period. The actual date and location information must be reflected as required in the ELD data.

If a Canada/Mexico-domiciled company with a terminal in the United States dispatches a driver from one of its Canada/Mexico locations to move a vehicle to its U.S. terminal for use in the U.S., is the vehicle move considered a drive-away/tow-away operation?

No, because the movement does not meet does not the definition of “drive-away/tow-away operation” in 49 CFR 390.5T.

Additional Updates

The following questions and answers have received minor wording updates. These changes did not alter the substance of the information. Click the links below to read the full revised questions and answers.

Are Canada- and Mexico-domiciled drivers required to use electronic logging devices (ELDs) when they are operating in the United States (U.S)?

Read the answer

What is the process for transferring data via email?

Read the answer

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

Read the answer

Does the size requirement for print display listed in section of 49 CFR part 395 subpart B Appendix A also apply to the on-screen display?

Read the answer

Is the display required to be handed to the inspector outside of the vehicle?

Read the answer

Section 4.9.1 of 49 CFR part 395, subpart B, Appendix A states than an electronic logging device (ELD) must support either telematics or local transfer for data transfer. Can an ELD offer web services and USB transfer?

Read the answer

What is the resolution process if the FMCSA data transfer mechanism incorrectly rejects a data file during an electronic data transfer?

Read the answer

To ensure that the list of self-certified electronic logging devices (ELDs) is current, ELD providers must notify FMCSA of any major changes to their device. What constitutes a major change to an ELD?

Read the answer

These FAQs and more are on the ELD website at:



As always, you can count on the commercial truck insurance professionals at The Daniel & Henry Company to assist you through challenging claims and all of our insurance, risk management, and safety issues. Contact us today to discuss solutions for your transportation risk management program.


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