Electronic Logging Device (ELD) Implementation
The Commercial Vehicle Safety Alliance (CVSA) and law enforcement around the United States will begin enforcing the electronic logging device (ELD) mandate requirements on Dec. 18, 2017. The out-of-service criteria (OOSC) associated with the ELD mandate will go into effect on April 1, 2018.
The Federal Motor Carrier Safety Administration’s (FMCSA) congressionally mandated ELD compliance deadline is still set for Dec. 18, 2017.
On that date, inspectors and roadside enforcement personnel will begin documenting violations on roadside inspection reports and, at the jurisdiction’s discretion, will issue citations to commercial motor vehicle drivers operating vehicles without a compliant ELD. Beginning April 1, 2018, inspectors will start placing commercial motor vehicle drivers out of service if their vehicle is not equipped with the required device. Please note, a motor carrier may continue to use a grandfathered automatic onboard recording device (AOBRD) no later than Dec. 16, 2019. The AOBRD must meet the requirements of 49 C.F.R. 395.15.
This announcement does not impact enforcement of the OOSC for other hours-of-service violations.
CVSA supports moving forward with the compliance date as specified in the rule. However, setting an April 1, 2018, effective date for applying the ELD OOSC will provide the motor carrier industry, shippers, and the roadside enforcement community with time to adjust to the new requirement before vehicles are placed out of service for ELD violations.
What Do I Need to Know?
The ELD Rule applies to most motor carriers and drivers who are currently required to maintain records of duty status (RODS). The rule applies to commercial buses as well as trucks. Canada- and Mexico-domiciled drivers are included unless they qualify for one of the exceptions to the ELD rule.
ELD Rule Exceptions
The following are not required to use ELDs (but carriers may choose to use ELDs even if they are not required):
- Drivers who use paper logs no more than 8 days during any 30-day period.
- Driveaway-towaway drivers (where the vehicle driven is the commodity) or the vehicle being transported is a motorhome or a recreation vehicle trailer (at least one set of wheels of the vehicle being transported must be on the surface while being transported)
- Drivers of vehicles manufactured before model year 2000.
What Do I Need to Do?
Carriers must evaluate and select ELDs, and ensure they are installed and drivers and administrative staff are trained to use them by the deadline that applies (December 16, 2019 for carriers using AOBRDs or December 18, 2017) for those using paper logs or logging software.
Drivers must understand and be able to use ELDs by the required deadline, including how to annotate and edit RODS, certify RODS, and collect required supporting documents. You will also need to know how to display and transfer data to safety officials when requested.