The Commercial Vehicle Safety Administration (CVSA) recently issued an Inspection Bulletin for hand-held and electronic logging devices (ELDs). Make sure you know what your ELD needs to do and what to do if your device malfunctions.
CVSA Inspection Bulletin Issued
The majority of drivers and inspectors still have a lot of questions around ELD inspections despite ELDs being manadated for the majority of drivers in the U.S. as of December 17, 2017. The CVSA recently issued a bulletin to review the requirements for devices used to record a driver’s hours-of-service (HOS) according to 49 CFR Part 395 Subpart B. We’ve broken it down for you to make sure you pass your next inspection with ease. A complete copy of this Inspection Bulletin can be found here.
The way that commercial motor vehicle (CMV) drivers record their HOS has changed significantly in the last year due to the ELD mandate. Here are the ways that you are able to log and be considered compliant:
- Electronic Logging Device (ELD): On December 18, 2017, the majority of CMV drivers, including passenger-carriers, were mandated to use ELDs to record their HOS (if previously using paper or an electronic logbook). If you enter the transportation industry after December 18, 2017, and are required to keep a record of duty status (RODS), you must install an ELD in your vehicle.
- Automatic Onboard Recording Device (AOBRD): If you were using an AOBRD before December 18, 2017, you can continue to use it until December 16, 2019 before transitioning to an ELD. This is known as the AOBRD grandfather clause. The majority of drivers that we deal with took advantage of this clause.
- Electronic Logbook and Paper Logs: If you qualify for an exemption, you can use an electronic logbook or paper logs to track your HOS. These methods alone are no longer a compliant form of logging for those required to comply with the ELD mandate. Visit this post on the BigRoad Blog to learn more about ELD mandate exemptions.
At minimum, your ELD needs to display the following items: annotations, driver's location description, CMV power unit number, trailer number (if applicable), and shipping document number (if applicable). You are also required to show some specific location information including distance and direction from the nearest city. You are eligible to use location codes in lieu of actual names. When doing this, a list of codes must be carried in the CMV and provided to the enforcement official upon request.
Similar to paper logs and electronic logbooks, you need to display the following information on your graph grid:
- Total hours (in your working day so far)
- Off duty time including personal conveyance
- Sleeper berth time
- Driving time
- On duty, not driving time including yard move
What Is Reviewed During a Roadside
When conducting a roadside inspection, the following items need to be reviewed by the inspector when the driver is using an ELD:
- Verify that the ELD is integrally synchronized to the CMV
- Ensure the ELD can display RODS for last 7 days, plus current day
- The driver can produce an instruction sheet for the ELD
- The driver has blank paper logs to record their duty status and other information for a minimum of 8 days if there is an issue with the device
- The driver can demonstrate the use of the device
- The ELD can display or print a copy of the RODS at time of inspection
When requested, the driver must produce their HOS records via electronic data transfer (telematics or local), on the display screen of the ELD, or printed from the ELD. It’s important to note that a device that is unable to print a copy of the driver’s RODS is not a violation if the device is able to display an HOS chart or electronic display of each duty status change for the current day and the previous seven days.
What Do I Do If My ELD Malfunctions?
If your ELD malfunctions, you must provide written notice of the malfunction to your motor carrier within 24-hours. If you cannot
access any logs, you will need to recreate your RODS for the current 24-hour period and previous seven days to comply with 395.8. You are required to keep blank paper logs in your vehicle in case you have a malfunction. Complete instructions on what to do during a malfunction can be found on the BigRoad ELD Driver Card and Malfunction Guide.
How Can BigRoad Help?
BigRoad’s DashLink ELD is the #1 choice for ELD mandate compliance. Over 40,000 fleets have already selected BigRoad to help them achieve compliance. Request a demo to see our solution in action today!