Electronic Logging Devices

The Canadian ELD Mandate is a Final Rule released by Transport Canada requiring federally regulated carriers to equip certain commercial motor vehicles with a third-party certified ELD. Federally regulated carriers are those providing extra-provincial transportation and U.S.-based motor carriers operating in Canada. Covered vehicles include those registered at a gross vehicle weight greater than 4,500 kg and currently require the driver to use a logbook. Basic HOS rules did not change with the mandate.

Last updated: 06/01/2021

The amendments to the regulations mandate the use of ELDs by drivers who are federally regulated and currently maintaining a daily log. If a driver is currently operating in compliance with a specific province or territory's regulatory requirements, there would be no change.

Last updated: 06/01/2021

Yes. The Canadian HOS regulations have been amended to require the motor carrier to ensure that each commercial vehicle that it operates carries an ELD information packet containing a current version of the following documents:

(a) a user's manual;

(b) an instruction sheet for the driver describing the data transfer mechanisms supported by the ELD and the steps required to generate and transfer the data with respect to the driver's HOS to an inspector;

(c) an instruction sheet for the driver describing the measures to take in the event that the ELD malfunctions; and

(d) a sufficient number of RODS to allow the driver to record the information required under section 82 for at least 15 days.

Regulations: Section 77(7)

Last updated: 06/23/2021

The ELD technical standards are not clear on this subject other than to say "the driver must confirm the operating zone change." Some ELDs (including those from Omnitracs) will automatically detect zone crossings and store the data until the driver acknowledges the event. At that point, the zone change will be inserted into the driver's log at the date, time, and GPS location where the zone change actually occurred.

Last updated: 06/01/2021

No. The ELD is not required to function if the vehicle is not powered; however, if a driver is required to use an ELD to maintain RODS, the driver must use the ELD to capture all duty status change events. The ELD may provide the option for the driver to use some ELD functionalities when away from the vehicle.

Last updated: 06/01/2021

While Transport Canada has included language in the new ELD regulations that would prevent the driver from doing this, the CCMTA has not developed the technical standard on accurately including additional hours not in the ELD. The requirement for the ELD to allow for entry of additional hours not in the ELD has been removed from the testing regime for certification. We have received confirmation drivers will be allowed to provide a mixture of records to complete the entire 14-day cycle at roadside until the CCMTA provides the correct technical specifications and Transport Canada clarifies the timing for its implementation into the ELD and the subsequent re-certification testing requirements. Regulations: Section 77(5)(f)&(h)

Last updated: 06/23/2021

A motor carrier must assign only one ELD driver account for each of its drivers required to use an ELD. An ELD must not allow the creation of more than one driver account associated with a driver's license for a given motor carrier. The motor carrier is also responsible for establishing requirements for unique user identifications and passwords.

Regulations: Section 78.1(a)&(b)

Last updated: 06/23/2021

The amendments to the regulations mandate the use of ELDs by drivers who are federally regulated and currently maintaining a daily log. If a driver is currently operating in compliance with a specific province or territory's regulatory requirements, there would be no change.

Last updated: 06/01/2021

Yes, an ELD must be integrally synchronized with the engine of the commercial motor vehicle. Engine synchronization means monitoring engine operation to automatically capture the engine power status, vehicle motion status, miles driven, and engine hours. 

Last updated: 06/01/2021

No, there is no requirement for the ELD to be hard-wired to the ECM. It is simply required to have a connection to the ECM. That may be accomplished in both wired and wireless modes.

Last updated: 06/01/2021

An ELD records location data at 60-minute intervals when the driver powers the vehicle on and off, begins driving the vehicle, changes duty status or operating jurisdiction, and indicates personal use or yard moves.

Updated: 06/01/2021

Yes. An ELD can be on a smartphone or other wireless device if the device meets ELD technical specification standards.

Updated: 06/01/2021

The Canadian ELD Mandate is a Final Rule released by Transport Canada that effectively replaces paper logs and requires federally regulated carriers to equip their vehicles with compliant, third-party certified ELDs. It was released on June 13, 2019. ELD devices in Canada must be 1) compliant with Technical Standards, which are compliance standards published in the Canadian ELD Mandate, and 2) be certified by an accredited third party. The amended regulations can be found here.

Updated: 06/01/2021

Each province and territory determines if, when, and how the Canadian ELD Mandate will impact intra-provincial carriers. I suggest you keep current on adoption information by checking in with your province's regulations regularly.

Updated: 10/04/2022

The effective date for the Canadian ELD Mandate is still June 12, 2021. On March 2, 2021, the Canadian Minister of Transportation announced a phased enforcement period that will begin with awareness and education only. Two months later, the CCMTA stated jurisdictions should consider the education and awareness component through June 12, 2022. Early in 2022, CCMTA changed the ELD enforcement date to January 1, 2023. The notice can be found here.

Updated: 10/04/2022

ELD software can be on a smartphone, tablet, portable device, or another wireless device as long as the software meets technical standards laid out in the U.S. and Canadian ELD Mandates. Any driver using a portable ELD must mount it in a fixed position visible from their normal seated position. It must remain mounted for the entirety of the time the driver is operating the vehicle.

Updated: 06/01/2021

Yes. An ELD must provide a mechanism for a driver to obtain a copy of the driver's own ELD RODS in electronic or print form. The driver must not be required to go through a motor carrier to obtain a copy of their RODS if they reside or are directly accessible through the ELD.

Updated: 06/01/2021

An edit is a change to an ELD record that does not overwrite the original record, while an annotation is a note related to a record, update, or edit that a driver or authorized support personnel may input to the ELD. All edits, whether made by a driver or the motor carrier, must be annotated to document the reason for the change. For example, an edit showing time being switched from "off duty" to "on-duty not driving" could be annotated by the carrier to note, "Driver logged training time incorrectly as off duty." This edit and annotation would then be sent to the driver for approval.

Updated: 06/01/2021

Both the driver and authorized carrier staff can make limited edits to an ELD record to correct mistakes (other than automatically recorded drive time) or add the missing information. All edits must include a note (annotation) to explain the reason for the edit. In addition, motor carriers are only able to suggest edits to certified logs, and the driver must confirm that any carrier edit is accurate and re-certify the log. If the driver chooses not to re-certify RODs, this is also reflected in the ELD record. The ELD must keep the original, unedited record, along with the edits. Example: A carrier edits a record to switch a period of time from "off-duty" to "on-duty not driving", with a note that explains "Driver logged training time incorrectly as off-duty". The edit and annotation are sent to the driver to verify. The edit is not accepted until the driver confirms it and resubmits the RODS.

Regulations: Section 78.3(1)&(2)

Updated: 06/23/2021

The regulations require the driver to certify their RODS after recording the last duty status change for the day. The ELD will prompt the driver with a reminder of this requirement. When a driver certifies their RODS, the ELD creates an event capturing the date and time the log was certified. This event becomes part of the driver’s ELD record and is visible to anyone authorized to review the driver’s RODS.

Regulations: Section 78.2

Updated: 06/23/2021

Yes, a driver visiting from Mexico and operating in the U.S. or Canada must use a certified ELD in order to remain compliant with U.S. and Canadian federal regulations.

Updated: 06/01/2021

Drivers can use paper logs if: 1) the driver is not required to keep RODS; 2) the vehicle being driven meets a specific exemption from the ELD regulations, or: 3) the ELD is malfunctioning. If the ELD is malfunctioning, the driver can also use an electronic recording device to maintain their RODS.

Updated: 06/01/2021

An ELD must only allow the driver to input information when the vehicle is stationary and the driver is not under an on-duty driving status.

Updated: 06/01/2021

Using one account for multiple ELD users is not acceptable. If a driver is performing a road test for example, unless the driver performing the road test has logged into the ELD with their own login, they should allow for the device to record an unidentified driving event. The administrator can later provide clarification the vehicle movement remains unassigned and include the reason as a "mechanic low-speed yard move."

Updated: 06/01/2021

Drivers will be required to maintain RODS indicating the DOT number they worked under for each day and will be required to present 14 previous days plus the current day's RODS at a roadside inspection. This includes the records on the ELD in use at the time of the roadside inspection and the RODS from all non-compatible ELDs in either paper or electronic format necessary to fulfill the 14 previous day requirement.

Updated: 06/01/2021

Different users may authenticate into the same ELD. The ELD is specific to a vehicle, not a driver. Once authenticated as an authorized user of the ELD, the driver's logs previously recorded using a compatible ELD will be loaded onto the current ELD.

Updated: 06/01/2021

In order to ensure the ELD captures all vehicle power-up events, drivers should allow the ELD to become fully functional and log into the ELD before cranking the engine. At the conclusion of a drive segment, drivers should always select the appropriate duty status to indicate the desired non-driving duty status in order to preserve available drive time and prevent the possibility of being locked into an erroneous drive segment. After the driver's non-driving duty status is displayed on the ELD, the driver should power down the vehicle and log out of the ELD. After fully logging out, the battery disconnect switch may be engaged if equipped.

Updated: 7/2/2021

While not required, the motor carrier can include an ELD support system that allows drivers to make edits to ELD data when away from the ELD. Otherwise, the driver must return to the ELD and make edits.

Updated: 7/2/2021

An ELD must not allow the creation of more than one driver account associated with a driver’s license for a given motor carrier. For an owner-operator, the same person may have two accounts: a) a driver account for logging HOS and b) a supporting personnel account for managing the backend.

Updated: 7/2/2021

Yes, the ELD must allow the driver to review, edit, and annotate their ELD records to account for errors and omissions. ELD Technical Standards: Section 4.3.2.8

Updated: 7/2/2021

The final rule allows for carriers, using their support personnel accounts, to propose changes to a driver's certified ELD logs. To protect the driver's logs from manipulation, edits requested by anyone or any system other than the driver must require the driver's electronic confirmation or rejection.

Regulations: Sections 78.3(1)&(2)

Updated: 7/2/2021

Yes:

A) Events of type 2 (intermediate log), 5 (login/logout), 6 (CMV power-up/shut-down), or 7 (malfunction/diagnostic) may not be edited in any way. This includes an assumption of logs from the unidentified driving profile.

B) If a driver assumes unidentified driving time, the automatically generated change in duty status events would be associated with the driver, but any intermediate log events would not.

C) Edits that reduce the total amount of automatically recorded driving time recorded by the ELD are not allowed. The unidentified driving time may be transferred to a driver, and driving time may be transferred between drivers in a team driving scenario, but driving time may not otherwise be re-assigned or changed to another status and may never be cumulatively changed.

ELD Technical Standards: Section 4.3.2.8.2

Updated: 7/2/2021

No, the annotations made by the driver or the motor carrier will be used by safety officials to help determine if a HOS violation has occurred. Annotations cannot impact any automatically recorded driving time.

Updated: 7/2/2021

This distance is not specified in order to account for the variety in size of screens. The safety official must be able to read the screen display without having to physically enter the cab of the CMV. This means any tethered device should have sufficient cabling to allow the device to be passed to the safety official outside of the cab without a requirement to leave the ground. ELD Technical Standards: Section 4.8.1.2

Updated: 7/2/2021

The display must be designed so that it can be reasonably viewed from outside the cab of the vehicle. That may require the device to be untethered from its mount or connected in a manner that would allow it to be passed outside of the vehicle for a reasonable distance.

Updated: 7/2/2021

Yes. However, the ELD must comply with the ELD Technical Standards.

Updated: 7/2/2021

Yes. If the US destination is within the 160 km radius of the driver's home terminal and the driver returns to the home terminal each day to begin a minimum of 8 consecutive hours of off-duty time, then the driver is not required to use an ELD or maintain a RODS.

Updated: 7/2/2021

No. Vehicle location information is not precise enough to identify street addresses. For each duty status change, the ELD must convert the 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 provincial abbreviation.

Updated: 7/2/2021

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

Updated: 7/2/2021

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 RODS, an ELD provides a more accurate accounting of a driver's 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.

Updated: 7/2/2021

If there are cellular network limitations that prevent the ELD from transferring the ELD data output file via email, the safety official will use the ELD's display screen or printout to verify compliance with the current HOS regulations.

Updated: 7/2/2021

No. The ELD rule prohibits multiple driver accounts for one driver. The motor carrier must proactively change the driver's status to and from exempt and non-exempt.

Updated: 7/2/2021

You can find the Canadian ELD Regulations here and the Technical Standards here.

Updated: 7/2/2021

No. The Engine Control Module (ECM) and ELD may be connected by serial or control area network communication protocols. Hardwiring to the J1939 plug and Bluetooth connectivity are examples of methods of receiving the data from the ECM or vehicle data bus.

Updated: 7/2/2021

No. The regulations only allow for a driver to move to paper logs in the event the ELD has malfunctioned in accordance with the ELD Technical Standards. In this case, the driver must annotate the ELD log explaining the error. If appropriate, the safety official will recalculate the driver's hours to determine compliance with the current HOS regulations. The driver's available duty/drive time clocks will only reset as a result of a compliant/corresponding reset.

Updated: 7/2/21

If the driver is unable to transfer the RODS electronically for any reason, the enforcement officer will use the display to review the driver's RODS. Only the enforcement official can determine if there is a violation of the requirement for the driver to transfer the logs electronically.

Updated: 06/01/2021

An ELD can produce and transfer ELD data records for the current 24-hour period a driver is operating a vehicle and the previous 14 consecutive days. An ELD must be capable of electronically transferring an ELD output data file to an authorized safety official by email. In addition to email transfer, it may also optionally transfer local data via USB or Bluetooth. Omnitracs provides only the email transfer option.

Updated: 06/01/2021

For a Canadian ELD, the output file includes both an uneditable PDF and a CSV file to be sent in an encrypted e-mail to enforcement.

Updated: 06/01/2021

On March 2, the Canadian Minister of Transport, the Honorable Omar Alghabra, released a statement on newly formed enforcement procedures around the Canadian ELD Mandate. The mandated deadline remains as June 12, 2021. However, the government will begin a phased enforcement rollout after the deadline that focuses on education and awareness at first. Therefore, there will be no enforcement penalties at the start of the mandate and during the education and awareness phase. On May 5, 2021, CCMTA suggested provinces and territories assess no penalties until June 12, 2022. Early in 2022, CCMTA changed the ELD enforcement date to January 1, 2023. The notice can be found here. However, each province and territory will create its own strategy that will be adopted into its commercial vehicle driver regulations.

Updated: 10/04/2022

The enforcement officer will review the driver's RODS to verify compliance with Canadian HOS regulations. The officer can review the RODS on display if the driver has a printout. The enforcement officer can also request a driver transfer their RODS electronically using the ELD output file as specified in the technical standards. The ELD will report all relevant information and data elements required for that current 24-hour period and the previous 14 consecutive days.

Updated: 06/01/2021

Fines and points will only begin after enforcement of the ELD requirement goes into effect. Once we have reached that point in the enforcement strategy, fines for not having a vehicle equipped with a third-party certified ELD will be the responsibility of the motor carrier. If the motor carrier has not complied with the regulatory requirements, it is not likely possible to fight the related citation.

Updated: 10/04/2022

Canada does not have the equivalent federal ELD exemption as the US Livestock Carrier or Agricultural Exemption. Drivers subject to the mandate in Canada (which includes all drivers crossing the border) will be subject to federal regulations in Canada.

Updated: 06/01/2021

The Canadian ELD Mandate does not change HOS regulations. Driver's remain subject to the same driving and duty status limitations and exceptions.

Regulations: Section 76(1)-(4)

Updated: 06/23/2021

A motor carrier shall ensure that each commercial vehicle that it operates is equipped with an ELD that meets the requirements of the technical standard. The motor carrier shall ensure that the ELD is mounted in a fixed position during the operation of the commercial vehicle and is visible to the driver when the driver is in the normal driving position, with the exception of commercial vehicles that are: (a) operated by a motor carrier under a permit; (b) operated by a motor carrier to which an exemption has been issued under the Act; (c) the subject of a rental agreement of no longer than 30 days that is not an extended or renewed rental of the same vehicle; or (d) manufactured before the model year 2000.

Regulations: Section 77(1)(a)-(d)

Updated: 06/23/2021

The 160km air radius concept exempts a driver from maintaining RODS. The motor carrier may still have a requirement for that driver to use the ELD as an exempt driver. Anytime the driver fails to qualify under the 160km air radius exception, RODS must be maintained using an ELD, unless one of the ELD exemptions are met. Drivers who qualify for the short-haul exception will be allowed to cross the U.S.-Canadian border but must not violate the HOS regulation in effect for the jurisdiction in which they are operating.

Regulations: Section 77(3)

Updated: 06/23/2021

No such exemption exists in Canada. If the driver does not qualify under any of the four exemptions in the Canadian ELD Mandate or fails to meet the requirements of the short-haul exemption for maintaining RODS, the driver will be required to use the ELD to record their RODS.

Updated: 06/01/2021

Unless the highway truck qualifies for one of the four ELD exemptions, the vehicle must be equipped with an ELD. The 160km air radius concept exempts a driver from maintaining RODS. The motor carrier may still have a requirement for that driver to use the ELD with an exempt driver status. Anytime the driver fails to qualify under the 160km air radius exemption, RODS must be maintained using an ELD.

Updated: 06/01/2021

No. While Transport Canada has made amendments to HOS regulations in order to define compliance rules more clearly, HOS limits still remain the same for regulated carriers in Canada.

Updated: 06/01/2021

Both members of the team must be logged into the ELD. One log will be the primary (driver), and the other will be the co-driver. The ELD is capable of separately logging the activities of team drivers.

Updated: 06/01/2021

While Transport Canada has included language in the new ELD regulations that would prevent the driver from doing this, CCMTA has not developed the technical standard on accurately including additional hours not in the ELD. The requirement for the ELD to allow for entry of additional hours not in the ELD has been removed from the testing regime for certification. We have received confirmation drivers will be allowed to provide a mixture of records to complete the entire 14-day cycle at roadside until CCMTA provides the correct technical specifications and Transport Canada clarifies the timing for its implementation into the ELD and the subsequent re-certification testing requirements.

Updated: 06/01/2021

Yes. ELDs in Canada must be programmed with the capability to provide drivers with a 30-minute warning when reaching any driving or duty status limit.

Updated: 06/01/2021

No. The HOS regulations do not change in Canada because of the ELD requirement.

Updated: 06/01/2021

In the event the ELD malfunctions and the malfunction continues without the ELD self-correcting, a motor carrier shall repair or replace the ELD. The motor carrier must replace the ELD:

a) within 14 days after the day on which the carrier was notified of the ELD malfunction by the driver or otherwise became aware of it, or

b) upon return of the driver to the home terminal from a planned trip, if that return exceeds the 14-day period.

Regulations: Section 78(5)

Updated: 06/23/2021

No. There is no requirement for the motor carrier to perform any tests. The ELD must self-monitor and report to the driver when the device is experiencing a diagnostic or malfunction event.

Updated: 06/01/2021

An ELD that shows it is experiencing a malfunction is not necessarily considered a "defective" device. However, a malfunction requires drivers and motor carriers to take specific actions as outlined in the regulations. A driver will be required to discontinue the use of an ELD that has malfunctioned and begin keeping logs using paper or an electronic recording device. This is true regardless of if or how the malfunction has impacted the ability of the ELD to accurately record the driver’s RODS.

Regulations: Sections 78(1)-(7)

Updated: 06/23/2021

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.

Updated: 7/2/2021

Section 4.6.1.6(d) states that "An unidentified driving records data diagnostic event can be cleared by the ELD when driving time recorded under the unidentified driver profile for the current day and the required previous days specified in current HOS regulations drops to 15 minutes or less."

This means 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.

Updated: 7/2/2021

No. Requirements specified in the Canadian ELD Standard are aligned with those in the U.S. Final Rule for interoperability on both sides of the border. However, the Canadian ELD Standard includes additional requirements to comply with current HOS regulations in Canada. Current Omnitracs ELDs will require a software update and certification by an accredited third-party entity.

Updated: 06/01/2021

The cost for device certification is contracted between the ELD provider and the accredited body. Neither Transport Canada nor the CCMTA has anything to do with the cost to certify an ELD device. The cost to obtain the certification is approximately 50,000 USD per device submitted for certification.

Updated: 06/01/2021

Transport Canada requires all ELDs to be certified for use by an accredited third party. Motor carriers must ensure that their ELDs of choice have passed the third-party certification requirement before committing to an ELD for their fleet.

Updated: 06/01/2021

Along with Omnitracs, several ELD providers have undertaken the certification process with FPInnovations, leading to a number of devices in the queue to be tested. Many procedural processes must be complete before the testing begins. Once the device testing starts, it is expected to take four to six weeks for FPInnovations to complete its testing. If technical standards compliance issues are found with a device during testing, additional time is necessary to correct the issue(s), and retesting will take place.

Updated: 06/01/2021

Once the certification has been achieved, an ELD Registration ID will be provided by the accredited body certifying the device. That ID will be embedded into the ELD software via an over-the-air update. The ELD will also be listed on the Transport Canada ELD website.

Updated: 06/01/2021

The ELD provider is responsible for obtaining third-party certification of the ELD to be used in Canada. Motor carriers are required to equip commercial motor vehicles with ELDs that have received certification.

Updated: 06/01/2021

Yes, we are very confident.

Updated: 06/01/2021

There are currently three certifying bodies:

• FPInnovations, as of October 26, 2020
• CSA Group, as of June 14, 2021
• COMDriver Tech, as of July 22, 2021

Updated: 7/23/2021

Unless the driver moving the vehicle in the yard has logged into the ELD with their own login, they should allow for the device to record an unidentified driving event. The administrator can later provide clarification the vehicle movement remains unassigned and include the reason as a "low-speed yard move."

Updated: 06/01/2021

HOS regulations in both the United States and Canada prevent the editing of automatically recorded drive time. This includes a prohibition against shortening, changing to a non-driving status, or reassigning to anyone other than an authenticated co-driver in a team driving situation. Per the HOS regulations, drivers and motor carriers are limited to annotating the driving events recorded on a driver's log if they are deemed incorrect or in error. It is important for drivers to carefully think about the intention of the vehicle movement before beginning to drive. If a driver has not selected personal conveyance or yard move prior to the vehicle being moved, automatically recorded driving time will be recorded at 8 km/h. This drive time cannot be changed to personal conveyance or yard move. Likewise, if a driver fails to log out of the ELD and another driver moves the vehicle, that drive time will be recorded for the wrong driver, and it cannot be reassigned to any other driver. ELD Technical Standards: Section 4.3.2.8.2(b)&(c)

Updated: 06/23/2021

Once the vehicle has been stopped for three seconds, a five-minute timer starts. Unless the vehicle is moved or the driver manually selects another duty status, a prompt will appear after 5 minutes. The prompt will ask the driver to confirm a change to on-duty, not driving. If the driver does not move the vehicle and one additional minute passes without the driver's confirmation, the driver is automatically placed on on-duty, not driving. The certification testing regime for Canada requires the placement of the on-duty, not driving status at the point of the duty status change, regardless if it is manual or automatic. Drivers should make every effort to manually change their status from drive to on-duty, not driving if they have concluded the driving segment to prevent the loss of drive-time availability.

Updated: 06/01/2021

Per Transport Canada, "If a motor carrier authorizes a driver to operate a commercial vehicle for yard moves within a terminal, depot, or port and that is not on a public road, the motor carrier shall ensure that the driver's ELD has been configured so that the driver can indicate those moves." If a yard move is indicated before moving a vehicle, the driver will automatically transition to drive when the vehicle exceeds 32 km/h. There is no distance limitation. Additionally, if the driver had previously indicated the use of yard move and if the vehicle goes through a complete power cycle (power-down followed by a power-up), the ELD is required to prompt the driver to confirm the continued use of yard move. If the driver fails to respond to the prompt and begins moving the vehicle, the driver will be automatically switched to drive, which cannot be edited. Regulations: Section 77(4)

Updated: 06/23/2021

An ELD must automatically switch to a driving status once the commercial vehicle is moving at eight km/h. HOS regulations in both the United States and Canada prevent the editing of automatically recorded drive time. This includes a prohibition against shortening, changing to a non-driving status, or reassigning to anyone other than an authenticated co-driver in a team driving situation.

ELD Technical Standards: Section 4.4.1.1

Updated: 06/23/2021

Commercial drivers operating in Canada can only go 75 kilometers/46 miles in a 24-hour period while traveling under personal conveyance. Once they exceed that driving time, their personal conveyance status will automatically switch to an on-duty, driving status. There are other limitations within the HOS regulations when using personal conveyance. Drivers should be familiar with the full regulatory requirements of personal conveyance in Canada.

Updated: 06/23/2021

Unless the driver performing the road test has logged into the ELD with their own login, they should allow for the device to record an unidentified driving event. The administrator can later provide clarification the vehicle movement remains unassigned and include the reason as a "mechanic road test."

Updated: 06/01/2021

When a driver does not log into the ELD and does not respond to the ELD visual and audible prompts, the ELD must record accumulated driving and non-driving time in accordance with the ELD defaults. 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 14 days. Other events that must be associated with the unidentified driver profile include the CMV engine power up and shut down, power compliance monitoring, and intermediate log events. ELD Technical Standards: Section 4.6.1.6(c)

Updated: 7/2/2021

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.

Updated: 7/2/2021

The rejected unidentified driving events must remain available for review at roadside for the current day and the previous 14 days and are included in the ELD output files.

Updated: 7/2/2021

Yes, the ELD is required to automatically change a driver's duty status to driving when the vehicle reaches the 8 km/h threshold or less after being in the sleeper berth duty status.

Updated: 7/2/2021

If a driver forgets to select special driving categories (personal conveyance or yard move) at the beginning and/or end of the special driving category, then the driver can make an annotation in the ELD record identifying the start and end of the special driving category. The ELD rule does not allow automatically recorded driving time to be shortened for the purpose of correcting special driving category selections.

Updated: 7/2/2021

No, this is not permitted under ELDs. The device can use geofencing to prompt the driver to change their duty status, but it cannot change the duty status automatically.

Updated: 7/2/2021

Yes, a driver can be assigned unidentified driving records under the unidentified driver profile and indicate a special driving condition (yard move or personal conveyance). However, an ELD must not allow the automatically recorded driving time to be shortened or altered in any way.

Updated: 7/2/2021

Yes, a driver can edit their record after erroneously accepting a driving event that was originally recorded under the unidentified driver profile. The ELD must prompt the driver to annotate edits. In addition, the carrier can suggest the edit to the driver's certified ELD logs, which can be routed to the driver for confirmation.

Updated: 7/2/2021

A motor carrier must either explain why the time is unassigned or assign the time to the appropriate driver. The motor carrier must retain unidentified driving records for at least six months as part of its HOS and ELD records and make them available to authorized safety officials.

Updated: 7/2/2021

The U.S. ELD Mandate is a federal government regulation that requires commercial drivers to use ELDs to record their Hours of Service (HOS). The Mandate has also established ELD performance and design standards, requires ELDs to be certified and registered with the Federal Motor Carrier Safety Administration (FMCSA), and establishes supporting documents drivers and carriers are required to keep with them. It also formally prohibits driver harassment regarding ELD data or connected technology and offers assistance to drivers who believe they are victims of harassment.

The FMCSA published the Final Rule on ELDs on December 16, 2015. The Mandate required commercial motor vehicle drivers to use either grandfathered AOBRDs or ELDs by December 18, 2017. The use of grandfathered AOBRDs was permitted for interim use during the following two years. As of December 16, 2019, all commercial motor carriers required to comply with the U.S. ELD Mandate must be using ELDs.

All commercial drivers driving in the U.S. required to maintain RODS must comply with the Mandate unless they have special permissions granted through a temporary waiver or exemption from the FMCSA.

Per the Mandate, the following persons are not required to use ELDs:

• Drivers who use paper logs no more than eight days during any 30-day period
• Driveaway and towaway drivers transporting vehicle commodities, motor homes, recreational vehicle trailers (where one set of wheels of the transported vehicle must be on the surface while being transported)
• Drivers operating vehicles manufactured before the model year of 2000

*Although these persons may be considered exempt, carriers are still encouraged to use ELDs even when not required.

Is the motor carrier or driver responsible for ensuring they have a registered ELD?

Either the motor carrier or owner-operator is responsible for ensuring their fleet is equipped with registered ELDs. Although the FMCSA will attempt to notify affected users on the removal of any registered ELDs, motor carriers are responsible for periodically looking through the registration and revocation list to ensure compliance. That list can be found here.

An ELD can produce and transfer ELD data records for the current 24-hour period a driver is operating a vehicle and the previous 7 consecutive days. An ELD must electronically transfer data to an authorized safety official using a predefined method established by the ELD provider using either a telematics or local method of transfer.

A driver using an ELD must have an ELD information packet with them at all times while operating a commercial motor vehicle. Any or all items may be maintained electronically. The packet must contain the following items:

• The user manual for the ELD being used
• An instruction sheet describing ELD-supported data transfer mechanisms and step-by-step instructions to produce and transfer the driver's HOS records to an authorized safety official
• A driver instruction sheet that contains ELD malfunction reporting requirements, including record-keeping procedures during ELD malfunctions
• A minimum of 8 days' worth of blank RODS graph-grids

Every motor carrier must retain ELD RODS data, including back-up data, for a minimum of six months. The back-up copy must be stored on a separate device. All kept records must be stored in a manner that protects driver privacy. A motor carrier must also retain a maximum of eight supporting documents for every 24-hour period a driver is on duty. A driver must submit their RODS and supporting documents to their motor carrier no later than 13 days after receiving them.

The driver must record the driving time as Off-Duty Personal Conveyance time on their ELD. There is no time limit on personal conveyance in the U.S.

Both a driver and an authorized carrier can make limited edits, such as correcting mistakes or adding information, to an ELD record or records. Any submitted amendments must include an annotation that justifies the amendment. Additionally, a driver must also submit their confirmation that a carrier edit is accurate.

A registered and certified ELD will automatically record the following:

• Date
• Time
• Location data (at 60-minute intervals when the vehicle is in motion)
• Engine hours
• Vehicles miles
• Driver, authenticated user, vehicle, and motor carrier identification information

An ELD must automatically switch to a driving status once the commercial vehicle is moving at five miles/eight kilometers per hour.

Not generally. However, there are limited exceptions that allow drivers or carriers to make limited fixes. This is only permissible in specific instances, such as when a driver mistakenly accepts a driving segment that doesn’t belong to them or as a correction of errors between team drivers.

ELD software can be on a smartphone, tablet, portable device, or another wireless device as long as the software meets technical standards laid out in the U.S. and Canadian ELD mandates. Any driver using a portable ELD must mount it in a fixed position visible from their normal seated position. It must remain mounted for the entirety of the time the driver is operating the vehicle.

Yes. An ELD must provide a mechanism for a driver to obtain a copy of the driver's own ELD RODS in electronic or print form. The driver must not be required to go through a motor carrier to obtain a copy of their RODS if they reside or are directly accessible through the ELD.

An ELD must not allow more than one driver account to be created under the same driver name and license number. A motor carrier must also establish requirements for unique user IDs and passwords.

An ELD records location data at 60-minute intervals when the driver powers the vehicle on and off, begins driving the vehicle, changes duty status or operating jurisdiction, and indicates personal use or yard moves. If a driver is using the commercial motor vehicle for personal use, location data is not recorded.

Yes, a driver visiting from Mexico and operating in the U.S. or Canada must use a certified ELD in order to remain compliant with U.S. and Canadian federal regulations.

Yes, an ELD must be synchronized with the associated vehicle's engine in order to automatically record engine power status, vehicle motion status, miles driven, and engine hours.